abn-2025-12-31-1-en

Strategic priorities

Grow profitably

Right-size cost base

Optimise capital
allocation


ABN AMRO	Annual Report 2025	6


≡	Our Bank	Interview with our Chief Executive Officer

Interview with our Chief Executive Officer

Marguerite Bérard | CEO of ABN AMRO

“Strategy is

the first 20%.

Execution is

the rest”

Marguerite Bérard has outlined clear goals for ABN AMRO. As she reflects

on her first year as Chief Executive Officer, she explains her vision for the

bank and why it all comes down to execution. “We have an ambitious

strategy and talented people. Now it’s time to deliver.”

What kind of year was it for you as incoming CEO?

“Personally, I am grateful for the warmth with which

I have been welcomed at the bank and in the

Netherlands. I found ABN AMRO to have strong brands

and people who genuinely care about the bank. It’s a

privilege to stand alongside such talented colleagues.

2025 was a successful year with many highlights.

Amid profound geopolitical and economic change,

we managed to deliver a strong performance.

A major milestone was the launch of our new strategy

with clear targets and a solid plan to right-size our cost

base, optimise capital allocation and grow profitably.

We also shared our five ambitions for 2028 and beyond.

We want to strengthen our position in Dutch retail

banking. We aim to become a top‑five European private

bank. We will continue to support family wealth and

businesses – the true backbone of the economy.

We will support Europe’s autonomy by financing key

transitions in digitalisation, energy, mobility and

defence. And finally, we will invest to maintain our

global top‑three position in clearing.”

How do you view the commercial performance of

the bank in 2025, and what is next?

“We saw good performances in the areas where we

want to grow. As I mentioned, one of our five strategic

ambitions is to strengthen the Dutch retail bank’s

position, which benefitted from the strong housing

market. The bank is increasingly well equipped to

handle higher mortgage volumes, also through

intermediaries, with shorter turnaround times and

more dynamic pricing.

Our intended acquisition of NIBC will give us additional

scale and we will further build on our digitalised service

model and premium touch client experience. Together,

these strengths will help us deepen client relationships

and accelerate profitable growth.


ABN AMRO	Annual Report 2025	7


≡	Our Bank	Interview with our Chief Executive Officer

Demand in the European transition sectors we focus on

is growing faster than the broader economy. The energy

transition illustrates this shift and is also guiding our

sustainability efforts, which are moving from a broad

approach to concretely helping clients reduce their CO₂

emissions. Financing of energy, digital and mobility has

already increased at Corporate Banking.

Finally, Wealth Management delivered a good year.

Market performance contributed, but above all, our

teams became more commercially effective: we

significantly increased the number of weekly client

meetings, improved follow-up, and focused on guiding

clients from savings to investment solutions that can

create more long-term value. We worked to support

family wealth and businesses, and move closer to

becoming a top-five European private bank – both

ambitions will be accelerated by the integration of

Hauck Aufhäuser Lampe in Germany.”

“To remain competitive

and add value for clients and

other stakeholders, we need

to prioritise.”

What was the biggest dilemma you faced in your

first year?

“To remain competitive and add value for clients and

other stakeholders, we need to prioritise. That means

identifying what the bank does best, investing in areas

of strength and having the discipline to end activities

that no longer contribute to our goals. Saying goodbye

to long‑standing clients and colleagues is never easy.

For example, we took the decision to wind down our

asset-based finance activities in Germany, the UK and

France, to discontinue the Moneyou brand and to

sell Alfam.

We also announced a workforce reduction of

approximately 20% by 2028. These are difficult

decisions. We make them carefully and ensure that we

always act transparently and respectfully towards those

who are impacted. But holding on to everything simply

because it has always been there would not be the right

thing to do for the bank.”

What makes you confident the bank can meet

its targets for 2028?

“Our strategy is ambitious, yet achievable. All our

ambitions and plans are rooted in real business cases

from across the bank. Most of our plan relies on things

we can control. Moreover, the bank already started

delivering in 2025. We walk the talk. That is essential,

because strategy is the first 20%. Execution is the rest.

We are prioritising profitable growth that is less capital-

intensive than in the past, and we have shown good

progress in optimising our capital allocation and right-

sizing our cost base.”

“Banking isn’t just about

what we offer, it’s also about

how we offer it.”

ABN AMRO wants to differentiate itself with a

premium touch experience in retail and private

banking. Why is this important, and how will

clients notice?

“Banking isn’t just about what we offer, it’s also about

how we offer it. Clients will experience faster, more

efficient and more personalised services that show we

understand them and support their goals. It will also

involve making smart use of our investments in

generative artificial intelligence and other technologies.

Last year, for example, we created a GenAI avatar to

train contact‑centre staff through realistic scenarios,

launched our lending assistant Lenny to streamline

credit requests, and introduced a voicebot that

simplifies credit‑card servicing.

Technology helps us to further tailor our propositions,

provide advice based on better data insights and deliver

digital solutions that make everyday banking smoother.

And by scaling our challengers such as Tikkie, BUUT and

BUX, we’re strengthening our connection with the next

generation of clients. Ultimately, it’s the combination of

advanced technology and the expertise of our people

that creates the premium touch experience we want to

deliver.”

You plan to return more capital to shareholders.

What does that mean for other stakeholders?

“Investors are important, but so are all our other

stakeholders. During our Capital Markets Day, we

announced our intention to return more capital to

shareholders. This new capital distribution policy will

help us increase our valuation, allowing us to pursue our

own path and to continue adding value for our clients,

employees and society at large.”


ABN AMRO	Annual Report 2025	8


≡	Our Bank	Interview with our Chief Executive Officer

How does global volatility impact Europe's

businesses and what role can banks play?

“Europe is facing major geopolitical and economic

changes that are testing not only its resilience but also

the very values on which it is built: human dignity,

democracy and the rule of law. Defending those values

requires confidence to invest in Europe’s key transitions.

Europe must step up, and banks have a crucial role to

play. Banks are the plumbing of the economy. We can

direct the flow of capital to transition sectors such as

energy, digital resilience, sustainable mobility and

defence to help reinforce Europe’s strategic autonomy.”

“Europe is facing major

geopolitical and economic

changes that are testing not

only its resilience but also

the very values on which it

is built: human dignity,

democracy and the rule

of law.”

Supervisory Board Chair Tom de Swaan will be

leaving the bank this year. How do you reflect on

his role?

“Tom has been an anchor for ABN AMRO during some

of the most challenging periods in our recent history,

and I am deeply grateful for the way in which he

supported me personally during my first year as CEO.

Under his chairmanship, the foundations of the bank

have been profoundly strengthened. I would like to

sincerely thank Tom for his dedication and unwavering

commitment to the bank. At the same time, I am

looking forward to working with his successor as we

lead ABN AMRO into its next phase of growth.”

What is your main priority in 2026?

“Now that we have presented our strategy, our focus is

on disciplined execution. Change is not always

enjoyable and can become tiring over time. But it’s like

working out: you have to stop talking about it and

actually get started – running five minutes the first day,

ten minutes the next, and so on. As we start delivering,

we will prove to ourselves that we can do it and that will

build our confidence. We have everything we need to

thrive. We have strong roots to grow from: a diversified

business model, solid market positions and balanced

risk management. We operate in markets with robust

fundamentals; we have a strong presence in key

transition themes and are well positioned for

international growth in clearing and wealth

management. Now it’s time to focus our energy,

execute on our bold choices and work together to

bring our ambitions to life.”


ABN AMRO	Annual Report 2025	9


≡	Our Bank	Who we are	Our ambitions

Who we are

ABN AMRO is there for everyone with a drive to move forward, serving over

five million clients in the Netherlands and Northwest Europe. We use our

expertise to support clients in their financial decisions – whether it’s buying

a house, starting a business, or making investments – and in doing so, we

create long-term value for them, our colleagues, investors and society at

large. More than 20,000 employees deliver retail, corporate and private

banking services with a clear purpose: Banking for better, for generations

to come.

Our ambitions

The strategy we presented in 2025 builds on the bank’s

strong foundations: a diversified business model, solid

market positions and balanced risk management. It sets

new priorities for 2026-2028, supported by enablers

that will help us deliver on them and guide us towards

our five longer‑term ambitions for 2028 and beyond.

You can read more about our ambitions and 2025

results in the Strategy & performance chapter.


Enablers

	Technology & data	Risk management	People & performance	Sustainability


Strategic ambitions

	Strengthen the Dutch retail bank	Become a top-5 private bank in Europe	Support family wealth and businesses	Finance European transitions	Grow our clearing bank


ABN AMRO	Annual Report 2025	10


≡	Our Bank	Who we are	Our business model

Our business model

ESRS

ABN AMRO offers banking services

to people and businesses. We earn

money from the interest clients pay

on mortgages and loans, and from

fees and commissions for other

services.

Our loans to clients are funded by deposits and money

borrowed from capital markets. We pay interest on

these sources of funding. The difference between the

interest we earn on loans and the interest we pay on

deposits and capital market funding is our net interest

income.

We also earn money from fees and commissions

through transaction banking, wealth management,

advisory services, clearing and capital markets.

We carefully manage the risks of providing loans and

use the money we earn to pay for our costs, reinvest

in the bank and deliver returns to our investors.

Operating income by type (2025)

Operating income by client unit (2025)



	This is where we operate ABN AMRO serves clients mainly in the Netherlands and Northwest Europe. Besides 26 locations in the Netherlands, we have branches in Belgium, France, Germany, Greece, Luxembourg, Norway and the United Kingdom. Outside Europe, ABN AMRO Clearing Bank has offices in Asia Pacific and the Americas. Amsterdam Headquarters Personal & Business Banking Wealth Management Corporate Banking


	The Netherlands: Personal & Business Banking, Wealth Management, Corporate Banking Belgium: Wealth Management, Corporate Banking France: Wealth Management, Corporate Banking Germany: Wealth Management, Corporate Banking Greece: Corporate Banking Luxembourg: Wealth Management Norway: Corporate Banking United Kingdom: Corporate Banking Outside Europe, ABN AMRO Clearing Bank N.V. has offices in Australia, Brazil, Hong Kong, Japan, Singapore and the United States.


ABN AMRO	Annual Report 2025	11


≡	Our Bank	Who we are	Helping our clients move forward

Helping clients move forward


Personal & Business Banking

We offer payment and savings accounts, credit cards, mortgages, loans, investment accounts and insurance to 5 million clients in the Netherlands. We also provide banking and payment services to over 350,000 small and medium-sized enterprises – the backbone of the Dutch economy.			We combine easy-to-use digital services with expert advice. For clients who experience difficulties using our services, we provide assistance online, in a branch or at their home.
					Chief Commercial Officer Annerie Vreugdenhil
					Chief Commercial Officer Annerie Vreugdenhil

	Operating income (EUR million)			Operating expenses (EUR million)
	3,873	2024: 3,932		2,404		2024: 2,451



	Operating result (EUR million)			Residential mortgages (EUR billion)
	1,469	2024: 1,481		163		2024: 156


Wealth Management

We provide private banking in the Netherlands, Germany, France and Belgium, supported by strong local brands. In total, we manage EUR 283 billion in investments for our clients. Wealth Management offers services such as investment advice, asset management and estate planning.			Wealth Management serves around 150,000 clients across the Netherlands and Belgium (ABN AMRO MeesPierson), France (Neuflize OBC) and Germany (Bethmann HAL).
					Chief Commercial Officer Choy van der Hooft-Cheong
					Chief Commercial Officer Choy van der Hooft-Cheong

	Operating income (EUR million)			Operating expenses (EUR million)
	1,693	2024: 1,568		1,302		2024: 1,092



	Operating result (EUR million)			Client assets (EUR billion)
	391	2024: 476		283		2024: 239


ABN AMRO	Annual Report 2025	12


≡	Our Bank	Who we are	Helping our clients move forward



Corporate Banking

We support around 10,000 mid- to large-corporate clients in Northwest Europe with financing, advisory, transaction banking and capital market access. A key ambition is to finance Europe’s transitions in energy, mobility, digital and defence. We also focus on family-owned businesses, jointly supporting entrepreneurs and advising on intergenerational			transfer with Wealth Management. We are one of the world’s leading clearing providers, processing trades across markets and providing services to investment firms, brokers and trading institutions.
					Chief Commercial Officer Dan Dorner


	Operating income (EUR million)			Operating expenses (EUR million)
	3,160	2024: 3,358		1,776		2024: 1,802



	Operating result (EUR million)			Client loans (EUR billion)
	1,384	2024: 1,556		57		2024: 61


	Group Functions

	ABN AMRO’s three client units are supported by Group Functions to ensure integrated and efficient service delivery. The majority of Group Functions’ costs are allocated to the three client units. Group Functions includes departments such as: • Brand, Marketing & Communications • Finance • Group Audit • Group Economics • Human Resources • Innovation & Technology • Legal & Corporate Office • Risk Management • Strategy & Transformation • Sustainability Centre of Excellence				Internal employees by client unit in FTEs


ABN AMRO	Annual Report 2025	13


≡	Our Bank	Who we are	Putting our values to work

Putting our values to work

Our values are more than just words. They shape how we support our

clients and each other, guide us through dilemmas and set high standards

for today and beyond: Banking for better, for generations to come.

Our Values@Work help us bring this purpose to life.


We stand up for what’s right		We own it and make it happen		We help others move forward

Stakeholders

We aim to create long-term value for all our

stakeholders. By providing financial solutions to

individuals and businesses, we contribute to a strong,

resilient economy.

Our products and services are designed to help a broad

range of clients manage their finances with ease, now

and in the future.

Our employees are vital to everything we do. We offer

meaningful career opportunities, attractive benefits and

a supportive, safe and inclusive workplace.

For our investors, we aim to deliver sustainable

financial performance by managing the bank

responsibly and maintaining a focus on long-term

growth.

We strive to increase our positive impact on society and

reduce the adverse effects our activities may have on

people and the environment.

Read more in the How we create value for

our stakeholders section.




Clients	Employees	Investors	Society

Individuals, small and medium-sized enterprises, large companies and non‑profit organisations	Internal and external employees, including consultants and temporary staff	Holders of bonds, shares and depositary receipts for shares	Suppliers, business partners, communities, governments, regulators and non‑governmental organisations


ABN AMRO	Annual Report 2025	14


≡	Our Bank	Who we are	Our people

Our people

Our people are the key to our success and help us grow in a world that is

changing rapidly. We believe that diverse and inclusive teams foster

innovation, support personal development and improve decision-making.

Employment Engagement Survey

We regularly ask our colleagues about their experience

of working at the bank. This Employment Engagement

Survey includes questions about teamwork, feedback

and feeling heard and valued, but also topics such as

our strategy, collaboration and leadership.

The engagement of our staff remained strong over

2025 but declined to 79% from 82% in 2024. Find out

more in the Performance on our strategy chapter.

Women in management

In 2025, the number of women in our Dutch middle

management increased to 31% from 30% a year earlier

but still fell short of our target of 35%. We offer

workshops and coaching to help women develop their

careers and raise their visibility across the bank. You can

read more about this topic in the Sustainability section.

Simplifying the organisation

In April 2025, we tightened our hiring controls and

restricted the conversion of fixed-term contracts to

permanent positions to help manage costs. We also

reduced the number of external employees. The charts

below show how this influenced workforce

composition, including a decline in external staffing,

and how these measures affected numerous colleagues

across the organisation. But these steps also helped the

bank to further develop its own talent and rely less on

outside experts.

Under the new strategic plan, we will further simplify

the organisation and reduce global staff by about 20%

by 2028, with about half of the reductions expected to

occur through attrition. Staff will be treated

transparently and responsibly, in line with the bank’s

and local standards throughout this transition. In the

Netherlands, for example, the bank and labour unions

agreed to extend the Social Plan for staff by three years.



Our people
2025 employee engagement score				Gender diversity across internal employees
				Middle management



	79			All employees
	79
		2024: 82

Internal employees			External employees

35%

2025 target

Internal & external full-time equivalents excluding HAL acquisition


	Permanent contract		Fixed-term contract


ABN AMRO	Annual Report 2025	15


≡	Our Bank	Year in review

Year in review




	Board changes Marguerite Bérard succeeded Robert Swaak as Chief Executive Officer at the Annual General Meeting of Shareholders (AGM) on 23 April 2025. Daniel Hartert was appointed to the Supervisory Board on 11 September 2025, succeeding Arjen Dorland. In November, Chief Operating Officer Ton van Nimwegen announced he would step down on 1 January 2026. On 29 January 2026, Michiel Lap was nominated to succeed Supervisory Board Chair Tom de Swaan, who retires at the AGM on 22 April 2026 after almost eight years. In addition, Jean-Pierre Mustier was nominated for appointment to the Supervisory Board at the AGM, subject to regulatory approval.

New strategy: profitable growth,

capital efficiency and lower costs

We presented a new strategic plan for 2026-2028

aimed at delivering profitable growth and enhanced

value for all stakeholders. At our Capital Markets Day

on 25 November 2025, we outlined three strategic

priorities: profitable growth, right-sizing the bank’s cost

base and deploying capital where it generates the

highest returns. The plan includes a net reduction of the

workforce by 5,200 full-time equivalents (FTEs) by 2028

compared with 2024, with half of the reductions

expected to occur through attrition. Read more about

the strategic plan, our financial targets and our long-

term ambitions in the Our strategy section.



	27.5%
	Dutch State reduces stake The Dutch State reduced its stake in ABN AMRO from 38.5% in 2024 to 27.5% at the end of 2025. In September 2025, the holder of the Dutch State’s stake (NLFI) announced that it aims to further reduce its stake to around 20%. Since NLFI’s stake has fallen below one third, the bank no longer requires NLFI’s approval for investments or divestments with a value of more than 10% of the bank’s share capital. NLFI’s approval is also no longer required for the issuance of, or the granting of rights to acquire, shares in the bank. The Dutch State, which acquired the bank in 2008, began reducing its stake following ABN AMRO’s stock market listing in 2015.

NIBC to boost our market

position

On 12 November 2025, ABN AMRO reached an

agreement with US asset manager Blackstone to

acquire NIBC Bank N.V. in The Hague. NIBC specialises

in savings products, mortgages and lending for

commercial real estate and digital infrastructure.

The intended acquisition will add further scale to our

Dutch retail banking activities and strengthen our

market position in mortgages and savings. We expect

the transaction to enhance our profitability.

The estimated price is around EUR 960 million, or

0.85 times NIBC’s book value, subject to final

adjustments. We aim to complete the acquisition in

the second half of 2026, pending regulatory approval.


ABN AMRO	Annual Report 2025	16


≡	Our Bank	Year in review

Hauck Aufhäuser Lampe

We completed the acquisition of Hauck Aufhäuser

Lampe (HAL) in July 2025 following regulatory

approval. The combination with Bethmann Bank

creates a strong top-three player in Germany, with

over EUR 70 billion in assets under management and

around 2,000 employees across 18 locations in

Germany and Luxembourg. We will operate under a

two-brand strategy in the region: Bethmann HAL for

wealth management and ABN AMRO for corporate

banking. Read more in the interview with HAL CEO

Michael Bentlage.

Solid market share in mortgages

We maintained our share of new Dutch residential

mortgages at 19% in 2025. Changes we made to our

mortgage conditions had a positive effect, especially in

attracting new clients applying through intermediaries.

For example, we now automatically reduce the risk

premium as clients repay their mortgage. The premium

is reviewed every month, rather than only at the end of

a fixed interest-rate period as was previously the case.



	EUR 250 mln

	Share buyback In September, we completed our fourth share buyback. Under the EUR 250 million programme, almost 10 million shares were purchased at an average price of EUR 25.39. Since the start of the first share buyback programme in 2022, almost 117 million shares have been repurchased.




	Welcome, BUUT Our new bank for younger generations, BUUT, was launched in September. The mobile app is designed for teenagers and their parents. It helps young people manage their money with tools like handy pots for saving and payments. The app is simple to use, visually engaging and tailored to the lifestyle of the younger generation. It also offers financial tips from experts, peers and educators, helping parents and teenagers learn about money together.




	Investing in carbon reduction Our Sustainable Impact Fund (SIF) led the majority of an investment round in Converge, a British developer of technology to reduce carbon emissions from concrete production, that totalled GBP 17 million. Concrete production accounts for about 8% of global carbon emissions, making it a key focus for decarbonisation. Through AI, sensors and software-as-a-service, Converge helps contractors make faster, data-driven decisions, reduce embodied carbon and minimise resource waste. You can read more in the Performance on our strategy chapter.


ABN AMRO	Annual Report 2025	17

Strategy & performance


Economic outlook	50


ABN AMRO	Annual Report 2025	18


≡	Strategy & performance	Our strategy

Our strategy

ABN AMRO is there for everyone with a drive to move forward. We use our

expertise to support clients in their financial decisions – whether buying a

house, starting a business or making investments – and in doing so, we

create long-term value for them, our colleagues, investors and society at

large. This reflects our purpose: Banking for better, for generations to come.

New strategic plan

Over five million clients across the Netherlands and

Northwest Europe trust us to deliver seamless service,

expert personal advice and tailored solutions, from

helping teenagers manage their money to finding

answers to complex financial challenges. Delivering this

premium touch is at the heart of our strategy.

In November 2025, we presented our strategic plan for

2026 to 2028. It builds on ABN AMRO’s strong

foundations: a diversified business model, solid market

positions and balanced risk management. The plan sets

out our priorities and the enablers that will help us

achieve them, guiding us towards our five long-term

ambitions. For details on our 2025 performance, see the

Performance on our strategy chapter.

Building on strength

While the plan looks ahead, it also gives due regard to

the pillars of our previous strategic period: customer

experience, future-proof bank and sustainability. These

strategic pillars, which spanned the period from 2021

to 2025, are also reflected in the new priorities and

enablers.

Over recent years, we have enhanced the customer

experience, laying the groundwork for our premium

touch proposition.

Since making sustainability part of our strategy, we have

built a strong foundation through innovative products,

reporting and sector expertise. Under the new strategic

plan, we have made sustainability a key enabler of our

business.

We are continuing on our path to becoming a future-

proof bank. This includes investing in our technology-

driven offerings that challenge traditional ways of

banking.

Our priorities

Our priorities for 2026 to 2028 are profitable growth,

right-sizing our cost base and optimising capital

allocation. These priorities will help us fulfil our long-

term ambitions for 2028 and beyond.

Our ambitions

Strengthen the Dutch retail bank

We continue to build on our leading position in retail

banking in the Netherlands. Our strong brand, digital

capabilities and client focus will help us to expand our

mortgages and deposits, strengthen relationships and

remain a trusted partner for households and businesses.

We expect that the intended acquisition of Dutch bank

NIBC will enable us to grow and deliver more value for

our clients.

Become a top-5 private bank in Europe

Already the Dutch market leader in wealth

management, we are also growing our business at

home and across Europe following the acquisition of

Hauck Aufhäuser Lampe. We focus on entrepreneurs,

women and next generation clients to become one of

the top-5 European private banks. By expanding our

offering and investing in digital tools, we are ready to

meet our clients’ changing needs.

Support family wealth and businesses

ABN AMRO and its predecessors have supported

generations of entrepreneurial families in managing

their personal and business finances. Our private and

corporate bankers collaborate to help families seize

commercial opportunities and preserve their financial

success. Our strong client network will help target new

customers in the ongoing multi-trillion-euro wealth

transfer across Europe to build strong and lasting

relationships across generations.

Finance European transitions

Europe is changing in key areas such as energy,

mobility, digitalisation and defence. We will support


ABN AMRO	Annual Report 2025	19


≡	Strategy & performance	Our strategy

these transitions with our specialised finance and

advisory services. We aim to achieve EUR 8 billion in

renewable energy financing by 2028 and EUR 10 billion

by 2030, contributing to the European Union’s

sustainability and future-proof goals.

Grow our clearing bank

ABN AMRO Clearing Bank is one of the world’s leading

clearing providers. We are strengthening our top-3

position as a facilitator of global trade in a fast-growing

market by investing in technology, broadening our

client base and venturing into new markets. We offer

clearing, settlement and other services for a wide range

of financial instruments, from derivatives and securities

to over-the-counter products and exchange-traded

funds.

Enablers of our strategy

We aim to realise our strategic ambitions through

innovation, empowering talent, proactive risk

management and integrating sustainability.

Technology & data

We aim to strengthen client engagement through

digitalised services, delivering premium experiences

with personalised data-driven insights. We plan to boost

efficiency and innovation by using GenAI to optimise

processes and empower client-facing staff. We

continue to invest in technology-driven solutions for

growth, scaling next-generation propositions such as

Tikkie, BUUT and BUX, while maintaining our position as

a trusted, secure digital bank with robust platforms.

People & performance

We aim to optimise our workforce by simplifying

operations, investing in critical skills such as data, digital

and artificial intelligence, and redesigning work to

enhance human-machine collaboration. At the same

time, we aim to foster a culture of accountability and

performance, stimulate cross-group collaboration and

attract and retain talent.

Risk management

We focus on lower-risk core activities such as Dutch

mortgages and corporate lending in the Netherlands

and Northwest Europe, while diversifying our income

through Markets and Clearing. At the same time, we are

positioned for deliberate growth in European

transitions, leveraging our commercial, sustainability

and risk expertise, supported by proactive risk

management and a control framework.

Sustainability

Sustainability is a key enabler of growth, with a focus on

decarbonisation. We have integrated sustainability into

functions across the bank, developing a strong capacity

in our client units and other departments, including Risk

Management and Finance.

Help clients achieve climate targets

Whether it is homeowners upgrading their energy-

efficiency labels or businesses adopting more efficient

processes, we aim to facilitate the necessary emissions-

reducing initiatives. Supporting our clients’ emissions

targets helps us move closer to our own long-term

ambition: reaching net-zero emissions by 2050.

Any emissions pathway must be both credible and

achievable if it is to support an orderly and sustainable

transition towards net-zero emissions. In November

2025, we announced our intention to update our

climate strategy to align with a well-below-2°C

pathway, in line with the Paris Agreement’s goal to limit

global warming.

Public policy commitments and regulatory

developments remain key drivers of the pace at which

our clients can transition. As current policies are

primarily geared towards staying well below 2°C, we

aim to align with this pace to ensure our plans remain

realistic for both our clients and ourselves. In sectors

and activities where public policy and technological

developments enable faster decarbonisation, we will

continue to strive for 1.5°C alignment.

To support this, we plan to monitor the absolute

greenhouse gas emissions of companies, activities and

projects we finance or invest in. This can help us avoid

blind spots and create more opportunities to support

our clients’ decarbonisation. You can read more in the

Sustainability Statements.

Financing the transition

Decarbonising the economy means not only financing

low- or zero-emission activities but also supporting

transitions in higher-emission sectors where we have

expertise. While our Sustainability (acceleration) asset

volume (SAS) helps classify loans and investments with

a sustainability component, we aim to strengthen the

link between our climate targets and clients’ emission

reduction efforts.

To support this, we plan to develop a transition finance

framework, which will require a refinement of our

current sustainable finance framework. The transition

finance framework will classify and enable financing for

activities that credibly cut emissions in line with climate


ABN AMRO	Annual Report 2025	20


≡	Strategy & performance	Our strategy

pathways, alongside already sustainable initiatives

aligned with regulatory definitions.

As part of our commercial efforts, we previously

announced initiatives to help Dutch homeowners invest

in energy efficiency, including a pricing model that

rewards improvements in their home’s energy label. In

the coming years, we aim to make further efforts in

reducing the carbon footprint of specific high‑emission

sectors. At the same time, we remain steadfast in our

dedication to renewable energy financing, setting an

interim target of EUR 8 billion by 2028 as part of our

pathway to EUR 10 billion by 2030.

Although we focus on decarbonisation, we aim to

address other sustainability issues that are important to

clients and society. For example, improving home

energy efficiency not only reduces emissions and

energy bills but can also create a positive social impact

by addressing damp conditions and improving

occupants’ health, particularly in lower-income

neighbourhoods. Nature-related issues, such as cutting

nitrogen emissions and boosting biodiversity, are

important for our agricultural and other clients. We

continue to support businesses moving towards a more

circular way of working, although 2025 will be the final

year that we measure progress against our 2027

circular loans target. Clients face increasingly complex

challenges, and we aim to help them navigate these

when financing is needed.

Our sustainability focus for the next strategic period is

to help clients achieve their emission targets, supported

by new commercial initiatives.

Our goals

The strategic plan presented in November 2025 outlines our targets and

long‑term ambitions. The tables below show our progress on these goals.


Ambitions

Ambition	Metric	2025	Ambition (2028)
Strengthen Dutch retail banking position	Residential mortgages (in EUR billions)	163	> 190
Become a top-5 private bank in Europe	Client assets (in EUR billions)	283	> 335
Support family wealth & businesses	Dual relationships with:
	SME clients	68%	c.70%
	Corporate clients	55%	c.60%
Drive growth by supporting European transitions	Renewable energy financing (in EUR billions)	5.8	8
Continue global growth in Clearing	Global market share position	Top 3	Maintain top 3


Financial targets

Grow profitably	2025	Target (2028)
Return on equity	8.7%	> 12%
Operating income (in EUR billions)	8.7	> 10

Right-size cost base	2025	Target (2028)
Cost/income ratio	64.4%	< 55%

Optimise capital allocation	2025	Target (2028)
Capital allocation to Corporate Bank ¹	51%	c. 50%
Common Equity Tier 1 (CET1) ratio	15.4%	> 13.75%

The 2025 data related to our ambitions are included for reference only. For details on last year’s progress under the previous strategy (2021–2025), see the Performance on our strategy chapter. 1. Excluding ABN AMRO Clearing Bank N.V.


ABN AMRO	Annual Report 2025	21


≡	Strategy & performance	Our strategy	Interview Head of BUUT

Hein ter Braak | Head of BUUT

“The new generation

wants their banking to

fit their digital world”

Communicating through Snapchat,

shopping via TikTok, getting

Fortnite skins for your birthday and

carrying no cash at all – welcome

to the digital world of a new

generation. Welcome to BUUT,

a neobank built for young people

who expect their banking to be

intuitive, visual and interactive.

“Kids got it instantly and began

swiping money between pots.

Ironically, it was mostly the parents

we had to explain it to: ‘This is a

bank.’”

Hein ter Braak, who heads ABN AMRO’s new bank,

explains how the idea was turned into a product in less

than a year. “BUUT is built on three key advantages:

first, the success of our peer-to-peer payment app

Tikkie, with over 10 million users, which shows how an

outstanding product and user experience can set a

brand apart. Second, having ABN AMRO as our sponsor

bank, providing its licence, regulatory expertise and

processing capabilities. And third, our modern tech

foundation, enabling us to scale quickly and

cost‑effectively.”

Snack or save?

The BUUT app was designed together with the target

group – children aged 10 to 16 and their parents.

“We constantly validated the concept with them.

We didn’t invent the product, they did,” says Ter Braak.

For instance, the ‘potjes’ (virtual pots) feature allows

children to visually label money, whether for snacks,

clothing or to save up for a new game console. “With

one card, they can pay from any payment pot they

choose, with money flowing out in real time. Seeing

exactly where it’s going and how much is left helps

encourage more thoughtful spending.”

Social media-style video clips explain everything from

discussing pocket money with parents to budgeting and

online scams. “Financial education flows naturally into

the experience. It’s about making money management

easy and even fun.”

Parents see their kids dealing with a world that looks

quite different from the one they grew up in. “The app

helps them talk about money with their kids. It includes

a parental interface where they can monitor spending

and transfer money into specific savings pots.”

Don’t mention the bank

BUUT was introduced in September 2025 as Tikkie’s

bank, not ABN AMRO’s. “Almost everyone in the

Netherlands knows the Tikkie app, but it’s not a bank.

Younger generations don’t want a traditional bank; they

want an intuitive product that fits seamlessly into their

lives,” says Ter Braak. “The BUUT brand also gives us the

flexibility to challenge industry norms and create

something unique for these generations.”

The team is working on new features and plans to open

up BUUT to young adults in 2026. The app’s design and

functionality will be tailored to match that age group’s

evolving financial needs. While teenagers prefer quick,

bite-sized information, older users look for more

advanced tools to help them save, invest or manage

their student loans. As their financial lives evolve, BUUT

will grow with them, Ter Braak promises.

But its impact for younger users is already clear. He

illustrates: “A 12-year-old called our customer support

desk the other day. He wanted to know if he could

charge his parents 9 euros for pulling weeds. Why

9 euros, we asked? It turned out he wanted to buy

something that cost 9 euros.” It shows that younger

generations do not necessarily want a bank, they want

answers to questions such as: how do I pay, how can I

save, am I spending too much? Meeting young clients in

their own space is what truly sets BUUT apart.”


ABN AMRO	Annual Report 2025	22


≡	Strategy & performance	How we create value for our stakeholders	Who are our stakeholders?

How we create value for

our stakeholders

Who are our stakeholders?

ESRS

We see our stakeholders as anyone who is affected by the bank’s activities,

products or services, or who could influence our ability to achieve our goals.

Our four main stakeholder groups are clients,

employees, investors and society, which includes public

institutions, regulators, media, governments, charities

and non-governmental organisations (NGOs).

ABN AMRO stays in regular contact with its stakeholders

through meetings, surveys, roundtables and

conferences.

These conversations help us improve our strategies,

policies and risk management. They also guide us in

making improvements to customer service, employee

working conditions and other areas. The table below

shows examples of how we engage with each of our

main stakeholder groups.


	Stakeholder group	How we engage	Key issues discussed

	Clients Individuals, small and medium-sized enterprises, large companies and non‑ profit organisations	• Regular client surveys • Contact centres • Video banking • In-person meetings	• Effects of interest rate and economic developments • Expansion of accessible digital banking • Transition to more sustainable business practices • Intergenerational transfer of wealth

	Employees Internal and external employees	• Employee engagement surveys • Employee engagement circles • Meetings with employee works councils, unions and other representative groups	• Compensation and personal recognition • The bank’s strategy and organisation • Use of generative artificial intelligence • Preparation for moving to new head office

	Investors Shareholders and bondholders	• Frequent roadshows • Investor conferences • Capital Markets Day 2025 • Annual General Meeting (AGM)	• Financial performance & strategy • Business, regulatory and market developments • Capital allocation and distribution • Environmental, social and governance topics

	Society Suppliers, business partners, communities, government authorities, regulators and NGOs	• Regular meetings with government representatives and regulators • Industry roundtables and conferences • In-person meetings with suppliers and business partners • Banking for better days initiative	• Measures to combat financial crime • Regulations affecting banking sector • Resilience, financing of defence sector • Sustainability of value chains • Accessible digital banking for all clients
Please note, this table is intended to be an overview only. It does not provide an exhaustive list of issues discussed with stakeholders during the year. Clients includes clients from Personal & Business Banking, Wealth Management and Corporate Banking units. For more information on our approach to stakeholder engagement, see the Sustainability Statements chapter.


ABN AMRO	Annual Report 2025	23


≡	Strategy & performance	How we create value for our stakeholders	Who are our stakeholders?

Our value creation model

We aim to create sustainable long-term value for all our

stakeholders by increasing our positive impact and

reducing the adverse effects our activities may have on

people and the environment. For example, we

contribute to the economy by providing loans to

companies and individuals. Our financial products and

services help our clients to manage their money, save

and invest for the future. We offer employees

opportunities to advance in their career and create a

safe and welcoming environment for them to work in.

However, we also understand that some of our activities

can have negative effects. For example, lending to

industrial companies could contribute to climate

change.

The four steps of our value creation model

Our value creation model explains how the bank

creates value for clients, employees, investors and

society. It is broken down into four types of resources,

or ‘capitals’: commercial, social, natural and human

capital.

The next page shows our value creation model, which

consists of the following steps.

• Inputs are the resources we need to operate the

bank, ranging from the time, skills and know-how of

our employees to the equity provided by the bank’s

investors.

• Business model shows how our work transforms

inputs into stakeholder value.

• Outputs are the direct results of what we do. They

include the loans and mortgages we offer to our

clients and the salaries and benefits we offer our

employees.

• Outcomes show how our business activities affect

stakeholders. For example, our products and services

can help clients save and invest, while our mortgages

support home ownership and provide a sense of

financial security.

The model also shows how ABN AMRO contributes to

the United Nations Sustainable Development Goals

(SDGs).


ABN AMRO	Annual Report 2025	24


≡	Strategy & performance	How we create value for our stakeholders	Value creation model


Our value creation model for 2025
The resources we need to operate our activities, ranging from the time, skills and know-how of our employees to the equity provided by the bank’s investors. This overview contains a selection of metrics to portray our value creation.
Commercial Deposits, savings and fee payments from clients, financial capital from shareholders, offices, IT and intangible assets • EUR 256.2 billion due to customers and EUR 6.5 billion in net interest income (NII) • EUR 26.1 billion in shareholders’ equity • 25 bank branches across the Netherlands • EUR 1 billion spent on IT during 2024 and EUR 253 million in intangible assets			Social Relationships with clients, employees, business partners and other stakeholders • 11 lending clients and 738 companies engaged regarding ESG through investment services • EUR 1.3 million in community investment made through ABN AMRO Foundation
Natural Our consumption of energy, water and other natural resources • 54 GWh of energy used at our branches, offices and for transportation			Human Employees’ time, skills and expertise, as well as investment in workforce training and development • 21,976 total number of internal employees in 2024
This is our ‘engine room’ – it shows how our activities transform inputs into value for stakeholders
Our purpose Banking for better, for generations to come			Our business activities Banking services We provide banking services to individuals and businesses. Most of our revenue comes from net interest income. We also receive fees and commissions in return for our services. Funding and managing risk We fund our loans through deposits, savings and capital markets – and actively manage the risks associated with them. Reinvesting and sharing returns From our income, we meet our operating costs, reinvest in our business and pay out returns to our investors
Our strategic pillars

Customer experience	Sustainability	Future-proof bank

The immediate results of our activities: the loans and mortgages we provide to clients or the salaries and benefits we pay employees
Commercial • EUR 8.0 billion interest paid to clients and counterparties • EUR 2.0 billion payments to investors • EUR 0.8 billion paid in corporate income tax • 99.91% availability of internet banking • 90% of affluent & 81% of consumer meetings held via video banking			Social • 200 Help with Banking Advisers supported clients 174,000 times
Natural • 37% sustainability (acceleration) asset volume • EUR 274 million committed to circular economy deals in 2025 in more than 42 deals • Progress on our climate targets (see Sustainability Statements)			Human • EUR 2.3 billion paid to employees in salaries and wages • 23,126 total number of internal employees in 2025

The effects of our activities on stakeholders – the fact, for example, that our products and services may help clients save and invest, or that, through home ownership, our mortgages may provide a greater sense of personal financial security
Commercial • EUR 2.45 earnings per share • 8.7% return on equity • 187 privacy-related client complaints (0 substantiated) • 186 client complaints relating to breaches of other regulatory or voluntary codes in the Netherlands (2 substantiated)			Social • 31% women in middle management • NPS scores • 1 Personal Banking • -27 Business Banking • 26 Wealth Management • 21 Corporate Banking
Natural CO2 emissions from our • scope 1 own operations 1.3 kton CO 2 • scope 2 own operations 0.9 kton CO2 (market-based) and 8.5 kton CO2 (location-based) • scope 3 own operations 20.7 kton CO2			Human • 79% employee engagement score • 1,150 more internal employees


Supporting the UN Sustainable Development Goals (SDGs)
	SDG 8 - Decent work and economic growth	SDG 12 - Responsible consumption and production	SDG 13 - Climate Action
	By lending to companies and other clients, we support economic growth and job creation. We also apply minimum labour standards and human rights to our loans and support initiatives to bring more disadvantaged people into the workforce.	ABN AMRO provides transition loans to help companies adopt more sustainable business practices. We also invest in the circular economy, providing loans to companies that reduce waste and consumption of scarce natural resources.	ABN AMRO works closely with businesses to help them reduce carbon emissions and move towards net-zero. We help finance greater energy efficiency in homes and commercial properties. We are also introducing measures to reduce our own carbon footprint.


ABN AMRO	Annual Report 2025	25


≡	Strategy & performance	Performance on our strategy

Performance on our strategy

Our purpose, ‘Banking for better, for generations to come’, provides clear

guidance for our strategy and how we deliver it. In this chapter, we report

on our strategic performance in 2025. You can read more about the

strategic plan for 2026 to 2028 in the Our strategy section.

Strategic pillars 2021-2025

The three pillars of our strategy described below have

acted as our guiding principles in executing our strategy

during the past five years.

Customer experience

The first pillar is customer experience. We focus on

helping clients in areas where we can provide the most

value and make daily banking easier. Our goal is to give

clients expert advice when it matters most. We use

generative artificial intelligence to improve our services

and make them more personalised. We have also

increased support for clients who have difficulty using

our banking services. Protecting client assets and data

from security risks and cyber attacks is a key priority

for us.

Sustainability

Our second pillar is sustainability. We aim to make a

difference through our lending and investment services

and by supporting our clients in their sustainability

transition. Our climate strategy supports the transition

to a net-zero economy by 2050 by aligning our portfolio

with the Paris Agreement’s goal to limit global warming.

Alongside our climate approach, we also want to help

enable our clients’ circular transition by financing

companies that reuse waste materials and reduce

pressure on scarce natural resources. We aim to support

efforts to halt and reverse biodiversity loss by engaging

with business clients in the agriculture & food and

transport sectors. We support meaningful social impact

by addressing inequality, respecting human rights and

promoting financial resilience and inclusion.

Future-proof bank

Our third pillar is building a future-proof bank:

enhancing our processes, compliance and efficiency.

To do this, we are simplifying the organisation,

modernising our IT systems and aiming to reduce our

cost base. We are streamlining our product offering and

improving processes through simplified financial

solutions and digital personal services. This helps us

reduce maintenance costs, lowers time to market and

simplifies working with partners. We are building

a workforce fit for the future and are committed to

maintaining a strict risk focus.


ABN AMRO	Annual Report 2025	26


≡	Strategy & performance	Performance on our strategy	Customer experience

Customer experience

For over two centuries, ABN AMRO and its predecessors have evolved to

meet the changing needs of their clients. Whether online, in a branch, at

home or at the client’s place of business, we aim to provide personal,

efficient and convenient service to help our clients move forward.

Client service model

ABN AMRO’s service model combines convenience and

expertise to offer our clients:

• Self-service via our online banking and mobile app

• Support through contact centres and chatbots

• Advice through meetings and video banking

We measure the performance of our customer

experience using the Net Promoter Score (NPS).

Innovating with generative AI

In 2025, ABN AMRO continued to invest in improving

client services for retail and business clients. Generative

artificial intelligence (GenAI) helped to improve both

efficiency and client satisfaction in 2025. We started

using a GenAI avatar to help train contact centre

employees through realistic scenarios. This training has

been motivating for new hires while helping

experienced colleagues to answer client questions

more effectively. The training platform was developed

by Convergent AI, a fintech startup supported by

ABN AMRO through the Techstars startup accelerator.

We also introduced a GenAI-powered voicebot for

International Card Services, which identifies credit card

users and deals with their needs securely and quickly.

This innovation simplifies calls for clients and saves time

for staff. Soon, the voicebot will handle a wider range of

service requests independently, improving convenience

further.

Chatbot Anna made notable progress in 2025 as a

leading GenAI application at ABN AMRO. Over the year,

the proportion of client questions answered with

generated responses increased from 0% to 9.3%,

across a total of 1.56 million conversations. Anna was

able to handle more complex and less frequently asked

questions as well, improving client service while

reducing workloads.

You can read more about our use of GenAI in the

Future-proof bank section. Even as we boost efficiency,

we are still here to help clients who struggle with digital

banking. See the Sustainability section for more details.

Speeding up businesses

Online business-to-business sellers often require

upfront payments while buyers prefer to pay via

invoices. To address this, ABN AMRO introduced a pay-

on-invoice solution (‘Achteraf betalen’ in Dutch). This

solution can be integrated into webshops in the

Netherlands, allowing immediate receipt of payments

for sellers and flexible and secure payment for buyers.

The service builds trust between sellers and buyers and

increases conversion rates. ABN AMRO plans to expand

this solution through partnerships with payment service

providers and corporate banking clients.

In 2025, ABN AMRO launched the SME Takeover Desk

to support small and medium-sized enterprises with

acquisitions. Offering flexible financing from

EUR 250,000 and regional expertise, the desk serves as

a platform for business owners and their auditors and

brokers, ensuring fast and expert assistance throughout

the acquisition process.



	Tikkie, our peer-to-peer payment app with over 10 million users in the Netherlands, processed a record number of 694,577 transactions on King’s Day 2025. With more than 170 million payments processed during the year, Tikkie has now reached 1 billion transactions since its launch in 2016.

Expatriate clients

In 2025, ABN AMRO further strengthened its position

for expatriate clients and their families living in the

Netherlands. These enhancements included video

banking, expanded mobile app options, webinars and

in-person services. We offer specialised advice to

expats at eight of our 26 Dutch branches, including a

new branch at the High Tech Campus in Eindhoven. This

personalised approach resulted in a transactional Net

Promoter Score of +80, reflecting high client

satisfaction and the likelihood of expatriates

recommending our services.

¹ BearingPoint’s 2025 Digital Leaders Study for the Netherlands.


ABN AMRO	Annual Report 2025	27


≡	Strategy & performance	Performance on our strategy	Customer experience

Solid market share in mortgages

Our share of new residential mortgage production in

the Netherlands remained solid at 19% in 2025,

reflecting our continued strong position in a competitive

market. We offered interest-rate discounts to eligible

clients who financed energy-efficient homes with

energy labels A or B, or who were upgrading to those

labels. By the end of 2025, 28% of our mortgage

portfolio benefitted from a sustainability discount,

compared with 24% a year earlier.

Banking for younger generations

BUUT, our new bank for younger generations, opened

its mobile app to the Dutch public in September. BUUT

is designed for teenagers and their parents. It helps

young people manage their money with tools such as

handy pots for savings and payments. The app is simple

to use, visually engaging and tailored to the lifestyle of

the younger generation. It also offers financial tips from

experts, peers and educators, helping parents and

teenagers learn about money together.

BUUT was developed within one year and benefitted

from ABN AMRO’s increasingly modular application

infrastructure. You can read more about this in the

interview with the Head of BUUT.

New investment services

We have continued to develop BUX, our retail

investment platform designed for younger investors,

which became part of ABN AMRO in 2024. After this

acquisition, BUX’s assets under management increased

by over 50% compared to the previous year. More than

60% of BUX’s new clients are new to ABN AMRO as

well.

In August, BUX launched BUX Prime in cooperation with

JP Morgan Asset Management. This new service offers

access to model portfolios of active exchange-traded

funds (ETF), better interest rates on cash holdings, a

new structure for lending securities and lower

transaction costs. The new product strengthens

ABN AMRO’s digital investment options, with a focus on

sustainable growth in key markets like the Netherlands

and Belgium.

In September, BUX clients could buy new shares in

listed companies for the first time. This was possible

because of an agreement made in 2024 with

PrimaryBid, a capital markets platform. The deal allows

BUX clients to invest in share sales that were previously

open only to professional investors.

ABN AMRO also introduced an easier way to start

investing, aimed at attracting a new generation of

clients. The new Index Mandate product offers access to

an actively managed portfolio of ETFs and index funds

that consider environmental, social and governance

(ESG) criteria.

Protecting client data

We have a strong focus on protecting our clients’ data.

We provide clear information to clients on how they can

identify and avoid fraud and identity theft. We have

made the bank’s cyber defences stronger and, as part of

our privacy programme, we have continued to improve

our processes, including impact assessments and

record-keeping. Mandatory training and controls

support our employees in securely managing client

information, including processing, storing and sharing it.

Client satisfaction

ABN AMRO regularly measures how satisfied clients are,

using the Net Promoter Score (NPS) for each client unit.

This score shows how likely clients are to recommend

the bank to others. As part of our strategy, we set targets

for relational NPS for our three client units. Our NPS for

all client units increased compared with the previous

year.

In Personal & Business Banking (P&BB), the score for

personal clients (consumer and affluent) improved to 1

in 2025 from -8 the year before. Clients appreciated our

efficient service, proactive communication and digital

tools. This was confirmed by BearingPoint’s 2025 Digital

Leaders Study 1, which ranked ABN AMRO as one of the

top performers in the Netherlands. P&BB’s business

clients & ecosystems segment recorded an NPS of -27

compared with -43 in the previous year. Wealth

Management’s score rose from 25 to 26, and Corporate

Banking rose from 15 to 21. The NPS for all client units

exceeded the targets we set for 2025.

Relational Net Promoter Score by client unit

Definitions of all key performance indicators and other metrics can be found in

Other information.


ABN AMRO	Annual Report 2025	28


≡	Strategy & performance	Performance on our strategy	Sustainability

Sustainability

Banks play a key role in society. They contribute to the economy and build

trust. We focus on what we do best: providing loans and investment and

payment services, while supporting our clients to become more sustainable.

We share our expertise to help clients lower their

carbon emissions and invest in sustainable businesses

and technologies. We provide various initiatives and

financial solutions to guide clients towards a more

sustainable future. For instance, our sustainability-linked

loans offer lower interest rates if the borrower meets

clear environmental objectives.

We measure our performance in different areas related

to sustainability, including by:

• increasing our financing for activities, assets or

projects with a significant and measurable

environmental or social impact

• supporting more wealth management clients to invest

in funds and strategies that take into account

environmental, social and governance (ESG) criteria

• improving the energy efficiency of the Dutch homes

we finance

Developments in 2025

One way we measure progress is through our

Sustainability (acceleration) asset volume (SAS). This

includes loans with a measurable sustainability

component, such as mortgages and corporate loans,

and ESG and impact investments for our clients. In

2025, this volume remained unchanged at 37% of

outstanding loans and client assets. The SAS growth

outpaced the total increase in relevant assets only

slightly. All three SAS categories met their respective

2025 targets. Two categories – residential mortgages

and corporate loans to clients – increased compared

with 2024. The SAS volume of ESG & impact

investments also increased, though at a slower pace

than total client assets. As a result, the overall SAS

volume percentage remained unchanged. See the table

on the next page for details on our progress.

Our sustainability efforts across the bank helped

to improve several sustainability indexes. In 2025,

ABN AMRO achieved an MSCI ESG rating of AA and

improved its Sustainalytics ESG risk rating from 19.8

to 14.1.






Climate	Nature	Social impact
We support the transition to a net- zero emissions economy by 2050 by aligning our portfolio with the Paris Agreement’s goal to limit global warming.	We support clients' circular transition by financing resource conservation and waste reuse, while addressing biodiversity loss through engagement.	We support meaningful social impact by addressing inequality, respecting human rights and promoting financial resilience and inclusion.


ABN AMRO	Annual Report 2025	29


≡	Strategy & performance	Performance on our strategy	Sustainability

Sustainability (acceleration) asset volume


	Targets		Results
Percentage sustainability (acceleration) asset volume¹	2025	2024	2025	2024
ESG + impact investments ^{2, 3, 4}	44%	42%	44%	48%
Residential mortgages	35%	34%	35%	32%
Corporate loans to clients	31%	27%	31%	28%
Total sustainability (acceleration) asset volume	37%	36%	37%	37%
1. The definition of sustainability (acceleration) asset volume is the sum of Taxonomy-aligned assets (mortgages and corporate loans) and acceleration volume based on ABN AMRO’s Sustainability Acceleration Standards. The overall target for sustainability (acceleration) assets volume is calculated as the sum of sustainability (acceleration) asset volume (mortgages and corporate loans) and sustainability client asset volume, divided by the sum of the outstanding mortgage loan book, corporate loan book and client asset volume.
2. The ESG + impact investments are the AuM, or client assets. Client assets consist of equities, corporate bonds, investment funds, ETFs and structured products.
3. For client assets the definition of sustainability (acceleration) assets volume has been aligned with the definitions set in the EU SFDR regulation (Articles 8 and 9).
4. Excluding HAL’s client assets portfolio.

Climate

Our climate strategy outlines how ABN AMRO supports

the Paris Agreement’s goal of limiting global warming

and the transition to a net-zero emissions economy by

2050. It consists of the following elements:

• We help our clients transition by providing financing

to reduce emissions and adopt sustainable business

models.

• We have set decarbonisation targets for portfolios

and sectors to align with climate goals.

• We work alongside government authorities and

industry leaders to encourage sustainable practices

and accelerate change across sectors.

The strategy also aims to address the bank’s long‑term

climate transition risks. As part of this, we evaluate the

sensitivity of various sectors to climate-related physical

and transition risks. For more information, see the

climate risk heatmap in the Climate change section of

the Sustainability Statements.

Emission reduction pathway

While this chapter presents our 2025 performance, the

paragraphs below also outline the steps we plan to take

from 2026 onwards.

In November 2025, we announced that we intend to

update our climate strategy to align with a well-

below-2°C pathway, in line with the Paris Agreement’s

goal to limit global warming. Any emissions pathway

must be both credible and achievable to support an

orderly and sustainable transition towards net-zero

emissions. Public policy commitments and regulatory

developments remain key drivers of the pace at which

our clients can transition. As current policies are

primarily geared towards staying well below 2°C, we

aim to align with this pace to ensure our plans remain

realistic for both our clients and ourselves. In sectors

and activities where public policy and technological

developments enable faster decarbonisation, we will

continue to strive for 1.5°C alignment.

To support this, we plan to monitor the absolute

greenhouse gas emissions of companies, activities and

projects we finance or invest in. This can help us avoid

blind spots and create more opportunities to support

our clients’ decarbonisation.

In 2024, we finalised our emission reduction targets for

the most important carbon-intensive sectors. We

completed the integration of our climate strategy into

the bank’s policies and processes in 2025. Despite the

dissolution of the Net-Zero Banking Alliance (NZBA), we

continue to follow its guiding principles in executing our

strategy to achieve net‑zero emissions by 2050.

Our climate strategy currently covers 86% of our

exposures to high-emitting sectors. In 2025, we made

progress on our climate strategy targets for reducing

greenhouse gas emissions in all sectors except

commercial real estate. For information about our

progress on sector targets, see the Climate change

section of the Sustainability Statements.

We are working hard, together with our clients, to

achieve our targets. However, the transition to net-zero

emissions is a long-term process that requires a

collective effort and comes with dependencies and

uncertainties. There are still significant challenges

ahead.

Supporting our clients

We understand that switching to a sustainable business

model and reducing emissions can be challenging for

our clients. At our decarbonisation conference in

February 2025, a survey among over 350 businesses

highlighted challenges in the energy transition, such as

high capital expenditure, complexity and cost impact.

One example of how we support our clients is the free

online Green Building Tool that we launched in April.

This tool helps commercial real estate clients identify

ways to save energy and improve their energy labels.


ABN AMRO	Annual Report 2025	30


≡	Strategy & performance	Performance on our strategy	Sustainability

In the same month, we committed up to EUR 1.2 billion

in new financing at favourable rates for small and

medium-sized enterprises (SMEs), with support from the

European Investment Bank and the European

Investment Fund. This will boost economic growth and

promote environmental sustainability projects.

ABN AMRO supports its clients with Green, Social and

Sustainability Bonds. In 2025, we structured, issued and

distributed 41 of these bonds for our clients, with a total

issuance volume of EUR 21.7 billion, up from

EUR 17.6 billion in the previous year. All bonds followed

publicly available Green, Social and Sustainability Bond

Frameworks, which were independently verified. Last

year, ABN AMRO issued four green bonds under the

new European Green Bond Standard, becoming the first

bank worldwide to do so.

We made progress towards our goal of achieving more

than EUR 8 billion in renewable‑energy financing by

2028 and EUR 10 billion by 2030. By the end of 2025,

we had financed EUR 5.8 billion in renewable energy,

up from EUR 5.4 billion in 2024.

In 2023, we earmarked up to EUR 1 billion in early-

stage capital to invest by 2030 to support the transition

to a decarbonised economy. These investments are

made through direct equity via our Sustainable Impact

Fund (SIF), third-party equity funds and hybrid debt.

Combined, these investments amounted to

EUR 408 million in 2025. For more information, see the

Climate change section in the Sustainability Statements.

In 2025, SIF acquired a stake in Revyve, a Dutch food

technology company that develops sustainable

alternatives to traditional egg ingredients. The fund also

invested in Converge, a British company developing

technology to reduce carbon emissions from concrete

production.

In 2025, mortgages for homes rated with the most

energy-efficient labels ‘A’ and higher accounted for

35% of our Dutch residential mortgage portfolio,

compared with 32% during the previous year. For more

details about energy labels in our mortgage portfolio,

see the Climate risk section of the Sustainability

Statements.

At the end of the year, we started the pilot ‘Beter

Wonen’ (‘Better Home Living’) to examine whether

Dutch clients are interested in a fully managed

sustainability upgrade of their homes. The goal is for

energy savings to match or exceed the monthly

investment costs. We collaborate with selected partners

who provide our clients with a complete service, from

applying for subsidies to planning and completing the

renovations.

In the first quarter of 2026, we will introduce a new

pricing model that ties mortgage interest rates to the

property’s energy label. This will benefit owners of

energy-efficient homes and owners who upgrade their

homes to a higher energy label. These initiatives aim to

support sustainable investments and maximise value for

our clients.

Nature

‘Nature’ refers to all life and non-living elements such as

air, water and soil. Clean air and water, healthy soil and

thriving ecosystems are essential for human well-being

and economic stability.

Biodiversity

By offering financial products to our clients, we help

them grow their businesses, which can also affect

biodiversity. Our biodiversity approach focuses on

reducing the negative impact of client activities,

especially in sectors such as dairy farming and deep-sea

shipping.

Our Nature Statement is informed by the Kunming-

Montreal Global Biodiversity Framework and sets out

the principles guiding the bank’s actions on nature. In

2025, for example, we advanced a proposal for a

transition plan for the dairy farming sector. This takes a

broad approach, including nature, and aims to support

clients in their sustainable development while balancing

risks and returns. For more information, please refer to

the Biodiversity section in the Sustainability Statements.

Circular economy

A key part of our Nature approach is to support clients

in adopting circular business models. One example of

our efforts is the growing role of our payment app

Tikkie in the Dutch recycling system. By integrating

Tikkie technology into deposit return machines for cans

and bottles, the bank facilitated nearly 3 million deposit

return transactions in 2025.

In 2025, we provided over EUR 274 million in loans to

support the circular economy. Since 2018, we have

provided a total of EUR 2.65 billion in circular loans. Our

sustainability focus for the new strategic period 2026–

2028 is to help clients achieve their emission reduction

targets, supported by new commercial initiatives. This

means 2025 was the final year for which we measured

progress towards our 2027 circular loans target of

EUR 3.5 billion.


ABN AMRO	Annual Report 2025	31


≡	Strategy & performance	Performance on our strategy	Sustainability

Social

We support meaningful social impact by addressing

inequality, respecting human rights and promoting

financial resilience and inclusion.

Financial care & health

We focus on ensuring all our clients have access to

banking services, including underserved communities.

With more than 200 Help with Banking Advisers, we

support clients who face challenges using our services.

In 2025, those advisers provided support on 174,000

occasions, up from 135,000 in 2024. We have also

improved accessibility of our products, apps and

websites, in accordance with the European Accessibility

Act (EEA).

Preventing financial difficulties is key to building

resilience. Research by the Dutch regulator AFM shows

GenZ individuals, born between 1997 and 2010, are

more financially vulnerable than older generations,

while our own study in January found that well-off

millennials also face financial risks. Our Financial Health

team works to strengthen resilience and prevent

problems, working with over 35 advocacy agencies and

other organisations to support clients. Our Financial

Health Coaches and Savings Coaches offer personalised

guidance to help clients manage their finances. We

started cooperating with ‘Belegger Uitlegger’, a Dutch

non-profit organisation, to educate young people on

investing.

Empowering women

Our Women in Wealth initiative highlights ABN AMRO’s

dedication to inclusivity, client-focused services and

sustainable growth. It addresses women’s financial

needs and goals. The initiative includes female-focused

events such as lunches and after-work sessions to foster

a sense of community among female clients.

Our Women Entrepreneurs programme connects like-

minded women, cultivates business opportunities and

provides learning sessions. Additionally, we collaborate

with over 100 institutions in Code-V to direct more

financing to women entrepreneurs in the Netherlands.

We support equal opportunities for women in creative

industries. Since 2018, we have cooperated with the

DGTL music festival to promote gender equality in

electronic music. We commissioned the 'Behind the

Spotlights' report with WOMEN INC. to address barriers

to and solutions for equality in the sector. We offer

financial support and coaching for emerging female

artists through the DGTL Academy.

We engage women through podcasts hosted by female

financial experts, through articles and by highlighting

women’s contributions to finance at in-house

exhibitions. One example is an exhibition on the history

of ABN AMRO’s ‘Women’s Bank’, a branch office created

specifically for female clients that opened in 1928.

Supporting human rights

In 2025, we updated the Duty of Care and Client

Centricity Policy to clarify how our duty of care is

connected to discrimination and anti-discrimination

efforts. We updated our Code of Conduct to emphasise

fairness and respectful client care. Screening for

discrimination risk was included in the Systematic

Integrity Risk Assessment. We trained client-facing staff

on topics such as grievance mechanisms, meaningful

stakeholder engagement, child labour and forced

labour, human rights due diligence and free prior

informed consent for indigenous communities.

We are in the process of updating our human rights

saliency assessment to identify the most salient human

rights issues across the bank’s roles. In 2025, we

updated the assessment for our role as a procurer and

began work on our roles as a service provider and

employer.

Financial economic crime (FEC) is connected to modern

slavery through money laundering, fraud and

corruption, which conceal the proceeds of human

trafficking and forced labour. In 2025, we monitored

these risks and analysed trends to identify areas for

investigation.

Sustainability in our own operations

While ABN AMRO's largest environmental footprint

stems from financing clients, we aim to make our own

operations more sustainable as well. Our efforts include

reducing energy use in offices, employee travel and

procurement. We have therefore set targets for scope 1

emissions (direct emissions), scope 2 market-based

emissions (from purchased electricity) and business

travel. Although we did not meet the scope 1 and

business travel targets in 2025, we remain dedicated to

meeting our 2030 targets. Smart solutions such as

energy-monitoring dashboards have cut IT energy

consumption, including at our data centres. Office

energy use dropped from 184 kWh/m² in 2018 to

93 kWh/m² in 2025, based on Usable Floor Area

measurements. For more information on greenhouse

gas emissions from our own operations, see the ESG

Annex of the Sustainability Statements.


ABN AMRO	Annual Report 2025	32


≡	Strategy & performance	Performance on our strategy	Sustainability

In 2025, the bank decided to embed sustainability in

the day-to-day operations of the client units, Risk

Management, Finance and other functions. This reflects

the new strategy, which positions sustainability as a key

strategic enabler and simplifies its governance.

We support meaningful social impact. Through the

ABN AMRO Foundation, every year employees can

dedicate one week to volunteer work. In 2025, we

invested EUR 1.3 million in community projects.

Diversity, equity and inclusion

We believe a diverse and inclusive workplace engages

employees, improves the working environment and

supports better decision-making. Our programmes

Reboot and B-Able support people with a refugee

background and occupational disabilities, respectively.

Our partnerships with organisations such as Talent to

the Top and Women in Financial Services promote

gender equality. We have signed the UN Women

Empowerment Principles and offer workshops to help

women advance their careers. The table below outlines

our diversity targets.

The hiring freeze introduced in April 2025 had a

noticeable impact on our workforce composition, which

carried over to our diversity figures. For example, we

employed 147 colleagues with occupational disabilities

last year, falling short of the B‑Able programme target

of 225. Hiring under the B‑Able and Reboot

programmes resumed in November.

Gender diversity remains a key focus. Women

represented 34% of the sub-top level, against a 48%

ambition. Senior and middle management figures also

remained below the 35% target. At the Executive Board

level, however, female representation increased to 50%

following the appointment of our new CEO. Cultural

diversity targets were met at the middle‑management

level, while senior management still offers room for

improvement. We will continue advancing towards our

long‑term ambitions.

Our diversity targets


	2025	2024	Target (2025)
Gender diversity: ¹
• Women at top level (Executive Board)	50%	38%	33%
• Women at sub-top level (Extended Leadership Team)	34%	39%	48%
• Women at senior management level (Hay 14 or higher)	31%	31%	35%
• Women at middle management level (Hay 12, 13)	31%	30%	35%
Employees with occupational disabilities:
• Number of employees (including external employees) with disabilities	147	148	225
Employees with a migration background in senior and middle management:
• Senior management with a migration background	6%	6%	8%
• Middle management with a migration background	10%	9%	9%
Gender pay gap¹	14%	15%	NA
1. For more details on the Gender pay gap, please refer to the Remuneration Report.
For more information on the diversity targets of ABN AMRO and its subsidiaries, including those required under Dutch legislation, please see our Diversity Policy on our website.


ABN AMRO	Annual Report 2025	33


≡	Strategy & performance	Performance on our strategy	Future-proof bank

Future-proof bank

Working more efficiently and effectively

Building a future-proof bank means working together more efficiently,

using our data more effectively and giving colleagues room to grow and the

freedom to experiment. In 2025, we launched a bank for teenagers,

continued to simplify our organisation and set a new strategic course.

Expanding our business

In November, we reached an agreement with

Blackstone to acquire NIBC Bank. We expect the

intended acquisition to add further scale to our Dutch

retail banking activities and strengthen our market

position.

We reinforced our presence in German wealth

management by completing the acquisition of Hauck

Aufhäuser Lampe (HAL) in July, following regulatory

approval. The combination with Bethmann Bank

establishes us as a top-three German wealth manager,

with 2,000 people in 18 locations managing over

EUR 70 billion in assets. We will adopt a two-brand

strategy in Germany by using Bethmann HAL for wealth

management and ABN AMRO for corporate banking.

In September, we launched BUUT, a neobank tailored to

younger generations, to rejuvenate and expand our

client base. Developed in just one year, BUUT has

benefitted from ABN AMRO’s modular application

infrastructure. Read more in our interview with the Head

of BUUT.

In August, ABN AMRO Clearing Bank (AACB) was

granted a restricted banking licence by the Hong Kong

Monetary Authority. This licence enables AACB to more

efficiently expand its services for settlement and

clearing in wholesale and capital markets in the region.

We are dedicated to supporting the European

sovereignty and defence industry, which also aligns

with our ambition to play a role in important transition

themes. For example, we committed EUR 10 million to

the Defence and Security Tech Fund of Keen Venture

Partners. This will support early-stage companies in

cyber defence, robotics, AI, space technologies and

dual-use applications for both civilian and military

purposes.

Growing interest in digital assets

In 2023, we became the first Dutch bank to issue

tokenised green bonds to professional investors and

record the transactions on a public blockchain.

Tokenisation converts traditional assets, such as bonds,

into digital tokens recorded in a decentralised ledger.

These tokens represent ownership or value and enable

faster, more secure and globally accessible

transactions.

In January 2025, we completed a test trade of

tokenised assets paid with stablecoins, digital

currencies pegged to assets such as the euro or the

US dollar. The test trade on 21X, the first EU-licensed

exchange for trading and settling digital assets, was

recorded directly on a public blockchain, enhancing

transparency and supporting future digital asset use

cases. Through our partnership with 21X and Apex

Tokeny, an issuance platform, we can allow investors to

trade previously issued tokenised assets.

In September, we joined nine other European financial

institutions in the Regulated Layer One (RL1) initiative to

build a shared ledger with transparent governance to

simplify and grow the adoption of digital assets.

The acquisition of Hauck Aufhäuser Lampe further

strengthened our capabilities in issuance, registration

and custody of digital assets. In 2025, Hauck Aufhäuser

Digital Custody secured a licence under the new EU

Markets in Crypto-Assets Regulation (MiCAR), enabling

the subsidiary to offer crypto-custody and transaction

services to institutional clients.

Improving our processes

Transforming work with GenAI

Being a future-proof bank means working faster and

smarter. In 2025, we invested in generative artificial

intelligence (GenAI) to enhance the client experience

and improve productivity.

We continued developing scalable and reusable digital

systems, creating uniform building blocks for faster,

smarter and cost-effective IT projects.


ABN AMRO	Annual Report 2025	34


≡	Strategy & performance	Performance on our strategy	Future-proof bank

GenAI is transforming client-facing as well as back-

office operations at ABN AMRO. Following the

introduction of ABN AMRO GPT in 2024, we

implemented Microsoft Copilot Chat in 2025 and

introduced Copilot 365 for specific teams and use

cases.

As part of our NextGen Lending programme, we

launched Lenny, a GenAI-driven lending assistant

developed by our Corporate Banking and Innovation

teams. Lenny streamlines credit request processes to

help our colleagues meet clients’ needs more quickly. In

line with EU regulations, employees retain full control

over the process.

These are just two examples of how GenAI solutions

support our teams, alongside many other applications

that are driving this broader transformation. We are

prioritising integrating GenAI into daily workflows.

Adoption has grown significantly across the bank, with

familiarity increasing from 65% (August 2024) to 85%

(September 2025) and usage rising from 45% to 77%.

Employees are trained at three levels – foundation

building, workplace/social learning and role-based

learning – to equip them with essential GenAI skills. In

2026, we plan to investigate how advancing GenAI

technologies may influence tasks, roles and

organisational structures. This will help us understand

the potential impact and determine whether

adjustments are needed.

Read more about how we use GenAI to help our clients

in the Customer experience section.

Working smarter

ABN AMRO simplified its risk governance over the past

year, reducing the number of risk committees and

limiting meeting attendance to key participants. This

sharper focus on the most important risks is expected to

enhance accountability and generate time savings.

Committees will prioritise key decisions, work with

concise materials and efficiently delegate medium- and

low-risk issues. This will increase resilience, help our

clients succeed and support the bank’s growth.

Our back-office activities also became more efficient in

2025. We made process improvements in the

settlement of inheritances and the handling of director

changes, allowing clients to make more changes

digitally. We also speeded up other processes, such as

opening joint accounts – a service often tied to key life

milestones for our clients. The time needed to open a

joint account dropped from 16 days to just 20 minutes,

with 40% of requests completed in 10 minutes via our

mobile app. This improvement helped raise the Journey

Net Promoter Score (jNPS) from -27 at the end of 2024

to +5 in 2025. This resulted in fewer client interactions,

lowering them by 13.5% compared with the previous

year. Between 2023 and 2025, chatbots and simplified

client communication led to a 16% decline in call

volumes. Process improvements in key areas during the

past years, such as new client registration, change of

directors and inheritance settlement, have resulted in

significant cost savings with a reduction of ~100 FTEs in

our Operations team.

We further improved the client data processes in other

parts of the organisation in 2025. This helped lower the

number of complaints related to client data by 35%

across the bank.

Working smarter does not stop outside the bank.

ABN AMRO and other large Dutch banks have

developed a joint migration plan for the 2026 transition

from the Dutch iDEAL online payment system to Wero,

the European digital wallet. This move is a significant

step towards a unified and future-proof European

payment system, with an expanded reach for Dutch

consumers and businesses.

Continuous access to banking services

We continue to provide reliable access to our banking

services. We aim to maintain availability of PIN and

iDEAL payments above 99.88% across the year. This

availability threshold was met. In addition, we monitor

our independent Bitsight cybersecurity rating. In 2025,

our rating of 800 indicated that our IT systems were

very secure. Bitsight cybersecurity ratings range

between 300 and 820. The higher the score, the

stronger the company’s overall security posture is.

ABN AMRO monitors its Bitsight rating as part of the

bank’s focus on IT security.

Availability of our banking services


	2025	2024
Internet Banking	99.91%	99.98%
ABN AMRO app	99.91%	99.96%
iDEAL	99.90%	99.91%
PIN payments (POS)	100%	100%

Workforce fit for the future

In 2025, ABN AMRO prepared for the next strategic

phase, which was outlined at the Capital Markets Day in

November. Throughout the year, we adapted to

changing client needs, simplified parts of the

organisation, launched new businesses and ended

others.


ABN AMRO	Annual Report 2025	35


≡	Strategy & performance	Performance on our strategy	Future-proof bank

Under the new strategic plan, the bank will simplify its

organisation and reduce global staff by 2028, with

about half of the reductions expected to occur through

attrition. Throughout this transition, staff will receive

transparent and responsible treatment, in accordance

with the bank’s and local standards. In the Netherlands,

for example, the bank and labour unions agreed in

September to extend the Social Plan for staff by

three years.

In April 2025, we tightened our hiring controls and

restricted the conversion of fixed-term contracts to

permanent positions to help manage costs. We also

reduced the number of external employees. As a result,

the percentage of external employees in the total

workforce declined from 14% in January to 9% in

December. These measures affected numerous

colleagues across the bank. At the same time, they also

created new development opportunities for internal

talent and reduced the bank’s dependence on external

expertise.

Learning

Lifelong learning and continuous development are key

to our purpose of Banking for better, for generations

to come. Learning ranges from mandatory training and

in-house workshops to professional certifications

and post-master programmes.

Our interactive training programme Sharp! helps

employees better understand non-financial risks.

Covering topics such as cybercrime, insider trading and

privacy issues, Sharp! teaches employees how to

identify risks, understand when they might arise and

make informed decisions.

We also offer leadership development programmes

tailored to different career stages, from first-time

managers to senior executives. These programmes are

complemented by ongoing training and other

development initiatives that support leaders throughout

their careers.

Work-life balance

Hybrid working can improve productivity and boost

employee engagement. It also helps employees

balance their work and personal lives, as reflected in

a score of 84 out of 100 in our Employee Engagement

Survey. This is an increase from the score of 83 in 2024

and places ABN AMRO five points above the European

Financial Services benchmark.

Absenteeism at the bank rose to 4.78% last year,

following a stable but relatively high rate of 4.2% in

2024. Long-term absences due to mental health issues

are rising, especially among employees aged 35 or

younger. Absenteeism is also high among women and

employees aged 55 or older. These issues extend

beyond the bank and are a growing concern in society.

We are working with our occupational health service

provider to prevent and reduce absenteeism.

Employee engagement

We regularly ask our colleagues how they experience

working at the bank. This Employee Engagement Survey

includes questions about teamwork, feedback and

feeling heard and valued, but also topics such as our

strategy, collaboration and leadership.

Despite a challenging year, five out of eight

engagement drivers scored 80 or higher, with an overall

engagement index of 79 that reflects the collective

resilience and dedication of our colleagues.

Employee engagement score

(in %)

These scores are based on ABN AMRO’s annual Employee Engagement Survey.

The latest survey was conducted in October 2025. A total of 82% of employees

participated in the survey.


ABN AMRO	Annual Report 2025	36


≡	Strategy & performance	Performance on our strategy	Future-proof bank

Ethics and integrity

Maintaining trust in the bank requires us to uphold high

standards of ethics and integrity. This means:

• what we have to do: ensure compliance with all

relevant laws and regulations

• what we can do: as a commercial organisation, make

decisions that serve our business interests

• what we want to do: act responsibly and demonstrate

morally sound behaviour to fulfil our purpose of

Banking for better, for generations to come.

Like other banks, ABN AMRO plays a key role as a

gatekeeper, helping to protect the financial system

against financial crime. To fulfil this responsibility:

• We have established a framework of internal policies

and controls to ensure compliance and minimise risks

related to fraud, money laundering, bribery,

corruption and terrorist financing.

• We conduct thorough due diligence of clients and

business partners, particularly those with political

exposure and those operating in countries or

industries where financial crime is more common.

Additionally, we collaborate closely with law

enforcement agencies to fight fraud, corruption and

money laundering.

• We foster a ‘speak-up’ culture, encouraging

employees to report potential violations and discuss

ethical dilemmas in a supportive environment.

Suspected breaches can be reported through the

bank’s dedicated ‘speak-up channels’, including

whistleblowing mechanisms. Employees receive

training to identify signs of financial crime and are

required to report all incidents, whether confirmed or

suspected, without delay.

Progress on financial targets

In November 2025, ABN AMRO presented new strategic

targets for 2028. These paragraphs compare the 2025

performance with the 2026 targets that were set under

the previous strategic plan.

Our return on average equity was 8.7% in 2025,

compared with a 2026 target of 9-10%. The cost/

income ratio amounted to 64.4%, compared with our

2026 target of around 60%.

Our strong capital position allowed us to continue

investing in our strategic priorities in 2025 while still

maintaining financial stability. In the first quarter, we

started reporting our capital position and credit risk

exposures under the Basel IV framework. This resulted

in a CET1 ratio of 15.4% at year-end, compared with

our 2026 target of 13.5%. This capital ratio is a measure

of a bank’s ability to absorb losses, with a higher ratio

indicating a more resilient bank. For more information,

please refer to the Financial performance section.

We finalised the simplification of our credit risk model

landscape. We continue to use advanced models for

calculating the capital requirements for the majority of

the balance sheet, specifically mortgages, banks and

other financial institutions. During the year, we received

regulatory approval to use standardised, less

complicated approaches to assess the credit risk of a

final set of loan portfolios that require significant

modelling and data efforts. This simplification will bring

stability and predictability to our capital position.


ABN AMRO	Annual Report 2025	37


≡	Strategy & performance	Performance on our strategy	Interview CEO HAL

Michael Bentlage | CEO of Hauck Aufhäuser Lampe

“Having a Dutch bank

as our shareholder has

helped us attract new

clients”

Michael Bentlage had never

crossed paths with ABN AMRO

during his long banking career.

But a meeting in London changed

everything. Today, Hauck Aufhäuser

Lampe (HAL) is a cornerstone of

ABN AMRO’s ambition to grow into

a top-five European private bank.

“Interestingly, I’d had no previous interaction with

ABN AMRO. I only knew it as a large, reputable bank

from the Netherlands,” Bentlage says in Frankfurt am

Main, where the bank’s origins date back to the 18^th

century. “When our Chinese shareholder met with

then-CEO Robert Swaak in London and agreed to sell,

ABN AMRO had just four weeks to negotiate the share

purchase agreement. I would never have believed such

a sizeable and complex bank could pull that off. But I

learned that you can be big and still move quickly on a

major decision when you need to.”

How does becoming part of ABN AMRO help HAL?

“First, size matters: when you’re not that big, your

salespeople have to go knocking on every door. Once

you reach a certain scale in asset servicing, private

banking or investment banking, potential clients start

calling you and inviting you to pitch. Since we became

part of ABN AMRO in July, we can service much larger

financing needs for private and corporate clients. This

strengthens our position with the sizeable family-owned

companies we serve, on both the business and the

personal side. Second is reputation: our people feel

positive, and not a single client has told us they are

unhappy that we have a Dutch bank as our shareholder.

On the contrary, it has helped us attract new clients.”

What do you expect for the combined businesses

in Germany?

“Together with ABN AMRO’s Bethmann Bank, also

based in Frankfurt, we will manage more than

EUR 70 billion in assets. That makes us the third-largest

private bank in Germany. Bethmann is a centuries-old

bank that also has extensive capabilities on the

corporate side, while HAL has strong expertise in areas

such as asset servicing and digital assets.

With this much broader product offering and our good

market position, we see room for strong growth across

all our products in Germany.”

Will HAL and Bethmann clients notice any changes

following the merger?

“Our combined wealth management organisation will

operate under the name ‘Bethmann HAL’, but existing

advisers, products and services will remain unchanged

as much as possible. We will offer access to

ABN AMRO’s international solutions, and I also envisage

new markets opening for some of our products. For

example, our custody and registry management for

digital assets of institutional clients fits perfectly with

ABN AMRO's current tokenisation activities, and I see it

as a key area for joint growth. Culturally, I find the Dutch

and German ways of doing business fundamentally

similar. Both have a direct, matter-of-fact

communication style and focus on substance and long-

term relationships.”

Are bank branches still important in this

digital age?

“Eventually, Bethmann HAL will have 17 locations

across Germany's key economic regions and

Luxembourg. Private banking is about trust, personality

and empathy, and you cannot digitalise that. Clients

often tell me: ‘When I call other banks, nobody answers.

When I call you, someone picks up and helps me.’ Life is

that simple.”


ABN AMRO	Annual Report 2025	38


≡	Strategy & performance	Interview with our Chief Financial Officer

Interview with our Chief Financial Officer

Ferdinand Vaandrager | CFO of ABN AMRO

“We have created

a solid base for our

2028 ambitions”

Ferdinand Vaandrager looks back

on 2025 as a year of delivery for

ABN AMRO. The bank already made

progress on its three new priorities

– right-sizing costs, optimising

capital allocation and growing

profitably – while preparing for the

next strategic phase. “We did what

we said we would do, and we have

laid a solid base for the coming

three years.”

The bank performed well in 2025. What was the

highlight for you?

“Whether you look at profitable growth, cost

management or optimising our capital allocation, we

delivered on our promises. In the Netherlands, the

strong labour market, relatively low interest rates and a

positive housing market all supported demand for our

mortgages. Fee income increased strongly and we

reduced costs by simplifying the bank. We also made

good progress on reshaping our balance sheet, so we

can grow in a more capital-efficient way.”

Another highlight is the intended takeover of

NIBC. How do you view this deal?

“The acquisition of NIBC Bank is a unique and very

attractive opportunity to further strengthen our position

in the Dutch retail market. We expect a return on

invested capital of around 18% by 2029, and it will

enhance our profitability. The combination strengthens

our position in the Dutch mortgage and savings

markets. It means welcoming about 325,000 new

savers and 200,000 new mortgage clients. It also offers

us a scalable platform for issuing mortgages that do not

remain on our balance sheet. Under this ‘originate-to-

manage’ model, we provide Dutch mortgages, sell

them to institutional investors and manage these loans

for them in return for a fee. It fits perfectly with our

strategy of growing in a way that uses less of our own

capital and makes the bank less dependent on net

interest income.

Where the NIBC deal will help us grow our Dutch

mortgage volumes, the acquisition of Hauck Aufhäuser

Lampe (HAL) plays a different but very complementary

role. It boosts our fee income and expands our wealth

management footprint in Germany, which really

supports the strong fee momentum we’re seeing across

the bank. Excluding HAL, which we consolidated as at

1 July, our total fee income grew by 6% in 2025. That’s

well above the growth ambition we had set of 3% to

5%, and all three client units played a part in driving this

growth. We saw strong results in payment services,

asset management, investment products, and advisory

fees at our corporate bank. Clearing also continued to

perform well, adding more fees and helping us further

diversify our income.”

How did reducing risk-weighted assets help

optimise capital allocation?

“In 2025, we implemented the Basel IV capital rules,

simplified our credit risk models and improved the

quality of our loan data. As part of our strategy, we are

reducing capital that is tied up in non-core activities and

lower-yielding loans so that we can redirect it to areas

where we can grow profitably. We optimised our

balance sheet through significant risk transfers, shifting

part of our credit risk on loan portfolios to investors or

other financial institutions. Together, these measures

lowered our risk-weighted assets (RWA). In simple

terms, RWA reflects the risk level of each loan and


ABN AMRO	Annual Report 2025	39


≡	Strategy & performance	Interview with our Chief Financial Officer

determines how much capital the bank must hold to

absorb potential losses on those loans. Total RWA

decreased from EUR 140.9 billion to EUR 135.4 billion

in 2025. This enables us to fund attractive growth

opportunities while simultaneously returning capital to

our shareholders.”

“I can confidently say

that 2025 marked a real

turning point.”

Cost discipline has been a focus for years. How do

you view the progress made in 2025?

“One of our strategic priorities is to right-size our cost

base, adjusting it in line with our relatively

straightforward business model. We are focusing on

lowering our cost-to-income ratio from over 60% to

below 55% by 2028 to match that of comparable

banks. I can confidently say that 2025 marked a real

turning point. We implemented strict hiring controls

and announced a workforce reduction of 5,200 full-

time equivalents by 2028. We are very aware of the

impact on our people, but this is a necessary step to

align staff levels with the bank’s size and needs.

Our cost-efficiency effort is also driving positive cultural

shifts. Internal mobility is rising and cost awareness is

improving. Colleagues are enthusiastically sharing ideas

to eliminate structural inefficiencies, stop activities that

add limited value, and streamline processes. A good

example is Lenny, our GenAI-powered lending assistant.

Lenny helps us quickly find optimal loan solutions for

corporate clients, improving service and reducing

costs.”

What’s the role of data, technology and

Generative AI in all of this?

“In recent years we have invested heavily in our data:

improving quality, setting clear rules and building a

strong architecture with one ‘golden source’ of truth.

This is enabling us to lower the cost of reports,

automate processes and apply GenAI at scale. Every AI

use case, for instance in risk, in operations or involving

clients, depends on the quality of our underlying data.

Ultimately, these investments do more than meet

compliance requirements: they enable automation,

simplify the organisation and reduce costs over time.”

What are your priorities for 2026?

“For 2026, the message is simple: it continues to be all

about delivery. We aim to finalise the legal merger of

HAL and expect to close the intended NIBC acquisition

in the second half of the year. Getting these integrations

right – for clients, colleagues and shareholders – is a

top priority. Beyond that, we will work towards the

targets we announced in November: gaining market

share in selected segments, increasing fee income,

keeping a tight grip on costs and executing the business

cases that support our financial targets.”

How did you personally experience the past year?

“It made me proud. Proud of our people, who have

dealt with tough choices but still maintained the energy

to push growth initiatives and improve client service. I

am also proud that investors are starting to recognise

our progress after years of hard work on data,

regulation and simplification. As the Dutch State

continues to reduce its stake in the bank, we are seeing

growing interest from long-only investors, who typically

buy and hold shares for the long term. This shows their

confidence in our ability to deliver on the priorities that

we have set: right-sizing our cost base, optimising

capital allocation and growing profitably. With our rich

200-year history, strong market positions and the

energy of our people, we have a solid foundation for

realising our 2028 ambitions.”

For more insights, read our Economic outlook.


ABN AMRO	Annual Report 2025	40


≡	Strategy & performance	Performance on our strategy	Financial performance

Financial performance

ABN AMRO delivered a solid financial performance in

2025, achieving a net profit of EUR 2.3 billion and a

return on equity of 8.7%. Net interest income was in line

with our guidance of more than EUR 6.3 billion for the

year. Fee and commission income increased by 12%,

supported by the consolidation of Hauck Aufhäuser

Lampe (HAL) and higher fees in asset management and

securities services. Operating costs excluding large

incidentals and restructuring expenses were at the

lower end of our EUR 5.4-5.5 billion guidance.

Our client units made important contributions to our

profitable growth. In the mortgage market, our share of

new production remained stable at 19%, while Wealth

Management grew client assets to over EUR 283 billion.

Within Corporate Banking, financing activity increased

in the energy, digital and mobility sectors.

Financial indicators


(in millions)	2025	2024	Change
Net interest income	6,335	6,504	-3%
Net fee and commission income	2,132	1,910	12%
Other operating income	249	447	-44%
Operating income	8,716	8,861	-2%
Personnel expenses	3,104	2,776	12%
Other expenses	2,506	2,691	-7%
Operating expenses	5,610	5,467	3%
Operating result	3,106	3,394	-8.5%
Impairment charges on financial instruments	20	-21
Profit/(loss) for the period	2,252	2,403	-6%
Other indicators
Common Equity Tier 1 ratio¹	15.4%	14.5%
Net interest margin (NIM) (in bps)	152	164
Return on average Equity²	8.7%	10.1%
Dividend per share (in EUR)³	1.54	1.35
1. As of 1 January 2025, the figures in the table are prepared in accordance with CRR III (Basel IV) regulations. The figures up to 31 December 2024 are prepared in accordance with CRR II (Basel III) regulations.
2. Figures based on bank's profit (or loss) for the year, excluding payments attributable to AT1 capital securities and results attributable to non-controlling interests, divided by average equity attributable to the owners of the company excluding AT1 capital securities.
3. Figure for 2025 shows proposed dividend, subject to approval by ABN AMRO's Annual General Meeting (AGM).

Financial results

Operating income decreased by 2% to

EUR 8,716 million in 2025. This was primarily due to

lower net interest income and other operating income.

These effects were partly offset by higher fee and

commission income.

Net interest income (NII) declined by 3% to

EUR 6,335 million in 2025. Excluding large incidentals,

NII decreased by EUR 166 million, mainly as a result of

margin pressure on deposits due to the interest rate

environment. Margin pressure on corporate loans and

mortgages also contributed to the reduction. These

pressures were partly compensated by increased

deposit and mortgage volumes, improved Treasury

results and the positive impact of the integration of HAL.

Net fee and commission income increased by 12% to

EUR 2,132 million. This growth was largely attributable

to higher fee income at Wealth Management, reflecting

the integration of HAL and increased fees for asset

management and securities services. Personal &

Business Banking benefitted from higher payment

services fees, driven by increased payment package

pricing and transaction volumes. Corporate Banking

also recorded a rise in fee income on higher clearing

transaction volumes, amid elevated market volatility,

and increased client mandates across debt capital

markets and advisory activities.

Other operating income decreased by 44% to

EUR 249 million. Excluding large incidentals, other

operating income in 2025 was EUR 222 million lower

than in 2024. This largely reflects less favourable results

across Treasury and Personal & Business Banking.

Corporate Banking recorded lower other income from

Global Markets and Clearing. These developments were

partly offset by lower derecognition losses compared

with 2024.


ABN AMRO	Annual Report 2025	41


≡	Strategy & performance	Performance on our strategy	Financial performance

Operating expenses rose by 3% to EUR 5,610 million

in 2025. The increase was mainly driven by higher

personnel expenses and was partly offset by lower

other expenses. Excluding large incidentals and

restructuring costs, operating expenses were at the

lower end of our full-year guidance of

EUR 5.4-5.5 billion.

Personnel expenses increased by 12% to

EUR 3,104 million. Excluding large incidentals,

personnel expenses increased by EUR 350 million. The

increase was attributable to a higher number of internal

employees, largely driven by the consolidation of HAL,

the impact of the Dutch collective labour agreement

(CLA) and higher restructuring provisions.

Other expenses decreased by 7% to EUR 2,506 million.

Excluding large incidentals, other expenses decreased

by EUR 173 million. This was mainly due to lower

external staffing costs and non-recurring VAT rebates in

2025. These positive developments were partly offset

by increased IT costs and higher depreciation and

amortisation expenses, mainly related to the integration

of HAL.

Lending and credit quality

In 2025, total loans and advances increased to

EUR 264.1 billion from EUR 256.2 billion a year earlier.

Growth was mainly driven by the continued expansion

of our residential mortgage portfolio, underscoring our

strong position in a robust housing market. Corporate

lending also rose, supported in part by the acquisition of

HAL.

These increases were partly offset by a reduction in

corporate loans following the wind-down of activities at

Asset Based Finance. Consumer loans also declined,

primarily because of the reclassification of Alfam’s loan

portfolios, to assets held for sale.

Credit quality remained strong over the year. Combined

with benign economic circumstances in the

Netherlands, this resulted in a net impairment charge of

EUR 20 million in 2025, compared with a

EUR 21 million net impairment release the year before.

The resulting cost of risk was 1 basis point, compared to

-2 basis points last year.

Capital position

ABN AMRO’s capital position improved throughout the

year. The Common Equity Tier 1 (CET1) ratio ended the

year at 15.4% compared with 14.5% as at

31 December 2024. This was due to optimisation

initiatives that led to a decrease in risk-weighted assets

(RWA). These included methodological enhancements

and data quality improvements. Besides that, significant

risk transfers contributed to the decrease.

We updated our capital framework and distribution

policy as announced during our Capital Markets Day on

25 November 2025. We are committed to returning

capital to shareholders and we aim for an ordinary

distribution up to 100% of the reported net profit. In

2025 an interim dividend of EUR 0.54 per share was

paid and we propose a final dividend of EUR 0.70 per

share. This corresponds to a payout ratio of 50% of the

reported net profit and brings the total dividend for

2025 to EUR 1.24 per share. Additionally, we plan to

distribute EUR 500 million, comprising EUR 250 million

in cash dividends and EUR 250 million through a share

buyback programme, for which we have applied for

regulatory approval. Our year-end CET1 capital ratio

already takes into account the additional distributions.

We expect to present the outcome of our annual capital

assessment with the fourth-quarter results.

Financial performance outlook for 2026

We maintain our 2026 guidance for commercial net

interest income to be around EUR 6.4 billion, excluding

the intended acquisition of NIBC. Our cost base for

2026 is expected to amount to EUR 5.6 billion,

excluding restructuring expenses and the intended

acquisition of NIBC.


ABN AMRO	Annual Report 2025	42


≡	Strategy & performance	Performance on our strategy	Financial performance


	Large incidentals

	Below is an overview of the largest incidentals affecting our results for the previous and current year. More detailed information on other large incidentals disclosed can be found in our quarterly reports.

	Interest income provision updates 2024 included a positive revaluation of EUR 29 million for a DSB claim, recorded in net interest income at Group Functions. In 2025, our provisions related to interest income compensation were updated resulting in an overall release of EUR 26 million, of which EUR 16 million related to a variable interest compensation provision update at Personal & Business Banking and EUR 10 million related to a positive revaluation for a DSB claim recorded at Group Functions.		Legal provisions In 2024, legal provisions with a net impact of EUR 95 million were recorded in other expenses at Group Functions. In 2025, our legal provisions were updated with EUR 55 million recorded under other expenses at Group Functions and Corporate Banking.

	Held-for-sale adjustment In 2024, the carrying value of assets held for sale was impaired to reflect the fair value less costs to sell. This resulted in an impairment of EUR 24 million (including disposal cost) recorded in net income from other operating activities, which is included in other income at Wealth Management.		Regulatory fines In 2025, the bank paid two administrative fines totalling EUR 29 million. Both payments were recorded under other expenses at Group Functions.

Financial performance by client unit

Personal & Business Banking


(in millions)	2025	2024	Change
Operating income	3,873	3,932	-2%
Operating expenses	2,404	2,451	-2%
Operating result	1,469	1,481	-1%
Impairment charges on financial instruments	-81	-108	25%
Profit/(loss) for the period	1,139	1,169	-3%

Net profit for Personal & Business Banking (P&BB)

decreased to EUR 1,139 million in 2025 (2024:

EUR 1,169 million). Operating income declined by 2%

to EUR 3,873 million, as a result of lower net interest

income and other operating income. Net interest

income fell marginally to EUR 3,231 million. Excluding

large incidentals, net interest income decreased by

EUR 47 million, mainly due to lower margins on

deposits and mortgages. This was partly offset by

volume growth in deposits and mortgages. Fee income

increased to EUR 655 million, supported by higher

payment services fees and rising transaction volumes.

Other operating income decreased to EUR 14 million

negative, largely as the result of negative fair value

revaluations on loans versus positive revaluations in the

previous year. Operating expenses remained stable at

EUR 2,404 million, with CLA-driven increases offset by

lower external staffing and restructuring costs.

Impairments showed a EUR 81 million release, driven

by releases across all three impairment stages.


ABN AMRO	Annual Report 2025	43


≡	Strategy & performance	Performance on our strategy	Financial performance

Wealth Management


(in millions)	2025	2024	Change
Operating income	1,693	1,568	8%
Operating expenses	1,302	1,092	19%
Operating result	391	476	-18%
Impairment charges on financial instruments	10	14	-24%
Profit/(loss) for the period	267	325	-18%

Net profit for Wealth Management declined to

EUR 267 million in 2025 (2024: EUR 325 million).

Operating income rose by 8% to EUR 1,693 million,

supported by higher fee income and other income. Net

interest income decreased to EUR 900 million, mainly

reflecting lower deposit margins. This was partly

compensated by higher volumes and the positive

impact of the integration of HAL. Fee income increased

significantly to EUR 771 million, driven by that same

integration and by higher other fee income, particularly

from asset management and securities services.

Operating expenses increased to EUR 1,302 million,

reflecting higher staff levels due to HAL’s integration,

CLA impacts and restructuring provisions. Impairments

amounted to a EUR 10 million addition, slightly lower

than for the previous year.

Corporate Banking


(in millions)	2025	2024	Change
Operating income	3,160	3,358	-6%
Operating expenses	1,776	1,802	-1%
Operating result	1,384	1,556	-11%
Impairment charges on financial instruments	92	74	23%
Profit/(loss) for the period	989	1,099	-10%

Net profit for Corporate Banking decreased to

EUR 989 million in 2025 (2024: EUR 1,099 million),

mainly because of lower operating income and higher

impairments. Operating income decreased by 6% to

EUR 3,160 million, as net interest income and other

operating income declined. This was partly offset by a

fee income increase of 4%. Net interest income

dropped to EUR 2,117 million, reflecting margin

pressure on liabilities, lower corporate loan volumes

and reduced Clearing NII. Fee income rose to

EUR 730 million as increased market volatility added to

higher Clearing fees, and client mandates increased

across debt capital markets and advisory activities.

Other operating income decreased to EUR 314 million,

mainly as a result of lower equity revaluations and the

wind down of the asset-based finance (ABF) portfolio.

Operating expenses declined to EUR 1,776 million, led

by lower external staffing costs in reflection of our cost

discipline, and by VAT rebates. This was offset by

increased personnel expenses. Impairments rose to

EUR 92 million, reflecting stage 3 charges despite

releases in stages 1 and 2. Our optimisation efforts

reduced risk weighted assets by 14% in 2025.


ABN AMRO	Annual Report 2025	44


≡	Strategy & performance	Performance on our strategy	Financial performance

Share price and dividend developments

The price of depositary receipts for ABN AMRO shares

listed on Euronext Amsterdam rose by approximately

99% during 2025. Over the same period, the STOXX

Europe 600 Bank Index, our principal benchmark,

increased by about 67%.

The total dividend proposed for 2025 is EUR 1.24 per

share, representing a dividend payout of 50% of the

bank’s reported net profit (after deduction of AT1

coupon payments and minority interests). The total

dividend consists of an interim dividend of EUR 0.54 per

share, paid in 2025, and a proposed final cash dividend

of EUR 0.70 per share that is subject to approval at the

Annual General Meeting scheduled for April 2026.

On 11 February 2026, we announced our plan to

distribute an additional EUR 500 million, consisting of

an additional cash dividend of EUR 250 million (around

EUR 0.30 per share based on the number of shares

outstanding at the end of 2025) and a EUR 250 million

share buyback, subject to regulatory approval. Together

with the ordinary cash dividend and the EUR 250 million

share buyback completed in the third quarter of 2025,

this brings the total payout for 2025 to

EUR 1,775 million, for a payout ratio of 87% of the

reported net profit (after deduction of AT1 and minority

interests).

Listing information & substantial holdings

During 2025, the Dutch State – acting through its

Netherlands Financial Institutions (NLFI) investment arm

– continued to reduce its stake in ABN AMRO. On 9

September 2025, NLFI announced its intention to sell

depositary receipts for ABN AMRO shares through

a pre-arranged trading plan to reduce its stake in the

bank from 30.5% to approximately 20%. By the end of

the year, the Dutch State owned 226 million shares,

equivalent to 27.5% of outstanding shares.

For more information on our shareholder structure,

listing information and substantial holdings, see the

chapter Leadership & Governance or visit our website.

Depositary receipts trade under ISIN code

NL0011540547, Reuters ticker ‘ABNd.AS’ and

Bloomberg ticker ‘ABN:NA’.


	31 December 2025	31 December 2024
Share count (in millions)
Total shares outstanding/issued and paid-up shares	823	833
- of which held by NLFI (shares and depositary receipts)	226	320
- of which held by other investors (depositary receipts)	597	513
- as a percentage of total outstanding shares	73%	62%
Average number of shares	830	841
Average diluted number of shares	830	841
Key indicators per share (in EUR)
Earnings per share¹	2.45	2.72
Shareholder's equity per share	28.92	27.17
Tangible shareholder's equity per share	28.49	26.86
Dividend per share²	1.54	1.35
Share price development (in EUR)
Closing price (end of period)	29.79	14.89
High (during the period)	29.95	16.69
Low (during the period)	14.96	13.05
Market capitalisation (end of period, in billions)	24.52	12.40
Valuation indicators (end of period, in EUR)
Price/Earnings	12.15x	5.48x
Price/Tangible book value	1.05x	0.55x
Dividend yield	5.2%	9.1%
Dividend payout ratio ^{1, 2}	50%	50%
1. Earnings per share: Profit for the period excluding reserved coupons for AT1 capital securities (net of tax) and results attributable to other non-controlling interests divided by the average outstanding and paid-up ordinary shares.
2. Dividend per share and payout ratio subject to approval of the Annual General Meeting in April 2026.


ABN AMRO	Annual Report 2025	45


≡	Strategy & performance	Performance on our strategy	Additional financial performance

Additional financial performance

Balance sheet


(in millions)	31 December 2025	31 December 2024
Cash and balances at central banks	49,486	44,464
Financial assets held for trading	2,044	2,503
Derivatives	3,933	4,347
Financial investments	50,231	47,173
Securities financing	40,173	26,989
Loans and advances banks	2,170	2,049
Loans and advances customers	255,760	248,782
Other	9,411	8,739
Total assets	413,210	385,047
Financial liabilities held for trading	1,631	1,163
Derivatives	1,967	2,499
Securities financing	15,320	10,352
Due to banks	4,320	2,329
Due to customers	279,126	256,186
Issued debt	74,072	74,542
Subordinated liabilities	4,946	6,613
Other	4,786	5,254
Total liabilities	386,167	358,939
Equity attributable to the owners of the parent company	27,040	26,105
Equity attributable to non-controlling interests	3	3
Total equity	27,043	26,108
Total liabilities and equity	413,210	385,047

Main developments in assets compared

with 31 December 2024

Total assets increased by EUR 28.2 billion to

EUR 413.2 billion as at 31 December 2025. This growth

was primarily driven by securities financing, loans and

advances customers, cash and balances at central

banks and financial investments.

Cash and balances at central banks increased by

EUR 5.0 billion as at 31 December 2025.

Financial investments went up by EUR 3.1 billion as at

31 December 2025. The main drivers were an increase

in corporate debt securities and, to a lesser extent, an

increase in government bonds.

Securities financing increased by EUR 13.2 billion as at

31 December 2025. This was largely driven by higher

reverse repurchase agreements and security borrowing

transactions as at the reporting date.

Loans and advances customers went up by

EUR 7.0 billion as at 31 December 2025. This growth

was primarily driven by client loans, which increased by

EUR 7.4 billion. Loans to professional counterparties

and other loans went up by EUR 0.3 billion. This was

partly offset by a EUR 0.8 billion decline in fair value

adjustments from hedge accounting.

Client loans increased by EUR 7.4 billion as at

31 December 2025. This growth was largely driven by

an increase in residential mortgages, which grew by

EUR 7.0 billion. The increase in residential mortgages

reflected a continuing strong mortgage market, where

we captured a 19% market share of new production

this year (2024: 19%). In addition, corporate loans to

clients increased by EUR 1.9 billion, mostly reflecting

the inclusion of the HAL portfolio. This was partly offset

by a EUR 1.4 billion decrease in consumer loans,

following the reclassification of loan portfolios from our

subsidiary Alfam to assets held for sale at Personal &

Business Banking.

Loans to professional counterparties and other loans

went up by EUR 0.3 billion as at 31 December 2025.

This increase was mainly driven by a rise in corporate

loans, and partly offset by a decline in government and

other loans, both largely reflecting Clearing activities.

Other assets increased by EUR 0.7 billion to

EUR 9.4 billion as at 31 December 2025. This was

mainly driven by reclassifications of held-for-sale

assets, partly offset by unsettled securities transactions.


ABN AMRO	Annual Report 2025	46


≡	Strategy & performance	Performance on our strategy	Additional financial performance

Loans and advances customers


(in millions)	31 December 2025	31 December 2024
Residential mortgages	163,185	156,209
Consumer loans	6,751	8,175
Corporate loans to clients¹	76,647	74,786
- of which Personal & Business Banking	11,625	8,135
- of which Corporate Banking	56,620	60,880
Total client loans²	246,583	239,170
Loans to professional counterparties and other loans ^{2, 3}	15,833	15,560
Total loans and advances customers, gross²	262,416	254,730
Fair value adjustments from hedge accounting	-5,434	-4,584
Total loans and advances customers, gross	256,982	250,146
Loan impairment allowances	1,222	1,364
Total loans and advances customers	255,760	248,782
1. Corporate loans excluding loans to professional counterparties.
2. Excluding fair value adjustment from hedge accounting.
3. Loans to professional counterparties and other loans includes loans and advances to governments, official institutions and financial markets parties.

Main developments in liabilities and equity

compared with 31 December 2024

Total liabilities increased by EUR 27.2 billion to

EUR 386.2 billion as at 31 December 2025. This

increase was primarily driven by a rise in amounts due

to customers and securities financing liabilities.

Securities financing added EUR 5.0 billion as at

31 December 2025. This was driven entirely by an

increase in repurchase agreements.

Due to banks increased by EUR 2.0 billion as at

31 December 2025, largely attributable to higher time

deposits from credit institutions and central banks.

Due to customers reached EUR 279.1 billion as at

31 December 2025. This was largely driven by a rise in

total client deposits, partly offset by total professional

deposits.

Client deposits saw an increase of EUR 28.8 billion as

at 31 December 2025. This was largely reflected in an

increase of EUR 24.3 billion in demand deposits, driven

by inflows in Wealth Management and Personal &

Business Banking. Current accounts saw an increase of

EUR 10.2 billion, almost entirely attributable to the

integration of HAL client accounts this year. A decrease

of EUR 5.8 billion in time deposits provided an offset,

largely related to a shift to demand deposits in Wealth

Management.

Professional deposits declined by EUR 5.9 billion as at

31 December 2025. This was largely driven by a

EUR 2.8 billion decrease in current accounts, led by

Clearing. Time deposits also came down by

EUR 2.2 billion, largely attributable to Global Markets

and Treasury professional deposits.

Issued debt decreased by EUR 0.5 billion to

EUR 74.1 billion, mainly caused by a decrease of

EUR 6.1 billion in short-term funding, though much of

this was offset by an increase of EUR 5.7 billion in

outstanding long-term funding. As at

31 December 2025, issued debt included

EUR 26.0 billion in covered bonds, EUR 18.6 billion in

senior preferred funding, EUR 17.6 billion in senior non-

preferred funding and EUR 11.8 billion in commercial

paper and certificates of deposit. EUR 7.3 billion in

outstanding long-term funding and EUR 11.8 billion in

outstanding short-term funding will mature

within 12 months.

Total equity increased by EUR 0.9 billion to

EUR 27.0 billion as at 31 December 2025. This increase

was mainly attributable to the inclusion of profit for the

period and an increase in other comprehensive income,

though partly offset by capital distribution and a

decrease in capital securities.

Equity attributable to the owners of the parent

company amounted to EUR 27.0 billion as at

31 December 2025. Excluding AT1 securities, it

increased by EUR 1.2 billion to EUR 23.8 billion as at

31 December 2025.


ABN AMRO	Annual Report 2025	47


≡	Strategy & performance	Performance on our strategy	Additional financial performance

Due to customers


(in millions)	31 December 2025	31 December 2024
Personal & Business Banking	135,764	126,626
Wealth Management	85,846	66,652
Corporate Banking	51,573	55,801
Group Functions	5,944	7,108
Total due to customers	279,126	256,186

Other information

Total bank


	2025	2024
Net interest margin (NIM) (in bps)	152	164
Cost/income ratio	64.4%	61.7%
Cost of risk (in bps)¹	1	-2
Return on average Equity²	8.7%	10.1%
Dividend per share (in EUR)³	1.54	1.35
Earnings per share (in EUR) ⁴	2.45	2.72
Client assets (end of period, in billions)	396.9	344.4
Risk-weighted assets (end of period, in billions) ⁵	135.4	140.9
Number of internal employees (end of period, in FTEs)	23,126	21,976
Number of external employees (end of period, in FTEs)	2,216	3,670
1. Impairment charges on loans and advances customers divided by the average loans and advances customers (excluding at fair value through P&L) on the basis of gross carrying amount and excluding fair value adjustments from hedge accounting.
2. Profit for the year excluding coupons attributable to AT1 capital securities and results attributable to non-controlling interests divided by the average equity attributable to the owners of the company excluding AT1 capital securities.
3. Final dividend per share for the year as declared/proposed by the company, subject to approval at the Annual General Meeting (AGM). For more information, please refer to Capital in the Risk, funding & capital section.
4. Profit for the year excluding coupons attributable to AT1 capital securities and results attributable to non-controlling interests divided by the average outstanding and paid-up ordinary shares.
5. As of 1 January 2025, the figures in the table are prepared in accordance with CRR III (Basel IV) regulations. The figures up to 31 December 2024 were prepared in accordance with CRR II (Basel III) regulations.

Return on equity for 2025 landed at 8.7%, compared

with 10.1% in 2024.

Return on assets in 2025 was 0.5% compared with

0.6% in 2024, mainly due to the lower return and

higher average assets this year.

Personal & Business Banking


	31 December 2025	31 December 2024
Loans and advances customers (in billions)	170.0	161.2
- of which Client loans (in billions)¹	170.2	161.5
Due to customers (in billions)	135.8	126.6
Risk-weighted assets (in billions)²	40.3	38.2
Number of internal employees (in FTEs)	4,285	4,425
Total client assets (in billions)	113.9	105.4
- of which Cash	100.3	93.3
- of which Securities	13.7	12.1
1. Gross carrying amount excluding fair value adjustment from hedge accounting.
2. As of 1 January 2025, the figures in the table are prepared in accordance with CRR III (Basel IV) regulations. The figures up to 31 December 2024 were prepared in accordance with CRR II (Basel III) regulations.

Loans and advances customers increased by

EUR 8.8 billion to EUR 170.0 billion

(31 December 2024: 161.2 billion), largely driven by

the growth of the residential mortgage and corporate

loan portfolios, and partly offset by reclassifications of

selected residential mortgage and consumer loan

portfolios to held for sale assets.

Due to customers added EUR 9.2 billion and amounted

to EUR 135.8 billion (31 December 2024: 126.6 billion).

This growth was largely attributable to demand

deposits, mostly from consumer clients, followed by a

smaller uplift in current accounts and time deposits.


ABN AMRO	Annual Report 2025	48


≡	Strategy & performance	Performance on our strategy	Additional financial performance

Total client assets recorded an increase of

EUR 8.5 billion to EUR 113.9 billion

(31 December 2024: 105.4 billion). This was largely

attributable to an increase in cash positions and, to a

smaller extent, a growth in securities. This was mainly

driven by clients’ preference to mitigate market

turbulence by focusing more on savings and staying in

cash.

Wealth Management


	31 December 2025	31 December 2024
Loans and advances customers (in billions)	19.3	16.2
- of which Client loans (in billions)¹	19.3	16.3
Due to customers (in billions)	85.8	66.7
Risk-weighted assets (in billions)²	17.3	12.0
Number of internal employees (in FTEs)	4,104	3,145
Total client assets (in billions)	283.0	239.0
- of which Cash	78.6	66.8
- of which Securities	204.4	172.2
1. Gross carrying amount excluding fair value adjustment from hedge accounting.
2. As of 1 January 2025, the figures in the table are prepared in accordance with CRR III (Basel IV) regulations. The figures up to 31 December 2024 were prepared in accordance with CRR II (Basel III) regulations.

Loans and advances customers grew by

EUR 3.1 billion to EUR 19.3 billion

(31 December 2024: 16.2 billion), mainly driven by

corporate loans, including the inflow related to the

integration of HAL.

Due to customers increased by EUR 19.1 billion to

EUR 85.8 billion (31 December 2024: 66.7 billion). This

was mainly driven by demand deposits, which saw

significant growth in the Netherlands and Germany,

partly in connection with a migration from time

deposits. Current accounts also contributed to this

growth, largely driven by the integration of HAL.

Total client assets added EUR 44.0 billion over the

course of the year and amounted to EUR 283.0 billion

(31 December 2024: 239.0 billion). This increase was

largely driven by the integration of HAL, followed by

favourable market performance and an inflow of new

assets.

Net new assets amounted to EUR 7.6 billion

(31 December 2024: 14.1 billion), largely driven by an

inflow of cash and, to a lesser extent, coming from

custodian services we provided to our clients during the

year.

Client assets


(in billions)	31 December 2025	31 December 2024
Opening balance client assets	239.0	215.6
Net new assets	7.6	14.1
Market performance	10.1	9.8
Divestments/acquisitions	26.4	-0.6
Closing balance client assets	283.0	239.0
Breakdown by type
Cash	78.6	66.8
Securities	204.4	172.2
- of which Custody	50.8	48.5
Breakdown by geography
The Netherlands	59%	65%
Rest of Europe	41%	35%

Corporate Banking


	31 December 2025	31 December 2024
Loans and advances customers (in billions)	71.7	75.6
- of which Client loans (in billions)¹	57.0	61.3
Due to customers (in billions)	51.6	55.8
Risk-weighted assets (in billions)²	75.5	87.7
Number of internal employees (in FTEs)	3,883	3,997
1. Gross carrying amount excluding fair value adjustment from hedge accounting.
2. As of 1 January 2025, the figures in the table are prepared in accordance with CRR III (Basel IV) regulations. The figures up to 31 December 2024 were prepared in accordance with CRR II (Basel III) regulations.


ABN AMRO	Annual Report 2025	49


≡	Strategy & performance	Performance on our strategy	Additional financial performance

Loans and advances customers decreased by

EUR 3.9 billion (31 December 2024: EUR 75.6 billion),

mainly driven by a EUR 4.3 billion decline in client

loans, partially offset by a EUR 0.4 billion increase in

professional loans. Client loans showed a limited

decrease, mainly due to the steering measures

including the wind-down of the ABF portfolio.

Due to customers decreased by EUR 4.2 billion to

EUR 51.6 billion (31 December 2024: EUR 55.8 billion),

mainly attributable to lower current accounts within

Clearing and lower time deposits within Global Markets.

RWA came down by EUR 12.2 billion to

EUR 75.5 billion (31 December 2024: EUR 87.7 billion).

This decline was largely driven by methodological and

data quality improvements, risk transfer transactions

and the wind-down of the ABF portfolio.

Group Functions


	31 December 2025	31 December 2024
Securities financing - assets (in billions)	31.1	18.2
Loans and advances customers (in billions)	-5.2	-4.2
Securities financing - liabilities (in billions)	15.3	10.3
Due to customers (in billions)	5.9	7.1
Risk-weighted assets (in billions)¹	2.3	3.0
Number of internal employees (in FTEs)	10,853	10,408
1. As from 2025, the Risk-weighted assets are based on Basel IV regulations.

Loans and advances customers decreased to

EUR 5.2 billion negative in 2025. This was attributable

to a shift in long-term interest rates during the year,

which resulted in changes to fair value adjustments

from hedge accounting, mostly on residential

mortgages.


ABN AMRO	Annual Report 2025	50


≡	Strategy & performance	Economic outlook 2026

Economic outlook

Global growth resilient despite rising risks

We expect the global economy to remain resilient in 2026. However, risks

remain numerous, with the Middle East emerging as the latest flashpoint.

Extra government spending in Germany and earlier ECB interest rate cuts

will support economic activity in the eurozone.

The US economy also remains solid, though the reliance

on investment in artificial intelligence (AI) and the

increasing vulnerability of its institutions could start to

weigh on performance. The gap between interest rates

will become smaller as the European Central Bank

(ECB) is expected to keep policy unchanged for now,

while the Federal Reserve continues to cut rates.

German spending helps European activity

The eurozone is expected to continue its gradual

recovery. That said, US import tariffs and the uncertainty

surrounding them after the US Supreme Court ruling

are weighing on European exporters. A recovery in

domestic demand, boosted by earlier ECB rate cuts, will

help stabilise growth. Increased defence spending and

German infrastructure investments will support

economic activity. While recent hostilities in the Middle

East pose risks for energy markets, inflation has so far

continued to decline to below the ECB’s 2% target.

However, core inflation, which excludes energy prices,

remains near that level. At this point, we expect the ECB

to keep the deposit rate at 2% until the end of 2026.

Outside Europe, the US economy continues to expand,

largely due to investments in AI and the easing of

monetary and fiscal policies. Trade tariffs and

immigration policies are gradually taking their toll,

however. US inflation is rising as firms increase prices to

cover import duties. Unemployment is rising only

slightly as labour supply and demand remain broadly

balanced. China is supporting demand and continuing

its industrial growth model. Even so, these measures are

insufficient to prevent a further slowdown and ongoing

pressures from falling prices.

Dutch labour market to remain tight

The Dutch economy is resilient and growth is expected to

normalise in 2026. Growth will be domestically driven as

weaker international trade – due to tariffs and geopolitical

tensions – and higher energy and labour costs reduce

Dutch exporters’ competitiveness. The economy faces

several bottlenecks, including nitrogen-emission

restrictions and congested power grids. Bankruptcies are

expected to see a marginal rise after the recent downward

trend. Economic growth will be supported by earlier ECB

rate cuts and higher government spending, both in the

Netherlands and in Germany, its main trading partner.

Labour demand will diminish as vacancies decline, though

staff shortages will remain the key challenge for

businesses. With unemployment at an all-time low, wage

growth will stay high. Combined with falling inflation, this

will boost purchasing power and consumer spending.

Dutch house price increases to slow

We expect Dutch house prices to rise by 3% in 2026,

but the pace is slowing as mortgage rates have begun

to rise again. Mortgage lenders, including ABN AMRO,

face higher financing costs as increasing government

debt pushes up capital market rates. House prices will

continue to rise because of income growth and the

housing shortage. Labour shortages, long procedures

and nitrogen rules are constraining new development.

Stricter rental regulation, higher taxes on rent income,

and rising land prices are reducing investors’ appetite

for rental housing. As a result, landlords selling rental

properties have temporarily boosted housing

transaction volumes. We expect this effect to decrease

in 2026.

Our economic projections


ABN AMRO	Annual Report 2025	51

Risk, funding & capital


Capital	117
Management Control Statement	124
Additional risk, funding & capital disclosures	130
About risk, funding & capital	142


ABN AMRO	Annual Report 2025	52


≡	Risk, funding & capital	Interview with our Chief Risk Officer

Interview with our Chief Risk Officer

Serena Fioravanti | CRO of ABN AMRO

“The Risk department is

now positioned closer

to the heart of the bank”

One year into her role as Chief Risk

Officer, Serena Fioravanti reflects

on achievements in 2025 and

shares her vision of the bank as a

‘stable island’ in a volatile world.

“Our de-risking is clearly bearing

fruit and we are making significant

progress on optimising our capital

allocation,” she says. “Our stability

and predictability give us the right

to grow again.”

Looking back, how would you sum up your first

year at the bank?

“It has been an intense but very rewarding year. We

implemented the Basel IV capital rules and finalised the

move to standardised credit risk approaches for certain

parts of our portfolio. At the same time, we began

reshaping the Risk organisation around its four strategic

pillars: simplicity, execution focus, risks that matter and

risk culture. This meant introducing a new

organisational structure, shifting resources towards the

capabilities we need for the future and supporting

major strategic developments such as the integration of

Hauck Aufhäuser Lampe (HAL) and preparations for the

intended acquisition of NIBC.”

It was a turbulent year for global business. What’s

your view on ABN AMRO’s performance in that

environment?

“2025 was a good year for us. When the world around

us felt unstable and geopolitics dominated the

headlines, ABN AMRO provided stability and

predictability. We experienced very few credit losses

and even felt confident enough to lower our through-

the-cycle cost of risk. This reflects our confidence in the

quality of our loan book and our ability to weather

economic downturns. In short, we proved we can be a

stable island in an unpredictable environment, which

earns us the right to think bigger, bolder and better – by

taking selective, controlled risks that support the

strategy.”

What is behind that stability?

“The de-risking of the bank is clearly bearing fruit: we

now focus on markets in Northwest Europe that we

know very well, our clients tend to be loyal and our

portfolio is largely collateralised. Completing the work

on Basel IV and on our credit risk models has also made

our capital framework more predictable.

On top of that, we freed up risk-weighted assets (RWA),

which is the basis for calculating how much capital we

need to hold against our loans. We achieved this by

improving our loan data and through several portfolio

optimisation transactions, including significant risk

transfers. These transactions allow us to move part of

the credit risk on corporate loans to institutional

investors. It’s an effective way to contain our RWA and

shift capital to areas that better fit our growth strategy.”

Talking about growth, how do you view the

intended acquisition of NIBC?

“From a risk perspective, NIBC is a strong match for us.

Most of its business consists of mortgages and savings

products in our home market. The same applies to its

corporate portfolio: it is focused on regions and sectors

in which we already have a strong presence. We also

work with similar systems and providers, which should

support a smooth integration. Of course, we will look

closely at the portfolio details and regulatory

expectations, but overall it is a business that we know

and can manage well.”


ABN AMRO	Annual Report 2025	53


≡	Risk, funding & capital	Interview with our Chief Risk Officer

Which emerging risks are you most focused on?

“While we feel very comfortable with our financial risks

– credit quality, capital and cost of risk – the

non‑financial risks are becoming more prominent and

complex. IT resilience remains front and centre. But this

now goes beyond cyber threats; it also includes the risk

linked to third-party dependencies. Geopolitical

tensions could force suppliers to change course,

creating constraints around data, access or continuity.

Not so long ago, this scenario would have been

unthinkable. But the past year has taught us that we

must be prepared, so that we can continue to serve our

clients whatever happens.”

“The past year has taught us

that we must be prepared, so

that we can continue to serve

our clients whatever

happens.”

What role does Risk play in supporting the bank’s

new strategy?

“Since joining in 2024, I have focused on making Risk

Management a simpler and more execution-driven

organisation that helps the bank grow. Risk used to be a

quality assurance function at the end of the line. Today,

we are an execution partner positioned right at the

heart of the bank. We get involved earlier, and

simplifying the way we work means we can deliver

more effectively. In short, we have moved much closer

to the business, helping the bank to take the right risks

in the right places.”

This clearly echoes the first three pillars of the

Risk strategy: simplicity, execution focus and risks

that matter. The fourth pillar is risk culture. Why is

this so important?

“Culture brings it all together. ABN AMRO has always

felt like a family to me. People are collaborative, they

invite each other in and they care. There is a strong

culture of discussion and exchange, which encourages

everyone to speak up. In Risk, we deal with everything

from credit transactions and models to cyber risk,

operational resilience and regulatory requirements. We

cannot be experts on everything, so we need to rely on

people with different skills and perspectives to bring

important issues to the surface.

A sound risk culture also requires accountability and

decisive leadership. You listen to the various points of

view, then you make a decision and you stick to it. A

tough but necessary decision we took last year was to

reduce our workforce, which also affected Risk

colleagues. That calls for accountability too – you need

to be transparent and support colleagues as they move

to new roles or career paths.”

In closing, what are your top priorities in the

year ahead?

“We will support controlled growth by strengthening

resilience to emerging risks, enabling capital-efficient

growth and focusing on the risks that matter. By

keeping things simple, making clear choices and

executing decisively, we will help the bank move

confidently into its next phase.”


ABN AMRO	Annual Report 2025	54


≡	Risk, funding & capital	Key risk developments

Key risk developments

Key figures


(in millions)	31 December 2025	31 December 2024
Total loans and advances, gross excluding fair value adjustments¹	264,077	256,153
- of which Banks	2,174	2,053
- of which Residential mortgages	163,185	156,209
- of which Consumer loans	6,266	7,575
- of which Corporate loans¹	86,516	83,827
- of which Other loans and advances customers¹	5,936	6,489
On-balance sheet maximum exposure to credit risk	408,228	381,484
Total Exposure at Default (EAD)²	396,130	390,006
- of which Personal & Business Banking	184,841	176,041
- of which Wealth Management	31,382	19,619
- of which Corporate Banking	94,190	107,060
- of which Group Functions	85,717	87,286
Credit quality indicators¹
Forbearance ratio	1.8%	2.0%
Past due ratio	0.7%	0.9%
Stage 3 ratio	2.1%	2.1%
Stage 3 coverage ratio	17.3%	18.5%
Cost of risk (in bps)³	1	-2
Regulatory capital
Total risk-weighted assets²	135,398	140,871
‐ of which Credit risk ^{2, 4}	116,153	122,779
- of which Operational risk²	17,628	15,977
- of which Market risk²	1,618	2,115
Total RWA/total EAD²	34.2%	36.1%
Liquidity and funding indicators
Loan-to-Deposit ratio	92%	97%
LCR ⁵	153%	138%
NSFR	141%	137%
Capital ratios
CET1 ratio	15.4%	14.5%
Total MREL	34.7%	34.6%
Fully-loaded leverage ratio (incl. central bank exposure)	5.3%	5.7%
1. Excluding fair value adjustments from hedge accounting.
2. As of 1 January 2025, the figures in the table are prepared in accordance with CRR III (Basel IV) regulations. The figures up to 31 December 2024 were prepared in accordance with CRR II (Basel III) regulations.
3. Impairment charges on loans and advances customers for the period divided by the average loans and advances customers on the basis of gross carrying amount and excluding fair value adjustment from hedge accounting.
4. RWA for credit value adjustment (CVA) is included in credit risk. CVA as at 31 December 2025 is EUR 0.2 billion (31 December 2024: EUR 0.1 billion).
5. Consolidated LCR based on a 12-month rolling average.


ABN AMRO	Annual Report 2025	55


≡	Risk, funding & capital	Key risk developments

Key risk figures per business segment


					31 December 2025
(in millions)	Personal & Business Banking	Wealth Management	Corporate Banking	Group Functions	Total
Total assets	174,893	31,478	91,316	115,523	413,210
Total Exposure at Default	184,841	31,382	94,190	85,717	396,130
RWA (CRR III)
Credit risk¹	32,833	13,404	67,607	2,309	116,153
Operational risk	7,467	3,884	6,277		17,628
Market risk		2	1,616		1,618
Total RWA (CRR III)	40,300	17,290	75,500	2,309	135,398
Total RWA/Total Exposure at Default	21.8%	55.1%	80.2%	2.7%	34.2%
Economic capital
Credit risk	2,688	1,425	6,449	706	11,268
Operational risk	900	372	756		2,028
Market risk			126	4,322	4,449
Business risk	256	216	726		1,198
Other risk types²	205	51	124	95	476
Economic capital	4,050	2,064	8,181	5,124	19,418
					2025
Average risk exposure amount (CRR III)	38,533	15,671	85,238	2,815	142,257
Cost of risk (in bps)³	-5	6	12		1
1. RWA for credit value adjustment (CVA) is included in credit risk. CVA as at 31 December 2025 is EUR 0.2 billion (31 December 2024: EUR 0.1 billion).
2. Other risk types include strategic equity investments risk and property risk.
3. Impairment charges on loans and advances customers for the period divided by the average loans and advances customers on the basis of gross carrying amount and excluding fair value adjustment from hedge accounting.


					31 December 2024
(in millions)	Personal & Business Banking	Wealth Management	Corporate Banking	Group Functions	Total
Total assets	163,586	17,826	99,162	104,473	385,047
Total Exposure at Default	176,041	19,619	107,060	87,286	390,006
RWA (CRR II)
Credit risk¹	31,417	9,110	79,375	2,876	122,779
Operational risk	6,832	2,842	6,163	139	15,977
Market risk			2,115		2,115
Total RWA (CRR II)	38,249	11,952	87,654	3,015	140,871
Total RWA/Total Exposure at Default	21.7%	60.9%	81.9%	3.5%	36.1%
Economic capital
Credit risk	2,410	999	6,464	714	10,586
Operational risk	836	331	717	16	1,900
Market risk			126	3,660	3,786
Business risk	306	248	455		1,009
Other risk types²	224	45	132	5	407
Economic capital	3,777	1,623	7,894	4,394	17,688
					2024
Average risk exposure amount (CRR II)	38,174	12,454	88,748	4,814	144,191
Cost of risk (in bps)³	-6	8	6		-2
1. RWA for credit value adjustment (CVA) is included in credit risk. CVA as at 31 December 2025 is EUR 0.2 billion (31 December 2024: EUR 0.1 billion).
2. Other risk types include strategic equity investments risk and property risk.
3. Impairment charges on loans and advances customers for the period divided by the average loans and advances customers on the basis of gross carrying amount and excluding fair value adjustment from hedge accounting.


ABN AMRO	Annual Report 2025	56


≡	Risk, funding & capital	Key risk developments

Loans and advances

In 2025, total loans and advances increased to

EUR 264.1 billion (31 December 2024:

EUR 256.2 billion). This growth was primarily driven by

an expansion in residential mortgage loans, reflecting

our strong position in a robust mortgage market.

Corporate loans also increased, largely due to the

acquisition of HAL.

The increase in total loans and advances was partly

offset by wind-down activities within corporate loans at

Asset Based Finance. In addition, consumer loans

decreased, mainly due to the reclassification of loan

portfolios of our subsidiary Alfam to assets held for sale.

Exposure at default

Exposure at default increased to EUR 396.1 billion

(31 December 2024: EUR 390.0 billion), driven largely

by the increase in loans and advances due to loan

portfolio growth in residential mortgages and the

acquisition of HAL.

Credit quality indicators

The credit quality indicators remained solid throughout

2025. The forbearance ratio improved to 1.8%

(31 December 2024: 2.0%). Forborne exposure

decreased to EUR 4.8 billion (Q4 2024: EUR 5.1 billion),

mainly because permanent forbearance measures

relating to some corporate loans ended. Approximately

37% of forborne exposure is currently subject to a

temporary measure.

The past due ratio decreased to 0.7%

(31 December 2024: 0.9%) and the stage 3 ratio

remained stable at 2.1%. The stage 3 coverage ratio

decreased to 17.3%, driven by portfolio developments

and the reclassification of portfolios of our subsidiary

Alfam to assets held for sale. The cost of risk remained

low at 1 basis point over 2025.

Risk-weighted assets

As of 1 January 2025, we report our risk exposures in

line with Capital Requirements Regulation (CRR) III.

Comparative figures for 31 December 2024 are

reported under CRR II. In the third quarter of 2025, we

completed the transition of certain portfolios to the

Standardised Approach. Following this transition, the

use of modelled approaches has been narrowed down

to residential mortgages, banks and financial

institutions.

Total RWA decreased to EUR 135.4 billion

(31 December 2024: EUR 140.9 billion) over the year.

This decrease was primarily caused by a EUR 6.6 billion

decline in credit risk RWA, mainly reflecting RWA

optimisation initiatives within Corporate Banking. The

decrease was partly offset by higher RWA in Wealth

Management, which was largely attributable to the

acquisition of HAL and the transition of certain

portfolios to the Standardised Approach.

Over the year, market risk RWA fell by EUR 0.5 billion

due to position changes, while CVA risk RWA

(counterparty credit risk) rose by EUR 0.1 billion.

Operational risk RWA increased by EUR 1.7 billion

compared with 2024. This RWA increase can be

attributed to the bank’s income growth in the past few

years, which forms the basis for the RWA calculation,

and to the inclusion of HAL in Q3 2025. In keeping with

the CRR III regulations regarding the operational risk

framework, the three-year period used for the

calculations is based on full calendar years, with

updates occurring in the fourth quarter. Accordingly,

the operational risk own funds requirements for

Q4 2025 are based on financial figures from the period

2023-2025.

RWA flow statement - credit risk

(in millions)

1. Asset quality includes risk transfer transactions.


ABN AMRO	Annual Report 2025	57


≡	Risk, funding & capital	Key risk developments

Economic capital

Economic capital (EC) increased to EUR 19.4 billion

(31 December 2025) from EUR 17.7 billion

(31 December 2024), reflecting higher credit risk EC

(EUR 0.7 billion), market risk EC (EUR 0.7 billion),

business risk EC (EUR 0.2 billion) and operational risk EC

(EUR 0.1 billion). The increase in credit risk EC was

mainly driven by methodological updates, application

of increased conservatism and the acquisition of HAL.

The change in market risk EC (in the banking book) was

primarily due to methodological adjustments. The

increase in business risk EC was mainly the result of

higher risk in business earnings and franchise value.

Operational risk EC increased as a consequence of

changes in income as well as the integration of HAL.

Liquidity and funding indicators

The loan-to-deposit (LtD) ratio fell to 92% as at

31 December 2025 (31 December 2024: 97%). This

was driven by increases in amounts due to customers,

which grew significantly to EUR 279.1 billion as at

31 December 2025 (31 December 2024:

EUR 256.2 billion), and in loans and advances to

customers, which rose slightly to EUR 255.8 billion as at

31 December 2025 (31 December 2024:

EUR 248.8 billion). These developments mainly reflect

loan growth in mortgages as well as the consolidation

of HAL’s deposits in the statement of financial position

with effect from July 2025.

The liquidity coverage ratio (LCR) and the net stable

funding ratio (NSFR) both remained above 100%

throughout 2025. Total wholesale instruments

decreased to EUR 83.0 billion as at 31 December 2025

(31 December 2024: EUR 85.4 billion). This was mainly

caused by a reduction in short-term funding from

seasonal balance-sheet steering, which was partly

offset by an increase in long-term wholesale funding.

This increase in long-term funding reflects a rise in

covered bond and senior preferred funding, and was

partly offset by a decline in senior non-preferred and

subordinated debt.

Capital ratios

As at 31 December 2025, the Common Equity Tier 1

(CET1), Tier 1 and total capital ratios were 15.4%,

17.8% and 20.9% respectively (31 December 2024:

14.5%, 16.9% and 20.2% respectively). The CET1

capital ratio increased compared with

31 December 2024 due to a decrease in RWA and an

increase in CET1 capital. The CET1 capital position

increased mainly as a result of unrealised gains on

investments in debt securities caused by market

movements, the addition of the 2025 net profit after

deduction of AT1 coupons and distributions, which was

partly offset by higher capital deductions.

The leverage ratio decreased to 5.3% as at

31 December 2025 (31 December 2024: 5.7%), mainly

due to an increase of the exposure measure, which was

partly offset by the increase in Tier 1 capital. The total

MREL ratio rose to 34.7% (31 December 2025: 34.6%).

As at 31 December 2025, the reported total MREL ratio

includes EUR 0.5 billion of newly issued MREL-eligible

senior preferred instruments and EUR 0.5 billion of

grandfathered senior preferred liabilities.

Emerging risks

Geopolitical risk

The year 2025 remained characterised by elevated

geopolitical tensions affecting the global economic and

financial environment.

An escalation of US trade policy, including higher

import tariffs, and increased uncertainty in global trade

flows might continue to adversely affect

export‑oriented economies such as the Netherlands.

The potential impact on the bank’s clients is mitigated

through well-diversified exposures and close

monitoring of trade‑sensitive sectors. In addition, we

make use of adverse scenarios in stress testing.

In the Middle East, the escalation between Israel and

Iran contributed to continued regional instability. Given

the Bank’s limited direct exposure, direct risks are

considered manageable. Indirect effects could arise as a

result of higher energy price volatility, supply chain

disruptions and elevated market risk premiums. These

risks are limited by setting risk appetite limits. We also

incorporate increased market volatility in our scenario

analyses.

Within Europe, renewed concerns around sovereign

debt sustainability, notably in France, led to increased

market scrutiny and wider credit spreads. While no

immediate systemic risks materialised, prolonged

uncertainty could put consumer confidence and growth

under pressure. The bank limits these risks by setting

sovereign exposure limits and conducting regular

country risk reviews.

In Germany, the partial suspension of the balanced

budget amendment (Schuldenbremse) allows increased

capital market borrowing to finance defence and

climate related investments. While this supports long-

term growth, additional issuance could place upward

pressure on interest rates. These risks are mitigated

through active management of interest rates and

liquidity management.


ABN AMRO	Annual Report 2025	58


≡	Risk, funding & capital	Key risk developments

In the Netherlands, geopolitical risk was primarily driven

by post‑election political uncertainty, resulting in

delayed policy clarity in areas such as climate and fiscal

policy. The bank mitigates domestic policy risk by

means of ongoing portfolio reviews and conservative

underwriting in policy‑sensitive sectors.

Going forward, geopolitical risks are expected to remain

elevated. These risks are incorporated into the bank’s

forward‑looking macroeconomic scenarios, credit risk

assessments and modelled loan impairment

calculations.

Cyber risk

The rapid adoption of new technologies in the cyber

domain continues to offer opportunities for the bank,

but it also increases our exposure to cyber‑related

threats. These threats are becoming more sophisticated

and persistent, which means continued investment in

our cyber‑security capabilities is essential to protect our

critical IT infrastructure.

Adversaries are increasingly leveraging AI, enabling

them to execute attacks with greater speed, precision

and scale. In a threat environment influenced by

ongoing geopolitical tensions, this calls for heightened

vigilance as motives and attack methods can change

rapidly. We closely monitor the threat landscape on an

ongoing basis, which allows us to adjust our defences

and respond quickly to emerging risks and evolving

tactics.

The importance of digital resilience is further

underscored by the EU’s Digital Operational Resilience

Act (DORA). The bank fully embraces this framework, as

it strengthens the financial sector’s focus on the risks

that matter most and highlights the importance of a

robust ability to prevent, withstand and recover from

ICT‑related disruptions.

Strong recovery capabilities, comprehensive business

continuity planning and enhanced security monitoring

remain core elements of our approach. Phishing,

particularly when used as a precursor to ransomware

attacks, data exfiltration or fraudulent transactions,

remains a prominent and persistent threat. We expect

cyber risks of this nature to continue to pose significant

challenges for both the bank and our clients in the years

ahead.

AI risk

Artificial intelligence (AI) is increasingly being adopted

around the world and it is also impacting and

transforming the banking sector. Generative AI

technologies have made significant strides in terms of

capabilities and are expected to continue developing

and improving; this will create opportunities for the

bank. Having proper risk management controls in place

will ensure responsible use and the implementation of

trustworthy AI. The internal risks arising from the bank’s

use of AI are actively managed. Internal risks also arise

from vendors applying AI to products and services used

by the bank. In 2025, the bank made further progress

on the implementation of the AI Act, reflecting phased

regulatory milestones (including AI literacy and

prohibited practices) and preparations for upcoming

compliance. Minimum requirements have been

formalised in an AI Risk Standard. Our risk management

framework will be enhanced to support innovation

through AI, and our capacity and knowledge are being

expanded to continue the development of responsible

AI risk management.

ESG risk

Environmental, social and governance (ESG) risks

remain a key area of focus for the bank and our

stakeholders. From a climate perspective, uncertainty

about the pace of the transition to a net-zero economy

persists, owing to a fragmented policy landscape and

mixed market signals among other things. Over the

longer term, the physical impact of climate change and

potential liability for unmet climate goals could

challenge the financial resilience of our clients. Social

risks, including shifting societal expectations about

inclusive products and services and demographic

changes (e.g. an ageing population, which affects

demand for banking products), are emerging as

important drivers. These factors are considered as risk

drivers in our double materiality assessment. For more

information on how we manage ESG risk, please refer to

the Sustainability statements chapter.


ABN AMRO	Annual Report 2025	59


≡	Risk, funding & capital	Risk management	Risk management framework

Risk management

Risk management framework



	This section provides information on: • Risk taxonomy • Risk appetite framework • Risk governance • Risk measurement

ABN AMRO is committed to being a well-capitalised

and sufficiently liquid bank that focuses on delivering

sustainable value to all of its stakeholders. This is

defined by our strategic risk appetite statement and

ensured by our risk management framework.

A core component of our risk management framework

is the enterprise risk management (ERM) cycle, which

safeguards that risks are identified, assessed,

addressed, monitored and reported consistently across

the bank.

Risk taxonomy

Audited

A key outcome of the risk identification step in the ERM

cycle is the risk taxonomy, which provides the

foundation for the reiterative process of defining and

managing material risks within the bank’s risk

management framework. The risk taxonomy is reviewed

and updated on an annual basis, or sooner if an update

is required due to the emergence of any new material

risk type.

The taxonomy considers materiality of risks based on

an assessment of financial and non-financial impact in

combination with likelihood. The key financial risk types

related to our business model are credit risk, liquidity

risk and market risk in the banking book. The chart

below depicts our risk taxonomy in place for 2025.

In 2025, the bank reviewed and updated its criteria for

assessing materiality to ensure a focus on the most

relevant risks. In 2026, we will monitor and report on

our risks in accordance with the updated risk taxonomy.

Consistent with the principles underpinning the new

strategy, the risk taxonomy will be simplified in 2026,

concentrating on those risks that are most relevant for

the bank’s steering and decision-making.

Risk taxonomy

Audited

External causal factors

Politics, (macro) economy, society, technology,

environmental, social and governance (ESG, e.g. physical and

transition risk, legislation and regulation)

Internal causal factors

People, processes, systems, balance sheet,

products (e.g. mis-selling, greenwashing), clients,

reputation and behaviour

Enterprise risk

Financial risk

Non-financial risk

Credit risk

Liquidity risk

HR risk

ICT risk

Fraud risk

Data risk

Market risk in

the banking

book

Business risk

Change risk

Compliance

risk

Model risk

Third-party

and

outsourcing

risk

Market risk in

the trading

book

ESG risk

Legal risk

Tax risk

Behavioural

risk

Value of the bank

• Financial • Reputational


ABN AMRO	Annual Report 2025	60


≡	Risk, funding & capital	Risk management	Risk management framework

Risk appetite framework

Audited

Our risk appetite determines the level of risk that the

bank is willing to take in order to pursue its strategy. It is

regularly evaluated and updated to ensure continuous

alignment with our strategy.

Strategic

Risk Appetite Statement

Strategic Risk Indicators

Bank

Risk Appetite Statement

Key Risk Indicators

Client Units RAS

Local & Entities RAS

The Strategic Risk Appetite Statement entails three

focus areas, each of which is substantiated by a

qualitative statement and concrete strategic risk

indicators (SRIs). In 2025, the Strategic Risk Appetite

Statement SRIs were further articulated in the bank-

wide Bank Risk Appetite Statement (bank RAS) and key

risk indicators (KRIs), which were cascaded to risk

appetite statements at a client unit level (client unit

RAS), local level (LRAS) and entity level (ERAS). In

alignment with the principles of ABN AMRO’s new

strategy, the risk appetite framework will be adjusted in

2026, resulting in a simplified structure whereby the

strategic and bank RAS layers are consolidated into a

single bank-wide layer.

The risk indicator framework consists of quantitative

and/or qualitative SRIs and KRIs. A limit and checkpoint

is set for every SRI and KRI, against which the actual risk

profile is monitored. Examples of SRIs and KRIs in our

risk appetite include:

• regulatory and internal capital ratios

• risk-adjusted return metrics

• concentration limits for counterparties, products,

sectors and countries

• economic capital and risk-weighted asset limits for

various risk types

• regulatory and internal liquidity metrics

• market risk parameters (supervisory outlier test on net

interest income and supervisory outlier test on

economic value of equity)

• non-financial risk parameters (effectiveness of

internal control environment)

• several ESG risk appetite indicators

The status of adherence to the risk appetite and the

outlook are discussed every month by the Executive

Board, and every quarter by the Supervisory Board,

based on the CRO memo.

Strategic Risk Appetite Statement

Audited




Sustainable business model & value creation		Financial soundness
Sustainable business model & value creation	Banking for better, for generations to come	Financial soundness

	Sound operating environment

Risk governance

Audited

Effective risk management requires organisation-wide

risk governance. Our risk and control structure is based

on the ‘three lines of defence’ governance model, which

has been designed to ensure risk is managed in line

with the risk appetite approved by the Executive Board

and Supervisory Board.

Three lines of defence

The three lines of defence model aims to clarify the

relationship between risk takers and the internal control

functions, and provides all employees within the bank

with clarity regarding their risk management

responsibilities. This defence model is applied across all

risk types and covers the whole organisation, including

the client units, functions, the Risk Management

organisation, outsourced activities and distribution

channels.


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≡	Risk, funding & capital	Risk management	Risk management framework

Three lines of defence

Audited



1	1st Line of Defence	2	2nd Line of Defence	3	3rd Line of Defence
1		2		3
Risk Ownership		Risk Control & Oversight		Risk Assurance

Responsibility • Delivers value-added services to our clients • Owns and manages risks and implements internal controls for day-to-day operations • Operates within the risk appetite • Strikes the right balance between return and risk in its decisions • Seeks outside-in views and advice, where necessary • Ensure systems, processes and reporting capabilities are commensurate with its activities and risk appetite		Responsibility • Sets the bank-wide risk management framework • Sets risk policies and ensures regulations are translated into policies • Sets the risk appetite • Maintains risk control and oversight through monitoring, reporting and escalating, where necessary • Provides independent challenge and expertise to the First Line • Proactively challenges the risk management practices of the First Line • Provides outside-in views and ensures consistency in risk management practices across the First Line		Responsibility • Protects and enhances organisational value by providing risk-based and objective assurance, insight and added value to support the achievement of our objectives • Evaluates the design and effectiveness of governance, risk management and control processes, agrees with management on remediation and monitors follow-up

• The first line of defence comprises management

within each client unit or function (such as Finance,

Innovation & Technology, HR, Asset & Liability

Management/Treasury), who are responsible for

managing the risks they incur in conducting their

activities and for executing effective and efficient

controls.

• The second line of defence consists of dedicated

departments in the Risk Management organisation

and Legal, which are responsible for setting the risk

management framework as well as the risk appetite

within which the first line must operate.

• The third line of defence is the internal audit function,

which provides assurance on the adequacy of the risk

management activities performed by the first and

second lines of defence based on an independent

assessment.

Board-level oversight

ABN AMRO has a two-tier governance model consisting

of an Executive Board and a Supervisory Board. The

Executive Board and Supervisory Board of ABN AMRO

define the governance arrangements aimed at ensuring

effective and prudent management of the bank and

oversee the implementation of these arrangements.

The Boards are accountable for setting, approving and

overseeing the implementation of the bank's risk

management framework, including:

• an adequate and effective internal governance and

internal control framework that includes a clear

organisational structure and well-functioning

independent internal risk management, compliance

and audit functions that have sufficient authority,

expertise, stature and resources to perform their tasks

• an adequate and effective three lines of defence

model at the bank

• a risk culture that addresses risk awareness at the

bank, risk ownership and risk-taking behaviour

• a corporate culture and values that foster responsible

and ethical behaviour, including a code of conduct

• the bank’s key policies within the applicable legal and

regulatory framework

• the overall risk strategy, including the bank’s risk

appetite and risk management framework and

measures to ensure the management body devotes

sufficient time to risk issues

• the amounts, types and distribution of both internal

capital and regulatory capital to provide adequate

cover for the bank’s risks

• targets for the bank’s capital and liquidity

management

The Risk Management organisation operates under the

direct responsibility of the Chief Risk Officer, who is a

member of the Executive Board.


ABN AMRO	Annual Report 2025	62


≡	Risk, funding & capital	Risk management	Risk management framework

Executive risk committees

The Executive Board is responsible for setting,

monitoring, reviewing and realising the bank’s mission,

vision, strategy, risk appetite and risk framework, with a

view to creating long-term value for the bank and

ensuring that effective internal risk management and

control systems are in place. In this context, the

Executive Board approves the materiality assessment

methodology and results as well as the risk taxonomy

every year. The internal capital adequacy plan (ICAAP),

business model analysis and climate resilience analysis

are also approved by the Executive Board.

In the risk decision-making framework, the Executive

Board has set up three executive risk management

committees, which are described below.

Group Risk Committee

The Group Risk Committee (GRC) is mandated by the

Executive Board to monitor, assess and manage the

bank’s risk profile within the approved risk appetite. The

GRC monitors and approves all material risks as defined

in the bank’s risk taxonomy. The GRC is chaired by the

Chief Risk Officer and meets at least once a month.

The GRC has delegated specific approval powers to

sub-committees, including client unit and Innovation

and Technology (I&T) risk committees, Strategic Product

Approval Committees (SPACs), the Scenario and Stress

Testing Committee (SSC), the Impairment and

Provisioning Committee (IPC), the Financial Crime Risk

Committee (FCRC), the Engagement Committee, and

the Methodology Acceptance Group (MAG).

Group Central Credit Committee

The Group Central Credit Committee (CCC) is

mandated by the Executive Board to make decisions on

the acceptance of credit and counterparty risk in

respect of individual persons, legal persons and public

administrative bodies relating to credit proposals falling

within the scope of the risk appetite determined by the

Executive Board. In addition, the CCC is responsible for

approving and monitoring large intercompany credit

facilities. The CCC is chaired by the head of Credit Risk

and convenes twice a week.

Regulatory Committee

The Regulatory Committee (RC) is responsible for a

bank-wide understanding, adequate oversight and

decision taking on matters relating to the timely

regulatory compliance of the Group to current, new and

changing national and international laws and

regulations, supervisory expectations and the

remediation of supervisory findings. The RC is chaired

by the Chief Risk Officer and convenes at least once

every two months.

Risk measurement

We develop and implement internal models to assess

the various risk types in our risk taxonomy. These

models support daily decision-making and periodic

monitoring of the bank’s portfolio and activities. They

estimate the probability and effect of potential events,

forming the basis for ABN AMRO’s internal risk

measures (economic capital) and regulatory capital

calculations under the Basel framework (regulatory

capital).

New models require approval before use. Such

approval is granted by the Methodology Acceptance

Group (MAG), a subgroup of the Group Risk Committee,

following validation by independent model validators.

External approval is sought from supervisory authorities

when necessary, especially for new Pillar 1 models or

those undergoing significant changes.

Our modelling teams work closely with business and

risk experts to develop models, which are validated at

least every three years or more frequently for critical

models. Annual monitoring involves back-testing,

assessing changes impacting the model, and

benchmarking with external data when relevant.

Corrective actions, like redevelopment or recalibration,

are taken if model performance declines or the

portfolio’s risk profile changes significantly. The

independent Model Validation & Model Risk

Management department validates internal models

according to the model risk management framework,

which includes model validation standards and

procedures. This ensures that models are validated in a

consistent and independent manner. Model data,

methodology, performance and implementation are

checked according to these standards and reviewed

against internal and regulatory requirements. The Head

of Model Validation & Model Risk Management reports

directly to the Chief Risk Officer.

Capital measurement

Regulatory capital (CRD V/CRR III)

In the European Union (EU), the Basel framework is

implemented via the Capital Requirements Directive

(CRD) and Capital Requirements Regulation (CRR). The

‘Basel IV’ package refers to the updates CRR III and

CRD VI (this is an EU Directive that has to be transposed

into local legislation). In the Netherlands, the

transposition of the CRD VI changes has been delayed

until the spring of 2026. The CRR III update is

applicable with effect from 1 January 2025 and

therefore applies to reporting dates after that date.


ABN AMRO	Annual Report 2025	63


≡	Risk, funding & capital	Risk management	Risk management framework

These capital requirements specify how much capital

and buffers the bank needs to have in place to cover its

financial risks.

When determining their capital requirements, banks

have to calculate their exposure to three major risk

types (credit risk, operational risk and market risk). The

changes compared with CRD V/CRR II concern the

calculations to be made within these different risk

areas:

• Within the area of credit risk, the regulations are

moving towards more standardised calculations by

removing the possibility of applying certain

approaches to certain types of exposures and through

the introduction of additional floors when internally

modelled approaches are used.

• For operational risk, a new single non-modelled

approach has been introduced to replace the existing

approaches.

• For market risk, new standardised, alternative

standardised and internally modelled approaches

have been introduced. To create a more level playing

field with jurisdictions outside the EU, the European

Commission has decided that these new approaches

will not be applicable for calculating regulatory

capital requirements until 1 January 2027. The

existing approaches therefore continue to apply.

Another key change in the applicable capital

requirements for banks is the introduction of an ‘output

floor’ that is calculated on the basis of all these risk

areas combined. This output floor is calculated as a

percentage of the capital requirements that would

apply if a bank only used standardised approaches for

all risk areas. This output floor is then compared with

the capital requirements that the bank has calculated

using the approaches it has approval for. ABN AMRO is

currently not constrained by this output floor.

The total capital requirements for the bank are

expressed in a total risk exposure amount (TREA). For

ABN AMRO, most of that TREA consists of the risk-

weighted exposure amount, which is also referred to as

risk-weighted assets (RWA). The bank’s capital ratio is

the amount of capital held by the bank divided by the

TREA. The CRR sets required minimum percentages for

such capital ratios and these minimum percentages are

referred to as the Pillar 1 framework or requirements.

Under the CRD, supervisory authorities have the

authority to impose bank-specific additional capital

requirements (on top of Pillar 1). These additional

capital requirements are known as Pillar 2

requirements.

Economic capital

For Pillar 2, we calculate the economic capital (EC) in

addition to the amount of regulatory capital required.

The economic capital covers all risk types in our risk

taxonomy for which capital is deemed to be the

instrument for mitigating unexpected losses, and is

used as the key metric for internal risk measurement

and management. It is the amount of capital we reserve

in order to achieve a sufficient level of protection

against large unexpected losses that could result from

extreme market conditions or events. Internal models

are used to calculate EC at a 99.9% confidence level

and a one-year time horizon. This implies that the

estimated capital figure for the coming year is sufficient

to cover a level of loss that will be exceeded in only

0.1% of all possible cases. The confidence level is

aligned with the definition of core available financial

resources (core AFR). Core AFR is the amount of capital

that is available to cover losses on a continuity-based

approach (i.e. excluding AT1, Tier 2 and senior non-

preferred instruments). EC is aggregated for all risk

types (without applying inter-risk diversification) to

determine the total EC at bank level and to support

capital adequacy assessment, capital allocation, ex-post

performance measurement and risk appetite setting,

such as industry concentration risk limits.


ABN AMRO	Annual Report 2025	64


≡	Risk, funding & capital	Risk management	Risk management framework

Stress testing and scenario analysis

Audited

ABN AMRO uses stress testing and scenario analysis as

an important risk management instrument. This entails

looking at profitability, capital and liquidity from a bank-

wide perspective in various scenarios on a regular basis.

The stress testing framework covers both internal and

external stress test types. In addition, sub-portfolio and

risk type-specific stress testing and scenario analyses

are performed. The outcome of stress testing is used for

setting and monitoring risk appetite limits and targets.

Purposes of stress testing

ABN AMRO applies stress testing for several purposes,

including:

• Business planning: various macroeconomic scenarios

for budget purposes.

• Capital planning: stress testing is used to gain insight

into the resilience of our capital under adverse

changes in the economic environment and

ABN AMRO-specific circumstances.

• Risk appetite setting and monitoring: the outcome of

stress testing is used for setting and monitoring risk

appetite limits and targets, including limits under

stress.

• Contingency planning: stress testing is used to assess

and strengthen the triggers and measures in the

liquidity and capital contingency and recovery plans.

Reverse stress testing is performed to gain deeper

insight into plausible events that could put the

continuity of ABN AMRO under pressure.

• Risk type-specific and client unit stress testing, such

as market risk trading and banking book and

mortgage stress testing.

• Supervisory stress testing, based on prescribed

scenarios and assumptions. This includes the stress

test programme of the European Banking Authority

(EBA), which is designed to assess banks’ resilience to

adverse economic or financial developments, and the

ECB economy-wide climate stress test, which aims to

evaluate the impact of alternative climate scenarios

on the resilience of the bank.

This figure shows the stress testing and scenario

analysis cycle.

Stress test & scenario analysis cycle

Audited



			Risk identification

Management action		Stress testing & scenario analysis			Scenario & scope selection
		Stress testing & scenario analysis

	Simulation & impact analysis on ABN AMRO			Data sourcing, models and methodologies

Conduct, governance & control framework

Scenario projections for stress testing purposes are

based on quantitative models as well as expert

opinions. In general, the results are presented together

with the mitigating actions, based on contingency plans,

whenever they result in a breach of a pre-defined

internal threshold. The stress testing framework also

comprises the sensitivity scenarios that address the

impact of various severe events on specific portfolios,

countries and/or sectors, as well as the annual reverse

stress test, in line with regulatory requirements.

Environmental risks are also incorporated into our bank-

wide stress testing framework by including specific

events related to physical risk and drivers of transition

risk, such as carbon prices.


ABN AMRO	Annual Report 2025	65


≡	Risk, funding & capital	Risk management	Credit risk management

Credit risk management



	This section provides information on: • Credit risk management approach • Credit concentration risk • Credit risk quality and impairment • Credit risk measurement • Credit risk mitigation

Credit risk management approach

Audited

Credit risk constitutes a key risk in our business model.

ABN AMRO employs two different approaches to

manage credit risk, which reflect the bank’s way of

doing business. Standardised products and processes

are managed on a pooled basis (programme lending),

to which uniform risk criteria are applied. For

customised lending to counterparties (non-programme

lending), risks are assessed on an individual basis.

Credit risk management process

Audited

The following figure presents a simplified overview of

the credit risk management process.

Planning

Credit acceptance

Loan approval and

disbursement

Credit risk monitoring

Business and risk

control functions

jointly responsible

Restructuring

and recovery

High-risk monitoring

Non-programme

lending

Customised loans,

mostly Wealth

Management,

Corporate Banking

and Business

Banking

(within P&BB)

Risk assessment

by client unit

Regular monitoring¹

Restructuring

Continual update

of risk governance,

management and

policies

Processes reflect

guidelines for credit

risk management

For programme lending,

product-specific

standards are established

ESG risk assessment for

larger OOEs and/or

periodically at

portfolio level

Analysis and credit

decision by credit

risk function

Increased risk

Recovery

Intensive monitoring

(‘Watch’) ²

Loan disbursement

Programme

lending

Standardised

loans, mostly

Personal Banking

(within P&BB)

Credit decision

based on credit

score and policy

rules

Account maintenance

Restructuring

Loan disbursement

Default prevention

Recovery

¹ Daily monitoring or annual or semi-annual credit review.

² ‘Watch’: status assigned to counterparties with an increased risk.

For more insight on our credit portfolio,

please refer to the Credit risk review section.


ABN AMRO	Annual Report 2025	66


≡	Risk, funding & capital	Risk management	Credit risk management

Planning

Within programme lending, the credit cycle starts with

the product planning phase, during which the product is

designed and/or reviewed. The goal is to optimise the

key drivers of risk and return within the context of

ABN AMRO’s strategy, risk appetite, clients’ best

interests and sustainability. For non-programme

lending, the lending product is customised and not

subject to a product planning phase.

Credit acceptance

For a credit approval decision within programme

lending, client-specific risk drivers and external data are

taken into consideration to calculate a credit score

(scorecard). The credit decision is based on the

outcome of the scorecard in combination with the

application of policy rules.

Within non-programme lending, the credit acceptance

phase starts with the creation of a credit proposal by the

relevant client unit. The qualitative and quantitative

details of the credit risk associated with the loan are

assessed and documented. Information must be

provided on matters such as the purpose of the loan,

details and structure of the credit facility, the borrower

and other involved parties, the sector and geography,

management and owners, and potential ESG risks,

along with a detailed financial analysis. In addition,

compliance with internal policies is checked. The credit

proposal first requires approval from the client unit,

after which an analysis is performed by Risk

Management. The final credit decision is based on the

independent assessment by the credit risk function.

Credit risk assessment regarding ESG risks

As part of the credit risk acceptance process for

corporate clients, ESG risks are assessed and evaluated

based on the client’s sector, size and the level of

preparedness for transitioning towards an ESG-aligned

business model. This involves different stages of the

credit lifecycle, including client onboarding, credit

acceptance and the periodical credit review. Various

tools are in place in order to assess these risks at client

level: the Client Assessment on Sustainability (CASY)

tool, the Transition Readiness Assessment (TRA) and the

Risk Classification Tool (RCT). The CASY and RCT

assessments are also subject to review by the credit risk

function. For more information on these tools, please

refer to Risk management of ESG matters - Risk

assessment and measurement.

Credit risk monitoring

Consistent and regular monitoring of counterparties,

exposures, risk mitigants and ongoing compliance with

internal policies helps to safeguard the bank’s position

in relation to all risks associated with the counterparties

and portfolios. Monitoring starts when the credit facility

is granted and continues throughout the lifecycle of the

credit facility and the relationship with the counterparty,

until the exposure has been fully repaid and/or the limit

has been cancelled.

Depending on whether a facility comes under

programme or non-programme lending, a time-based

or event-based review applies. For programme lending

portfolios, the entire risk management framework is

defined in a product programme, which must be

reviewed at least annually. Individual credit reviews are

performed on the basis of pre-defined triggers for risk-

based credit reviews. For non-programme lending, all

counterparties are subject to at least an annual review.

The review takes into consideration potential changes in

the risk profile of the counterparty that can impact

creditworthiness, compared with the assessment at the

point of loan origination.

If a situation arises in which an individual counterparty

shows signs of credit risk deterioration and action is

required to avoid the credit risk turning into a default

classification, a ‘watch’ status is assigned. This status

indicates that a counterparty is subject to increased

monitoring and appropriate follow-up measures, in

order to prevent further deterioration or a default.

Triggers for this status can be changes in the financial

position of the client, potential or actual breaches of

covenants, management issues, or the market or sector

outlook.

In addition to monitoring at counterparty level, the bank

monitors credit risk developments at aggregated level,

including at portfolio, client unit and bank-wide level.

Restructuring and recovery

Non-programme lending counterparties that are subject

to a default event are mandatorily transferred to the

Financial Restructuring & Recovery department (FR&R).

If a ‘going concern’ approach is applicable and return to

a performing status is considered likely, the

counterparty is transferred to the Restructuring team,

which will devise a plan aimed either at rehabilitation or

enhancement of the likelihood of full repayment. If a

‘gone concern’ approach is applicable and the bank

does not expect that the restructuring will result in the

counterparty returning to a performing classification,

the counterparty is transferred to the Recovery team.


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≡	Risk, funding & capital	Risk management	Credit risk management

Once a client is considered able to meet its future

payment obligations and the involvement of FR&R is no

longer required, the client is transferred back to the

client unit.

Programme lending facilities are transferred to the Late

Collections department if a default status is assigned

because payments have been past due for more than

90 days or because another default trigger applies. If

restructuring is ultimately ineffective, the facility is

transferred to other internal departments or external

parties (such as Flanderijn) for debt collection.

Counterparty credit risk

Counterparty credit risk (CCR) refers to the risk that the

counterparty to a transaction defaults before final

settlement of the transaction’s cash flows. In line with

the regulatory definition of CCR, ABN AMRO incurs

counterparty credit risk in two business activities:

derivatives and securities financing transactions.

To manage these risks, limits are set in accordance with

the bank’s risk appetite. Limit requirements are set on

the basis of the counterparty’s creditworthiness and

take account of a range of factors, including the mark-

to-market value and the potential future exposure (PFE)

of the transactions. Trades and exposures are monitored

against approved limits by the second line of defence

and in the event of breaches they are escalated to the

appropriate management levels, when necessary. The

bank can use credit risk mitigants to reduce the size of

the credit risk exposure or likelihood of losses.

Counterparty credit risk mitigation includes the use of

proper legal documentation, collateralisation, netting,

trade or portfolio compression and central clearing.

Credit concentration risk

Audited

Credit concentration risk is the risk of losses arising from

large exposures to a single counterparty or group of

counterparties that are highly positively correlated.

Limiting excessive concentrations is fundamental to

our credit risk strategy, and therefore we aim to keep

the credit risk portfolio sufficiently diversified. To avoid

credit risk concentrations, the bank sets maximum

levels for subgroups in the following categories:

• single counterparty and groups of related

counterparties (counterparty concentration)

• countries (geographic concentration)

• economic sectors (sector concentration)

• products (product concentration)

• ESG risk (physical and/or transition risk concentration)

Counterparty concentration

Counterparty concentration risk is the risk of losses

arising from large exposures to one counterparty or

group of counterparties in a risk group. A risk group is

an interrelated group of counterparties with a high

degree of interdependency due to a control

relationship. This control relationship may be due to

direct or indirect majority interests being held by the

same shareholder or group of shareholders.

Counterparty credit concentration risk is measured by

three metrics: one obligor exposure (OOE), economic

capital (EC) and loss at default (LAD). The OOE is the

total exposure to a risk group and includes all drawn

and undrawn credit facilities granted, plus all indirect

exposures, including guarantees and any other recourse

claims. EC is the internal measure of required capital we

reserve to protect against large unexpected losses,

while the loss at default is the expected loss in the

event that the counterparty defaults. The bank limits

counterparty credit risk by setting OOE, EC and LAD

limits. All credit applications with an OOE/EC/LAD

above the applicable limit are reviewed and require

approval from the Executive Board.

Geographic concentration

Geographic concentration risk is the risk of credit losses

arising from events or circumstances specifically related

to a country or region. ABN AMRO has branches and

subsidiaries located outside the Netherlands, as well as

clients who operate internationally.

Management of country risk focuses on cross-border

risk, which includes the risk that funds, goods or

services cannot be transferred out of a country as

a result of actions by local authorities in that country

or other events. These risks are managed by setting

country credit limits, based on individual country

analyses by economic, compliance and country risk

experts.

Country limits are reviewed at least once a year. Each

country also has an annually reviewed internal credit

rating, which is an important factor in managing country

concentration risks. As the Netherlands is our home

country, it is not included in any concentration risk

appetite statement or credit limit. Given that our

strategic focus is on Northwest Europe, our country risk

exposure has declined significantly in recent years.


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Sector concentration

Sector concentration risk is the risk of losses arising

from large credit exposures to counterparties active in a

single economic sector. Sector concentration risk arises

when deterioration in a specific sector has an effect on

all credit exposures related to that sector. ABN AMRO

manages sector concentration risk by setting limits on

economic capital (EC) for credit risk in each sector as a

percentage of total EC for credit risk. Adhering to these

limits ensures a sufficiently diversified portfolio.

Product concentration

Product concentration risk is the risk of losses arising

from large credit exposures in a specific asset or

product class. This asset or product class concentration

can occur, for example, in residential mortgages,

commercial real estate and leveraged transaction loans.

Limits are defined for each product type in our risk

appetite.

ESG risk concentration

A concentration of clients that are exposed to high

climate transition or physical climate risks can also pose

a risk for the bank. The bank therefore monitors the

concentration of corporate exposures in sectors with

higher climate transition risk. In particular, we limit the

concentration of corporate loans in sectors contributing

highly to climate change and also carbon-related

corporate loans in such sectors. For managing climate

risk in the residential mortgages book, the bank

monitors the percentage of properties that have

relatively high climate transition risks and are located in

an area sensitive to physical climate risk.

Please refer to Effect of climate risk on traditional risk

types for a description of the effect of ESG risks on

credit risk and how these risks are managed.

Credit risk quality and impairment

Audited

We continuously monitor the credit portfolio for signs

indicating that a counterparty may become credit

impaired in the future. Loans at risk are classified into

different risk categories for individual counterparties

and into days-in-arrears buckets for groups of

aggregated counterparties in order to optimise the

monitoring and review of these loans.

Risk stages

At each reporting date, financial instruments in scope of

IFRS 9 are classified into one of three risk stages,

depending on current credit quality, or as purchased or

originated credit impaired (POCI).

The following flow chart shows the risk stage allocation

of financial instruments.


Asset in scope?						YES
Purchased or originated credit impaired (POCI)?					NO		YES
Default trigger hit?				NO		YES
Lifetime PD significantly deteriorated?			NO		YES
Watch list Forbearance (but not impaired)		NO		YES
Days past due	0-30		>30

	Stage 1		Stage 2			Stage 3	Stage POCI


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Change in credit quality

The following figure shows the change in credit quality

of financial instruments since initial recognition. We use

quantitative and qualitative stage triggers to determine

whether a financial instrument should be classified as

stage 1 or stage 2. A transfer to stage 3 will always be

the result of the default of a financial instrument.


Change in credit quality since initial recognition

Stage 1	Stage 2	Stage 3
Performing (Initial recognition)	Credit quality deteriorated (Assets with significant increase in credit risk since initial recognition)	Default = Impaired (Credit impaired assets)
Recognition of ECL
12 month ECL	Lifetime ECL	Lifetime ECL
Interest income
Effective interest on gross carrying amount	Effective interest on gross carrying amount	Effective interest on amortised cost (gross carrying amount less loss allowance)

Calculation method for expected credit losses

ABN AMRO recognises loss allowances based on the

Expected Credit Loss (ECL) model of IFRS 9, which is

designed to be forward-looking. The amount of ECL is

based on the probability-weighted present value of all

expected cash shortfalls over the remaining life of the

financial instrument for both on- and off-balance sheet

exposures. ABN AMRO distinguishes between two types

of calculation methods for credit loss allowances:

• Individual lifetime ECL (LECL) for credit impaired

(stage 3) financial instruments with exposures above

EUR 5 million;

• Collective 12-month ECL (stage 1) and LECL (stage 2

and 3) for financial instruments that have similar

credit risk characteristics (e.g. residential mortgages,

consumer loans and SME loans); these are clustered

in portfolios and collectively assessed for impairment

losses. This applies to all financial instruments in

stage 1 and stage 2 and to stage 3 exposures below

EUR 5 million. ABN AMRO has models to quantify the

Probability of Loss (PL), Loss Given Loss (LGL) and

Exposure at Loss (EAL) for the purpose of calculating

the collective 12-month ECL and LECL for these

financial instruments.

Range of lifetime PD deterioration thresholds

The key quantitative metric that determines when a

financial instrument is transferred from stage 1 to

stage 2 is the deterioration in the lifetime probability of

default (LPD) from the date of origination to the

reporting date, based on internal data. If the LPD

deterioration of an exposure is above a predefined

threshold, the LPD is considered to be significantly

deteriorated.

The following table shows LPD deterioration thresholds

that triggered transfers to stage 2 as at

31 December 2025. The table provides ranges because

each product class uses multiple ECL models, and

thresholds are determined for each ECL model.


Product class	Range
Consumer lending	1.8x-4.0x
Residential mortgages	1.5x-2.1x
Corporate loans	1.3x-4.8x

Management overlays and other adjustments

Where necessary to reflect credit risk dynamics not

captured by our models, management judgement is

applied via a management overlay or other IFRS 9

adjustment. A management overlay is a temporary

adjustment in a loss allowance until a long-term

solution (e.g. model adjustment) is effective, and must

be an amount commensurate with the model limitation.

All overlays require a decision by the Impairment and

Provision Committee (IPC). The main types of

management overlays that ABN AMRO distinguishes

are: post-model adjustments (adjustments to model

outcomes), adjustments in the weightings of

macroeconomic scenarios and stage overrides. Other

adjustments, such as adjustments to model parameters

or input data, are not considered management overlays,

but follow the same internal approval process.


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Forbearance

Forbearance is the process of making concessions to

clients who are or will soon be experiencing financial

difficulty, with the intention of bringing them back

within their payment capacity. A forborne asset is any

contract that has been entered into with a counterparty

that is in or about to face financial difficulty, and that

has been refinanced or modified on terms and

conditions that we would not have accepted if the

counterparty had been financially healthy.

Forbearance measures can be applied to contracts on

which the counterparty has already defaulted, as well

as to contracts that are still performing. If the contract

is considered to be performing at the time the

forbearance measure is taken, an assessment is made

to determine whether the counterparty will be able to

meet the revised conditions of the contract and whether

full repayment of the credit facility is expected.

A forborne contract will cease to qualify as forborne

only when all the following conditions are met:

• The contract is considered performing;

• A minimum probation period of at least two years has

passed since the date of the last forbearance measure

or, if later, the date on which the forborne contract

was considered performing;

• Regular and timely payments of more than an

insignificant amount of principal or interest have been

made during at least half of the probation period;

• The counterparty does not have any contract, within

the credit agreement, that is more than 30 days past

due at the end of the probation period.

If the forborne contract is or has become non-

performing at the time of the forbearance measure,

a mandatory cure period of at least one year applies to

the contract before it is returned to performing status.

The cure period starts when the contract becomes

non-performing or, if the contract was already

non-performing, when the last forbearance measure

was taken.

Forbearance lifecycle

Audited


Non-forborne			Forborne				Non-forborne
		Defaulted forbearance clients remain defaulted for at least a year

Performing			Cure ≥ 1 year		Probation period ≥ 2 year		Ceases to be forborne

	Forbearance measure			End of cure period		End of forbearance period

Performing			Non-performing		Performing

Past due credit exposures

A financial asset is past due if a counterparty fails to

make a payment on the contractual due date or if the

counterparty has exceeded an agreed credit limit.

ABN AMRO starts counting days past due on the first

day that a counterparty is past due on any financial

obligation.

Credit impaired exposures

Financial assets classified under stage 3 are considered

credit impaired in accordance with IFRS 9. A transfer to

stage 3 will always be the result of the default of a

financial instrument. The definition of default for IFRS 9

is aligned with the regulatory capital definition.

A default is deemed to have occurred when the

counterparty is past due by more than 90 days on any

material financial credit obligation to the bank, or when

the bank considers the borrower to be unlikely to meet

its contractual obligations (unlikely to pay).


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Credit risk measurement

Audited

The models used for measuring and managing credit

risk vary from purely statistical to expert-based models

and employ both quantitative and qualitative risk

drivers. All models are subject to the bank’s model risk

management framework. They undergo initial validation

by the independent model validation function before

their first use, and are then monitored and validated

annually. Independent validation is also required when

a model is changed.

Probability of default

The probability of default (PD) indicates the likelihood

that a counterparty or exposure defaults within a one-

year time horizon. For the non-programme lending

portfolio, the model score is mapped to and expressed

as an internal uniform counterparty rating (UCR). The

UCR rating scale consists of 14 performing ratings, each

representing a fixed PD range. The indicative mapping

of the internal UCR rating scale to external rating

agency ratings is shown in the following table.

Internal rating scale mapped to external ratings


Grade Category	UCR (internal rating)	Low PD%	Mid PD%	High PD%	Standard & Poor's equivalent	Moody's equivalent	Fitch equivalent
Investment grade	UCR 1	0.000	0.03	0.035	AAA to A+	Aaa to Aa3	AAA to AA-
	UCR 2+	0.035	0.04	0.045	A+	A1	A+
	UCR 2	0.045	0.05	0.071	A	A2	A+ to A
	UCR 2-	0.071	0.10	0.127	A-	A3	A-
	UCR 3+	0.127	0.16	0.200	BBB+	Baa1	BBB+
	UCR 3	0.200	0.25	0.300	BBB	Baa2	BBB
	UCR 3-	0.300	0.36	0.465	BBB-	Baa3	BBB-
Sub-investment grade	UCR 4+	0.465	0.60	0.775	BB+	Ba1	BB+
	UCR 4	0.775	1.00	1.285	BB	Ba3	BB
	UCR 4-	1.285	1.65	2.225	BB-	B1	B+
	UCR 5+	2.225	3.00	4.243	B	B2	B
	UCR 5	4.243	6.00	8.485	B-	Caa	B-
	UCR 5-	8.485	12.00	16.971	CCC/C	Ca/C	CCC/C
	UCR 6+	16.971	24.00	100	CCC/C	Ca/C	CCC/C
Default	UCR 6-8		100		D	C-D	D

Loss given default

Loss given default (LGD) models estimate the amount

the bank would lose if the counterparty were to default.

LGD is expressed as a percentage of the outstanding

amount at default. For credit facilities that are not in

default, LGD estimates are influenced by the risk

mitigating techniques used by the bank (such as

collateral coverage and/or third-party protection), the

credit facility’s seniority and structure, and the bank’s

view on the creditor-friendliness of the relevant

country's legal framework.

Exposure at default

Exposure at default (EAD) models estimate the

expected exposure at the time a counterparty defaults.

If all or part of a facility is undrawn (i.e. the outstanding

amount is less than the approved limit) at the time of

the EAD calculation, a portion of the undrawn amount is

added to the exposure to reflect the tendency of

counterparties to utilise larger portions of their

approved credit facilities when nearing default. The

portion of the undrawn amount is determined by using

the applicable credit conversion factor (CCF). Under the

Basel IV standards/CRR III requirements, own estimates

of CCF are only allowed for undrawn revolving

commitments; for all other types of credit facilities,

regulatory prescribed CCF values are used.

Rating assignment

For non-programme lending, the ratings are individually

assigned to each obligor (PD) and facility (LGD) by the

business account manager (first line of defence) and

approved by Credit Risk (second line of defence). For

programme lending exposures, ratings are not assigned

individually, but assigned to pools with similar

characteristics on a monthly basis. For all exposures, the

EAD estimation is assigned automatically, based on the

facility type and the undrawn part of the facility.

Capital for credit risk

Regulatory capital

For the purpose of determining capital requirements for

credit risk, ABN AMRO applies the Advanced Internal

Ratings Based (A-IRB) approach to the mortgages

portfolio of ABN AMRO Hypotheken Groep B.V. Under

this approach, the previously described internal


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≡	Risk, funding & capital	Risk management	Credit risk management

estimates for PD, LGD and EAD are used to calculate

credit risk RWA. Additionally, ABN AMRO applies the

Foundation Internal Ratings Based (F-IRB) approach to

its exposures towards banks and financial companies.

Under this approach, internal estimates are used for the

PD parameter only, while for LGD and EAD the

regulatory prescribed values are used to calculate credit

risk RWA. According to the Basel IV/CRR III

requirements, under both A-IRB and F-IRB approaches,

estimated risk parameters are floored to the regulatory

prescribed levels. For the other portfolios, the

standardised approach (SA) is applied, meaning that

regulatory prescribed risk weights are used to

determine credit risk RWA. The PD, LGD and EAD

models are still used for the SA portfolios for internal

purposes, such as origination, pricing, monitoring and

reporting, internal capital calculation and the

calculation of credit risk adjustments.

Economic capital

The EC model for credit risk uses a Monte Carlo

simulation to determine a full portfolio loss distribution,

taking into account specific portfolio characteristics and

diversification effects. Loan facilities are valued on an

economic value (mark-to-market) basis to ensure that

loss estimates can be based not only on defaulting

borrowers, but also on possible credit migrations and

changes associated with the market values of loans.

Credit risk mitigation

Credit risk mitigation techniques are used by the bank

to reduce the credit risk associated with its credit

exposures. Such techniques relate mainly to collateral,

guarantees and credit insurance, netting of financial

assets and liabilities, and enforcing master netting

agreements or similar instruments.

Credit risk mitigation techniques have to meet certain

requirements so they can be used effectively and in line

with the bank’s risk appetite. For this reason, ABN AMRO

has established mandatory, bank-wide policies

governing the acceptance, management, monitoring

and reporting of credit risk mitigation techniques. These

are in line with regulatory requirements, as well as the

needs of the bank and its clients. These bank-wide

policies provide the rules that must be met by business-

specific procedures and processes to ensure the

effectiveness of credit risk mitigation.

Collateral management and guarantees

Collateral and guarantees represent assets or amounts

with material value that have been received by (or

pledged to) the bank to secure obligations under a

credit facility or other exposure. To be effective, such

security must give the bank the right to appropriate and

liquidate collateral and pursue the guarantors on time

and without impediment so that losses on the exposure

at the time a counterparty defaults are minimised.

In addition to minimising exposure to credit risk, eligible

collateral and guarantees can also reduce the

regulatory and economic capital the bank is required to

hold as a buffer for unexpected losses. The Capital

Requirements Regulation prescribes the criteria that

collateral and guarantees must meet to be considered

eligible for capital reduction. These criteria, which

provide for legal effectiveness and for the

enforceability, valuation and monitoring of collateral

and guarantees, are aimed at the effective and timely

realisation of collateral and guarantee amounts.

Residential mortgages, followed by commercial real

estate, represent the largest collateral category in our

books. We manage our collateral risk through lending

criteria such as loan to value, and for commercial real

estate financing we apply a minimum energy label.


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Credit risk review



	This section provides information on: • Credit risk exposure • Credit risk concentration • Forborne, past due and credit-impaired loans • Credit risk mitigation • Developments in specific portfolios

Credit risk exposure

We measure our credit risk exposure in two ways,

depending on the purpose for which the exposure is

calculated: EU IFRS or the determination of regulatory

or economic capital (CRD V/CRR III). This section

shows our exposure to credit risk according to both

frameworks and provides further details on

risk‑weighted assets and credit quality.

Credit risk overview

Audited


(in millions)	31 December 2025		31 December 2024
Cash and balances at central banks		49,486		44,464
Financial assets held for trading		2,044		2,503
Derivatives		3,933		4,347
Financial investments¹		50,231		47,173
Securities financing		40,173		26,989
Loans and advances banks		2,170		2,049
Loans and advances customers		255,760		248,782
Other assets	4,993		5,518
Less: Other¹	564		342
Other assets		4,429		5,176
On-balance sheet maximum exposure to credit risk		408,228		381,484
Off-balance sheet
Committed credit facilities	55,240		52,617
Guarantees and other commitments	6,609		6,638
Revocable credit facilities	36,983		38,093
Off-balance sheet credit facilities and guarantees		98,832		97,348
Maximum exposure to credit risk²		507,059		478,831
Adjustments on assets ^{2, 3}		4,242		1,996
Valuation adjustments ⁴		-4,194		5,664
Offsetting and netting		-45,368		-33,229
Off-balance sheet credit facilities and guarantees		-98,832		-97,348
Off-balance sheet exposure fraction expected to be drawn prior to default (credit conversion factors)		33,223		34,091
Total Exposure at Default ⁵		396,130		390,006
Credit risk RWA / Total Exposure at Default ⁵		29.3%		31.5%
1. This contains non-credit obligation assets and assets on accounts which are out of scope for credit risk.
2. Adjustment on assets includes equity positions.
3. Main adjustments on assets relate to selected financial assets held for trading and fair value adjustments from hedge accounting.
4. Adjustments on valuation include loan impairment allowances.
5. As of 1 January 2025, the figures in the table are prepared in accordance with CRR III (Basel IV) regulations. The figures up to 31 December 2024 were prepared in accordance with CRR II (Basel III) regulations.

The above table shows the maximum exposure to credit

risk and the reconciliation with the total exposure at

default. Exposure at default is predominantly used for

the determination of regulatory and economic capital.

Following the transition to Basel IV as from

1 January 2025 and the migration of portfolios to the

Standardised Approach in Q3 2025, we reviewed

certain tables in the Credit risk review section and

Additional risk, funding & capital disclosures sections.

This has led to changes in the presentation of

‘Overall credit risk EAD and RWA’ and ‘Geographic

concentration by EAD’. Comparative figures for 2024

have been updated accordingly. In addition, we

removed ‘Credit quality by exposure class’ and ‘IRB

approach: credit quality by exposure class’, given their

limited remaining added value due to the migration of

certain portfolios to the Standardised Approach.


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Overall credit risk EAD and RWA



x	Audited


							31 December 2025
	Original EAD	Less: Netting/ EAD mitigation³	EAD	- of which			RWA	RWA/EAD
(in millions)				Derivatives	Securities financing transactions
Credit risk IRB
Institutions¹	10,192	1,082	9,110	746	1,704		1,247	13.7%
Corporates	1,802	121	1,680	348	941		520	31.0%
Retail	169,226	32,019	137,207				15,166	11.1%
- of which secured by immovable property	169,194	32,015	137,178				15,158	11.0%
- of which qualifying revolving exposures
- of which other retail	33	4	29				8	27.3%
Subtotal	181,220	33,223	147,997	1,094	2,645		16,933	11.4%
Equities not held for trading	1,151		1,151				3,265	283.7%
Total credit risk IRB	182,371	33,223	149,148	1,094	2,645		20,198	13.5%
Credit risk SA
Central governments and central banks	86,422	-34,165	120,587	36	198		357	0.3%
Institutions¹	30,286	17,564	12,722	3,855	2,973		1,915	15.1%
Corporates	100,417	43,948	56,469	3,181	1,165		49,510	87.7%
Retail	12,919	8,096	4,823				3,554	73.7%
Covered bonds	924		924				95	10.3%
Secured by mortgages on immovable property	44,139	6,870	37,268				25,436	68.3%
Exposures in default	4,609	2,072	2,537	34			3,145	124.0%
Collective investments undertakings (CIU)	347	100	248				550	222.1%
Other²	2,984	235	2,749				1,968	71.6%
Total credit risk SA	283,048	44,720	238,328	7,107	4,337		86,532	36.3%
Risk exposure amount for contributions to the default fund of a CCP	2,068		2,068				797	38.6%
Securitisation positions	6,511	1,309	5,202				689	13.2%
Credit valuation adjustment	1,385		1,385				186	13.4%
Other risk exposure amounts							7,750
Total credit risk	475,383	79,252	396,130	8,201	6,982	—	116,153	29.3%
1. Institutions include exposures to banks and investment undertakings, regional governments and local authorities, and pension funds.
2. Other includes claims on institutions and corporates with a short-term credit assessment under the Standardised Approach and subordinated debt exposures under the Standardised Approach.
3. Consists mainly of netting, secured funding trades, guarantees, credit conversion factors and impairments under the Standardised Approach.


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						31 December 2024
	Original EAD	Less: Netting/ EAD mitigation³	EAD	- of which		RWA	RWA/EAD
(in millions)				Derivatives	Securities financing transactions
Credit risk IRB
Institutions¹	10,820	1,187	9,633	810	2,055	1,624	16.9%
Corporates	128,991	29,003	99,988	1,964	1,556	58,499	58.5%
Retail	172,472	4,712	167,760			18,495	11.0%
- of which secured by immovable property	164,118	571	163,547			17,369	10.6%
- of which qualifying revolving exposures	5,354	3,746	1,608			153	9.5%
- of which other retail	3,000	396	2,604			973	37.4%
Subtotal	312,282	34,902	277,380	2,774	3,611	78,618	28.3%
Equities not held for trading	1,100		1,100			3,423	311.3%
Other²	2,123		2,123			1,568	73.9%
Total credit risk IRB	315,505	34,902	280,603	2,774	3,611	83,609	29.8%
Credit risk SA
Central governments and central banks	79,926	-1,833	81,759	37	136	675	0.8%
Institutions¹	28,434	14,104	14,330	3,750	4,252	1,149	8.0%
Corporates	21,817	15,473	6,344	1,109	1,166	5,226	82.4%
Retail	5,472	2,302	3,170			2,377	75.0%
Secured by mortgages on immovable property	598	12	587			209	35.7%
Exposures in default	330	172	158			213	134.6%
Collective investments undertakings (CIU)	36		36			19	54.8%
Other²	152		152			110	72.7%
Total credit risk SA	136,763	30,229	106,534	4,896	5,554	9,978	9.4%
Risk exposure amount for contributions to the default fund of a CCP						716
Securitisation positions	2,869		2,869			371	12.9%
Credit valuation adjustment						122
Other risk exposure amounts						27,982
Total credit risk	455,137	65,131	390,006	7,670	9,165	122,779	31.5%
1. Institutions include exposures to banks and investment undertakings, regional governments and local authorities, and pension funds.
2. Other includes claims on institutions and corporates with a short-term credit assessment under the Standardised Approach and subordinated debt exposures under the Standardised Approach.
3. Consists mainly of netting, secured funding trades, guarantees, credit conversion factors and impairments under the Standardised Approach.

As of 1 January 2025, we report our risk exposures in

line with Capital Requirements Regulation (CRR) III.

Comparative figures for 31 December 2024 are

reported under CRR II.

EAD increased to EUR 396.1 billion

(31 December 2024: EUR 390.0 billion), largely as a

result of the increase in loans and advances, which was

partly offset by a higher fair value adjustment from

hedge accounting on residential mortgages.

Total RWA decreased to EUR 135.4 billion

(31 December 2024: 140.9 billion), driven by a

significant decrease in credit risk RWA of

EUR 6.6 billion. Credit risk RWA mainly decreased

due to RWA optimisation initiatives, including

methodological enhancements and data quality

improvements, and the wind-down of the Asset Based

Finance portfolios. Risk transfers also

contributed to the decrease. The decrease in credit risk

RWA was partly offset by the transition of certain

portfolios to the Standardised Approach and the

acquisition of HAL. Market risk RWA decreased by

EUR 0.5 billion over the year due to position changes.

CVA risk RWA (counterparty credit risk) increased by

EUR 0.1 billion over the year. Operational risk RWA

increased by EUR 1.7 billion compared with 2024. This

RWA increase can be attributed to the bank’s income

growth in the past few years, which forms the basis for

the RWA calculation, and to the inclusion of HAL in

Q3 2025. In keeping with the CRR III regulations

regarding the operational risk framework, the three‑year

period used for the calculations is based on full

calendar years, with updates occurring in the fourth

quarter. Accordingly, the Q4 2025 operational risk own

funds requirements are based on financial figures from

the period 2023-2025.


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Credit quality by internal rating scale mapped

to stages

Audited

The following table presents the gross carrying amount

of loans and the contractual amount of undrawn loan

commitments, classified by internal rating and risk

stage. In order to classify a client as stage 2, several

qualitative triggers are needed, which are not

necessarily dependent on internal ratings. Reference is

made to the Credit risk management section for more

information on internal ratings and stage determination.

The largest part of ABN AMRO's portfolio continues to

be classified in the highest and medium internal ratings

of stage 1. Stage 2 clients are mostly classified in the

medium internal UCRs, and mostly comprise corporate

loans and mortgage loans. Compared with 2024, the

share of the portfolio with an investment grade (UCR 1

to UCR 3 bucket) increased slightly, mainly due to

relatively higher investment grades in corporate loans,

which are the result of overall improved client ratings,

and in consumer loans, largely due to the

reclassification of loan portfolios of our subsidiary Alfam

to assets held for sale. Approximately 1.5% of the

bank's portfolio is reported in UCR 6+. This decline

compared with 2024 is mainly attributable to an

internal focus on reducing overdue revisions. In cases

where revision of the UCR is overdue, clients are

classified as UCR 6+ until a new rating is available.

During that time, the mid-PD of UCR 6+ is used for

capital calculation purposes.


					31 December 2025				31 December 2024
(in millions)	PD scale	UCR range	Stage 1	Stage 2	Stage 3³	Total³	Stage 1	Stage 2	Stage 3³	Total³
Residential mortgages
	0.000 - < 0.035	1	69	5		74	73	4		77
	0.035 - < 0.127	2	52,712	719		53,431	51,759	788		52,547
	0.127 - < 0.465	3	70,016	4,896		74,912	65,597	4,976		70,573
	0.465 - < 2.225	4	22,681	5,079		27,761	20,300	5,299		25,599
	2.225 - < 16.971	5	406	3,677		4,083	420	4,383		4,803
	16.971 - < 100	6+	21	952		972	23	667		690
	100	6-8			1,952	1,952			1,919	1,919
Total residential mortgages			145,906	15,327	1,952	163,185	138,172	16,118	1,919	156,209
Consumer loans
	0.000 - < 0.035	1	645	18		662	748	24		772
	0.035 - < 0.127	2	753	8		760	651	8		659
	0.127 - < 0.465	3	2,297	92		2,389	2,033	75		2,108
	0.465 - < 2.225	4	1,855	155		2,009	2,469	114		2,582
	2.225 - < 16.971	5	77	74		151	451	174		625
	16.971 - < 100	6+	47	17		64	431	90		521
	100	6-8			152	152			222	222
	No rating		76	2		78	83	2		85
Total consumer loans			5,749	364	152	6,266	6,866	487	222	7,575
Corporate loans
	0.000 - < 0.035	1	4,906	89		4,995	4,736	107		4,842
	0.035 - < 0.127	2	8,185	24		8,210	7,580	47		7,627
	0.127 - < 0.465	3	19,678	378		20,056	18,738	779		19,517
	0.465 - < 2.225	4	28,321	3,768		32,089	26,378	4,343		30,721
	2.225 - < 16.971	5	2,356	1,966		4,323	1,885	2,502		4,387
	16.971 - < 100	6+	2,562	873		3,435	3,948	614		4,562
	100	6-8			3,309	3,309			3,110	3,110
	No rating		10,048	53		10,101	8,962	98		9,060
Total corporate loans			76,056	7,151	3,309	86,516	72,227	8,490	3,110	83,827
Other loans
	0.000 - < 0.035	1	5,893			5,893	10,332	37		10,369
	0.035 - < 0.127	2	16,474	3		16,476	8,345			8,345
	0.127 - < 0.465	3	3,080	1		3,081	5,394			5,394
	0.465 - < 2.225	4	2,609			2,609	2,252			2,252
	2.225 - < 16.971	5					82			82
	16.971 - < 100	6+	7	2		9	423	1		424
	100	6-8			4	4			6	6
	No rating		20,174	38		20,212	8,654	4		8,658
Total other loans¹			48,236	43	4	48,283	35,483	42	6	35,531


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					31 December 2025				31 December 2024
(in millions)	PD scale	UCR range	Stage 1	Stage 2	Stage 3³	Total³	Stage 1	Stage 2	Stage 3³	Total³
Loan commitments and financial guarantee contracts
	0.000 - < 0.035	1	7,096	5		7,101	4,737			4,737
	0.035 - < 0.127	2	15,848	36		15,884	15,308	60		15,368
	0.127 - < 0.465	3	16,964	373		17,337	16,096	773		16,869
	0.465 - < 2.225	4	11,795	2,016		13,811	12,385	1,516		13,901
	2.225 - < 16.971	5	1,222	737		1,959	1,269	801		2,071
	16.971 - < 100	6+	690	142		832	1,282	140		1,422
	100	6-8			610	610			627	627
	No rating		511	6		517	336	4		340
Total loan commitments and financial guarantee contracts²			54,127	3,316	610	58,052	51,414	3,293	627	55,334
Total
	0.000 - < 0.035	1	18,609	117		18,725	20,625	172		20,797
	0.035 - < 0.127	2	93,972	789		94,761	83,644	902		84,546
	0.127 - < 0.465	3	112,035	5,740		117,775	107,858	6,603		114,461
	0.465 - < 2.225	4	67,261	11,017		78,279	63,784	11,272		75,056
	2.225 - < 16.971	5	4,062	6,454		10,516	4,107	7,861		11,968
	16.971 - < 100	6+	3,327	1,986		5,313	6,108	1,511		7,619
	100	6-8			6,026	6,026			5,885	5,885
	No rating		30,809	99		30,908	18,035	108		18,143
Total			330,075	26,201	6,026	362,302	304,162	28,430	5,885	338,476
1. Including Banks, Securities Financing and Government and official institutions.
2. Excluding performance letters of credit.
3. Including POCI.

Credit risk concentration

Audited

Geographic concentration

The exposures in the following table have been

classified on the basis of the geographical regions in

which clients are domiciled. The bank actively manages

and monitors the development of its country risk

exposures, based on the country at risk. The country at

risk may be different from the country of domicile, for

example if the bank finances a project in a country other

than the borrower’s country of incorporation.

Geographic concentration by EAD

Audited


					31 December 2025
(in millions, Exposure at Default)	The Netherlands	Rest of Europe	USA	Asia	Rest of the world	Total
Institutions¹	903	7,067	619	84	436	9,110
Corporates	54	1,256	213	152	4	1,680
Retail	137,059	123	9	14	2	137,207
- of which secured by immovable property	137,031	122	9	14	2	137,178
- of which qualifying revolving exposures
- of which other retail	28	1				29
Total IRB²	138,016	8,446	842	250	442	147,997
Central governments and central banks	76,944	30,651	8,323	4,246	422	120,587
Institutions¹	2,451	8,086	1,056	83	1,046	12,722
Corporates	21,633	28,592	1,309	767	4,169	56,469
Retail	4,568	246	1	6	3	4,823
Secured by mortgages on immovable property	31,729	5,516	11	10	1	37,268
Other	3,911	2,400	80	29	38	6,458
Total SA³	141,237	75,490	10,779	5,141	5,680	238,328
Total IRB and SA ^{2, 3}	279,253	83,937	11,621	5,391	6,123	386,325
Percentage of total IRB and SA ^{2, 3}	72.3%	21.7%	3.0%	1.4%	1.6%	100.0%
1. Institutions include exposures to banks and investment undertakings, regional governments and local authorities, and pension funds.
2. Total Exposure at Default does not include EAD calculated for equities not held for trading and other non-credit obligations.
3. Exposure at Default does not include EAD calculated for other non-credit obligations.


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					31 December 2024
	The Netherlands	Rest of Europe	USA	Asia	Rest of the world	Total
Institutions¹	1,158	6,977	817	141	540	9,633
Corporates	56,516	36,792	1,359	489	4,832	99,988
Retail	167,270	341	53	66	29	167,760
- of which secured by immovable property	163,087	315	52	65	28	163,547
- of which qualifying revolving exposures	1,581	23	1	1	1	1,608
- of which other retail	2,601	3				2,604
Total IRB²	224,944	44,110	2,229	697	5,401	277,380
Central governments and central banks	47,653	22,035	7,895	4,071	105	81,759
Institutions¹	3,095	7,080	1,892	583	1,680	14,330
Corporates	3,351	1,514	838	434	207	6,344
Retail	3,083	81	2	3	2	3,170
Other	709	66			5	780
Total SA³	57,890	30,777	10,626	5,091	1,999	106,383
Total IRB and SA ^{2, 3}	282,834	74,887	12,855	5,787	7,400	383,763
Percentage of total IRB and SA ^{2, 3}	73.7%	19.5%	3.3%	1.5%	1.9%	100.0%
1. Institutions include exposures to banks and investment undertakings, regional governments and local authorities, and pension funds.
2. Total Exposure at Default does not include EAD calculated for equities not held for trading and other non-credit obligations.
3. Exposure at Default does not include EAD calculated for other non-credit obligations.

Our exposure in the Netherlands decreased to 72.3% of

the bank’s portfolio as at 31 December 2025

(31 December 2024: 73.7%). Our exposure to clients in

the rest of Europe increased from 19.5% to 21.7%.

These clients were primarily located in neighbouring

countries, such as Belgium, France and Germany, and

our exposure in Germany increased due to the

acquisition of HAL. Our exposure to countries outside

Europe decreased slightly. Exposures in Asia and to the

USA were mainly related to treasury and clearing

activities.


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Industry concentration

Audited


	31 December 2025		31 December 2024
(in millions)	Gross carrying amount ^{4, 5}	Percentage of total	Gross carrying amount ^{4, 5}	Percentage of total
Loans and advances banks	2,174	0.8%	2,053	0.8%
Agriculture, forestry and fishing	6,574	2.5%	6,659	2.6%
Mining and quarrying	1,499	0.6%	1,576	0.6%
Manufacturing	5,448	2.1%	6,565	2.6%
Electricity, gas, steam and air conditioning supply	2,661	1.0%	2,241	0.9%
Water supply; sewerage, waste management and remediation activities	611	0.2%	664	0.3%
Construction	3,077	1.2%	2,952	1.2%
Wholesale and retail trade; repair of motor vehicles and motorcycles	7,712	2.9%	7,975	3.1%
Transport and storage	7,908	3.0%	8,749	3.4%
Real estate activities	13,189	5.0%	11,052	4.3%
Accommodation and food service activities	1,909	0.7%	1,733	0.7%
Information and communication	5,532	2.1%	4,851	1.9%
Financial and insurance activities¹	19,166	7.3%	17,890	7.0%
Professional, scientific & technical activities	2,464	0.9%	2,024	0.8%
Administrative & support service activities	5,074	1.9%	5,358	2.1%
Human health services & social work activities	2,636	1.0%	2,630	1.0%
Other sectors²	1,057	0.4%	909	0.4%
Total corporate loans	86,516	32.8%	83,827	32.7%
Private individuals (residential mortgages and consumer loans)	169,450	64.2%	163,783	63.9%
Other loans³	5,936	2.2%	6,489	2.5%
Total non-industry classification	175,386	66.4%	170,273	66.5%
Total loans and advances customers	261,902	99.2%	254,100	99.2%
Total loans and advances	264,077	100%	256,153	100%
1. Financial and insurance activities include asset managers, credit card companies and providers of personal financial services and securities and brokers. The direct exposure to private credit funds is limited to approximately EUR 0.2 billion as at 31 December 2025.
2. Other include loans to Public administration & defence, compulsory social security, Education, Arts, entertainment & recreation, Activities of households as employers, Activities of extraterritorial organisations & bodies and Other services.
3. Other loans include loans to Government and official institutions and default fund contributions for our clearing clients.
4. Excluding loans at fair value through P&L.
5. Excluding fair value adjustments from hedge accounting.

Compared with 2024, the total corporate loan portfolio

grew by EUR 2.7 billion. As a result, the share of

corporate loans in total loans and advances to

customers increased marginally to 32.8% (2024:

32.7%). Portfolio composition by industry remained

stable. The top five industries in terms of exposures

were in the financial sector, followed by real estate,

transport and storage, wholesale and retail trade and

agriculture, which was the same as in 2024.

The table shows the industry in which the original

obligor, i.e. the counterparty with which ABN AMRO has

the contractual relationship, has its main activity. In the

exposure table, non-material industry clusters are

aggregated under Other. Industry concentration limits

are established within the bank’s risk appetite, with the

thresholds for concentrations being based on relative

risk, the importance of the industry to the Dutch

economy and expert opinion.

Management of forborne, past due and

credit impaired loans

Audited

Credit risk reporting scope

Although all financial assets on our balance sheet are

subject to some form of credit risk, by far the largest

part is in loans and advances. To provide a meaningful

view of the credit risk in our lending book, the figures

presented in this section therefore relate to loans and

advances. Any credit risk outside the reported scope are

mentioned in the notes below the table. All figures are

reported gross of loan impairment allowances and

exclude fair value adjustments. The following table

provides a comparison between the gross carrying

amounts presented in this section and the consolidated

balance sheet.


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Total loans and advances customers

Audited


				31 December 2025					31 December 2024
(in millions)	Gross carrying amount³	Fair value adjustment from hedge accounting	Less: loan impairment allowance	Less: amortisation and depreciation	Carrying amount	Gross carrying amount³	Fair value adjustment from hedge accounting	Less: loan impairment allowance	Less: amortisation and depreciation	Carrying amount
Loans and advances banks	2,174		4		2,170	2,053		4		2,049
Residential mortgages	163,185	-5,477	120		157,588	156,209	-4,686	133		151,390
Consumer loans¹	6,266		74		6,192	7,575		130		7,445
Corporate loans¹	86,516	42	1,026		85,532	83,827	102	1,100		82,829
Other loans and advances customers¹	5,936	1	1		5,935	6,489		2		6,487
Total loans and advances customers¹	261,902	-5,434	1,222		255,247	254,100	-4,584	1,364		248,152
Total loans and advances¹	264,077	-5,434	1,226		257,417	256,153	-4,584	1,368		250,201
Other	159,605	-1,588	124	2,100	155,793	138,184	-981	133	2,224	134,845
Total assets	423,681	-7,021	1,350	2,100	413,210	394,336	-5,565	1,501	2,224	385,047

Loans and advances customers¹	261,902	-5,434	1,222		255,247	254,100	-4,584	1,364		248,152
Consumer loans at fair value through P&L²	486				486	600				600
Corporate loans at fair value through P&L	28				28	30				30
Total loans and advances customers	262,416	-5,434	1,222		255,760	254,730	-4,584	1,364		248,782
1. Excluding loans at fair value through P&L.
2. As a result of the implementation of IFRS 17 Insurance contracts, residential mortgages with an insurance feature and consumer loans with a death waiver have to be recorded at fair value through profit and loss.
3. Excluding fair value adjustments from hedge accounting.

Fair value adjustments from hedge accounting for

residential mortgages and corporate loans resulted

from entering into interest rate swaps to hedge

fixed‑rate assets against changes in market interest

rates. The fair value adjustment for mortgages

increased as a result of higher market interest rates.

Forborne exposures

Clients in (or potentially in) financial difficulty and

whose contracts have been amended in ways that are

regarded as concessions on the part of the bank are

accounted for as forborne assets. The following table

provides an overview of forborne assets, broken down

into performing and non-performing assets, and

classified by the type of forbearance measure.

Overview of forborne assets

Audited


									31 December 2025
	Gross carrying amount²	Performing assets			Total per- forming forborne assets	Non-performing assets			Total non-per- forming forborne assets	Total forborne assets	For- bear- ance ratio
(in millions)	Gross carrying amount²	Tem- porary modifi- cation	Perma- nent modifi- cation	Refi- nancing	Total per- forming forborne assets	Tem- porary modifi- cation	Perma- nent modifi- cation	Refi- nancing	Total non-per- forming forborne assets	Total forborne assets	For- bear- ance ratio
Loans and advances banks	2,174										0.0%
Residential mortgages	163,185	459	12		471	500	6	1	507	979	0.6%
Consumer loans¹	6,266	7	24	5	37	20	7	15	42	78	1.2%
Corporate loans¹	86,516	664	1,247	190	2,101	122	1,372	108	1,602	3,703	4.3%
Other loans and advances customers¹	5,936			2	2					2	0.0%
Total loans and advances customers¹	261,902	1,130	1,283	197	2,611	641	1,385	124	2,150	4,762	1.8%
Total loans and advances¹	264,077	1,130	1,283	197	2,611	641	1,385	124	2,150	4,762	1.8%
Loans at FV through P&L	514	1			1					2	0.3%
Total loans and advances	264,590	1,132	1,283	197	2,612	642	1,385	124	2,151	4,763	1.8%
1. Excluding loans at fair value through P&L.
2. Excluding fair value adjustments from hedge accounting.


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									31 December 2024
	Gross carrying amount²	Performing assets			Total per- forming forborne assets	Non-performing assets			Total non-per- forming forborne assets	Total forborne assets	For- bear- ance ratio
(in millions)	Gross carrying amount²	Tem- porary modifi- cation	Perma- nent modifi- cation	Refi- nancing	Total per- forming forborne assets	Tem- porary modifi- cation	Perma- nent modifi- cation	Refi- nancing	Total non-per- forming forborne assets	Total forborne assets	For- bear- ance ratio
Loans and advances banks	2,053										0.0%
Residential mortgages	156,209	513	10		523	508	14		521	1,045	0.7%
Consumer loans¹	7,575	20	45	3	68	9	25	12	46	114	1.5%
Corporate loans¹	83,827	660	1,336	210	2,207	175	1,387	163	1,725	3,932	4.7%
Other loans and advances customers¹	6,489							1	1	1	0.0%
Total loans and advances customers¹	254,100	1,193	1,391	214	2,798	692	1,426	177	2,294	5,092	2.0%
Total loans and advances¹	256,153	1,193	1,391	214	2,798	692	1,426	177	2,294	5,092	2.0%
Loans at FV through P&L	630	1			2	6	1		6	8	1.3%
Total loans and advances	256,783	1,194	1,392	214	2,799	698	1,426	177	2,301	5,100	2.0%
1. Excluding loans at fair value through P&L.
2. Excluding fair value adjustments from hedge accounting.

The forbearance ratio improved to 1.8%

(31 December 2024: 2.0%). The forborne exposure

decreased to EUR 4.8 billion (Q4 2024: EUR 5.1 billion),

mainly because permanent forbearance measures

relating to some corporate loans ended. Approximately

37% of the forborne exposure is now subject to a

temporary measure.

Past due not classified as stage 3

Audited


						31 December 2025
			Days past due
(in millions)	Gross carrying amount²	Assets not classified as stage 3 or POCI	≤ 30 days	> 30 days & ≤ 90 days	> 90 days³	Total past due, but not stage 3 or POCI	Past due ratio
Loans and advances banks	2,174	2,174					0.0%
Residential mortgages	163,185	161,233	833	57	45	935	0.6%
Consumer loans¹	6,266	6,114	368	14	4	386	6.2%
Corporate loans¹	86,516	83,207	581	47	5	633	0.7%
Other loans and advances customers¹	5,936	5,932					0.0%
Total loans and advances customers¹	261,902	256,486	1,782	117	54	1,953	0.7%
Total loans and advances¹	264,077	258,660	1,782	117	54	1,953	0.7%
1. Excluding loans at fair value through P&L.
2. Excluding fair value adjustments from hedge accounting.
3. Materiality thresholds are applied for counterparties transferring to stage 3. Below these thresholds, amounts are reported on > 90 days past due.


						31 December 2024
			Days past due
(in millions)	Gross carrying amount²	Assets not classified as stage 3 or POCI	≤ 30 days	> 30 days & ≤ 90 days	> 90 days³	Total past due, but not stage 3 or POCI	Past due ratio
Loans and advances banks	2,053	2,053					0.0%
Residential mortgages	156,209	154,290	1,195	26	3	1,224	0.8%
Consumer loans¹	7,575	7,353	356	16	20	392	5.2%
Corporate loans¹	83,827	80,717	570	200	2	772	0.9%
Other loans and advances customers¹	6,489	6,483					0.0%
Total loans and advances customers¹	254,100	248,842	2,122	242	25	2,389	0.9%
Total loans and advances¹	256,153	250,895	2,122	242	25	2,389	0.9%
1. Excluding loans at fair value through P&L.
2. Excluding fair value adjustments from hedge accounting.
3. Materiality thresholds are applied for counterparties transferring to stage 3. Below these thresholds, amounts are reported on > 90 days past due.


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Past due exposures

When a counterparty is past due or exceeds its credit

limit, all loans and advances (total gross carrying

amount) in the related credit arrangement are

considered to be past due. The absolute and relative

materiality thresholds used for determining a defaulted

status do not apply for the purposes of classification as

past due. Below these thresholds, arrears of more than

90 days are reported as past due.

Total arrears fell EUR 0.4 billion to EUR 2.0 billion, or

0.7%, compared with 31 December 2024. In Q4 2025,

we made further progress in aligning the past due

reporting over the different segments, which led to an

increase in the >30 days buckets and a decrease in the

<=30 days buckets for residential mortgages.

Furthermore, a EUR 0.2 billion decline in loans in arrears

was observed in the medium term bucket of the

corporate loans category.

Coverage and stage ratios

Audited


			31 December 2025				31 December 2024
(in millions)	Gross carrying amount²	Allowances for credit losses³	Coverage ratio	Stage ratio	Gross carrying amount²	Allowances for credit losses³	Coverage ratio	Stage ratio
Stage 1
Loans and advances banks	2,137	4	0.2%	98.3%	2,016	4	0.2%	98.2%
Residential mortgages	145,906	29	0.0%	89.4%	138,172	36	0.0%	88.5%
Consumer loans¹	5,749	8	0.1%	91.8%	6,866	12	0.2%	90.6%
Corporate loans¹	76,056	109	0.1%	87.9%	72,227	119	0.2%	86.2%
Other loans and advances customers¹	5,926		0.0%	99.8%	6,478		0.0%	99.8%
Total loans and advances customers¹	233,637	146	0.1%	89.2%	223,743	167	0.1%	88.1%
Stage 2
Loans and advances banks	37		0.0%	1.7%	37		0.0%	1.8%
Residential mortgages	15,327	39	0.3%	9.4%	16,118	42	0.3%	10.3%
Consumer loans¹	364	5	1.5%	5.8%	487	15	3.1%	6.4%
Corporate loans¹	7,151	96	1.3%	8.3%	8,490	170	2.0%	10.1%
Other loans and advances customers¹	6		0.4%	0.1%	5		1.1%	0.1%
Total loans and advances customers¹	22,848	141	0.6%	8.7%	25,100	226	0.9%	9.9%
Stage 3 and POCI
Loans and advances banks
Residential mortgages	1,952	52	2.7%	1.2%	1,919	55	2.9%	1.2%
Consumer loans¹	152	61	40.1%	2.4%	222	102	46.1%	2.9%
Corporate loans¹	3,309	821	24.8%	3.8%	3,110	811	26.1%	3.7%
Other loans and advances customers¹	4	1	32.8%	0.1%	6	2	27.1%	0.1%
Total loans and advances customers¹	5,417	935	17.3%	2.1%	5,258	971	18.5%	2.1%
Total of stages 1, 2, 3 and POCI
Total loans and advances banks	2,174	4	0.2%		2,053	4	0.2%
Residential mortgages	163,185	120	0.1%		156,209	133	0.1%
Consumer loans¹	6,266	74	1.2%		7,575	130	1.7%
Corporate loans¹	86,516	1,026	1.2%		83,827	1,100	1.3%
Other loans and advances customers¹	5,936	1	0.0%		6,489	2	0.0%
Total loans and advances customers¹	261,902	1,222	0.5%		254,100	1,364	0.5%
Total loans and advances¹	264,077	1,226	0.5%		256,153	1,368	0.5%
1. Excluding loans at fair value through P&L.
2. Gross carrying amount excludes fair value adjustments from hedge accounting.
3. The allowances for credit losses excludes allowances for financial investments held at FVOCI (31 December 2025: EUR 1 million; 31 December 2024: EUR 1 million).

Overall portfolio developments in combination with

lower allowances for credit losses at Corporate Banking

resulted in a decrease in the stage 2 ratio and

the stage 2 coverage ratio. The stage 3 ratio remained

stable, while the stage 3 coverage ratio showed a

decline as a result of portfolio developments in the

corporate and consumer loan portfolios.

For residential mortgages, the stage 2 ratio fell to 9.4%

(Q4 2025: 10.3%) due to the growth of the total

portfolio and stage shifts. The coverage ratio for stage 3

was down slightly at 2.7% (Q4 2025: 2.9%), mainly as a

result of a reduction in modelled impairments.


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Purchased or Originated Credit Impaired (POCI)

As at 31 December 2025, loans classified as POCI

amounted to EUR 84 million. The increase in POCI

compared with 31 December 2024 is due to the

acquisition of HAL. Due to the immateriality of this

amount, it has been included in the amount shown for

stage 3 throughout this report.

Exposure and impairment flows

This section provides more details on the exposure and

impairment flows underlying the change in coverage

and stage ratios shown in the previous section.

Total loans and advances

Audited


				2025				2024
(in millions)	Stage 1¹	Stage 2¹	Stage 3 ^{1, 2}	Total ^{1, 2}	Stage 1¹	Stage 2¹	Stage 3 ^{1, 2}	Total ^{1, 2}
Balance as at 1 January	225,759	25,136	5,258	256,153	228,418	21,940	4,707	255,066
Transfer to stage 1	5,574	-5,407	-167		8,704	-8,644	-59
Transfer to stage 2	-7,724	8,341	-617		-15,361	16,025	-664
Transfer to stage 3	-1,285	-1,214	2,499		-1,468	-1,186	2,654
Additional drawdowns and partial repayments	-18,760	-1,315	-590	-20,665	-16,518	1,265	-142	-15,394
Originated or purchased	52,982	49	81	53,112	42,922			42,922
Matured or repaid	-16,671	-2,433	-734	-19,837	-20,472	-4,170	-876	-25,518
Write-offs			-237	-237			-350	-350
Foreign exchange	-1,884	-62	-15	-1,961	1,017	50	21	1,088
Other movements	-2,217	-211	-61	-2,488	-1,483	-144	-34	-1,660
Balance as at 31 December	235,775	22,885	5,417	264,077	225,759	25,136	5,258	256,153
1. Excluding fair value adjustments from hedge accounting.
2. Including POCI.

Total loans and advances increased compared with

31 December 2024. This was mainly due to an increase

in mortgages and corporate loans, which was partly

offset by a decrease in consumer loans. Compared with

2024, there was a significant increase in total loans and

advances ‘originated or purchased’, which was due in

part to the acquisition of HAL.

There was a decrease in other movements in 2025,

which was primarily the result of consumer loan

portfolios of Alfam, and mortgages loans, being

reclassified to assets held for sale. Exposure flows per

product class are presented in the Additional risk,

funding & capital disclosures section.

Loan impairment charges and allowances

Audited


(in millions)	Banks	Residential mortgages	Consumer loans	Corporate loans	Other loans	Total loans and advances	Off-balance
Balance as at 31 December 2024	4	133	130	1,100	2	1,368	97
Transfer to stage 1		-3	-3	-3		-8	-1
Transfer to stage 2		5		3		8	2
Transfer to stage 3		8	32	83		123
Remeasurements¹		-14	-12	-33	-1	-59	-15
Changes in models			1	73		75	-1
Changes in risk parameters		-1	1	-3		-3	6
Originated or purchased		6	3	36		45	5
Matured or repaid		-12	-5	-59		-75	-6
Impairment charges (releases) on loans and advances		-10	18	98	-1	106	-9
Write-offs		-3	-28	-206		-237
Unwind discount / unearned interest accrued		1	1	29		30
Foreign exchange and other movements			-47	6		-41	-24
Balance as at 31 December 2025	4	120	74	1,026	1	1,226	63
							2025
Impairment charges (releases) on loans and advances		-10	18	98	-1	106	-9
Recoveries and other charges (releases)		-8	-25	-43		-76
Total impairment charges for the period²		-18	-7	55	-1	29	-9
1. Remeasurements represents the current year change of expected credit loss allowances mainly attributable to changes in volumes such as partial repayments and changes in the credit quality of existing loans remaining in their stage.
2. The impairment charges for the period excludes charges (releases) for financial investments held at FVOCI 31 December 2025: EUR 0 million.


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(in millions)	Banks	Residential mortgages	Consumer loans	Corporate loans	Other loans	Total loans and advances	Off-balance
Balance as at 31 December 2023	3	198	147	1,254	3	1,605	109
Transfer to stage 1		-4	-4	-10		-18
Transfer to stage 2		6		23		29	2
Transfer to stage 3		16	29	137		181
Remeasurements¹		-73	-15	-16	-2	-105	22
Changes in risk parameters		1	3	-11		-7
Originated or purchased		4	3	33	1	41	5
Matured or repaid		-14	-6	-60		-79	-7
Impairment charges (releases) on loans and advances		-64	11	96	-2	41	22
Write-offs		-2	-31	-317		-350
Unwind discount / unearned interest accrued		1	3	22	1	27
Foreign exchange and other movements			-1	45		45	-34
Balance at 31 December 2024	4	133	130	1,100	2	1,368	96
							2024
Impairment charges (releases) on loans and advances		-64	11	96	-2	41	22
Recoveries and other charges (releases)		-11	-25	-48		-83
Total impairment charges for the period²		-75	-13	48	-2	-42	22
1. Remeasurements represents the current year change of expected credit loss allowances mainly attributable to changes in volumes such as partial repayments and changes in the credit quality of existing loans remaining in their stage.
2. The impairment charges for the period excludes charges (releases) for financial investments held at FVOCI 31 December 2024: EUR 1 million.

Loan impairment charges and allowances per stage

Audited


				2025				2024
(in millions)	Stage 1	Stage 2	Stage 3²	Total²	Stage 1	Stage 2	Stage 3²	Total²
Balance as at 1 January	170	226	971	1,368	237	289	1,079	1,605
Transfer to stage 1	82	-82	-8	-8	61	-70	-9	-18
Transfer to stage 2	-21	68	-39	8	-32	104	-43	29
Transfer to stage 3	-5	-31	159	123	-6	-29	216	181
Remeasurements¹	-123	-36	100	-59	-106	-46	46	-105
Changes in models	24	17	34	75
Changes in risk parameters	-2	-2		-3	-5	-4	2	-7
Originated or purchased	45			45	41			41
Matured or repaid	-17	-13	-44	-75	-18	-24	-38	-79
Impairment charges (releases) on loans and advances	-17	-79	202	106	-65	-68	174	41
Write-offs			-237	-237			-350	-350
Unwind discount / unearned interest accrued			30	30			27	27
Foreign exchange and other movements	-3	-7	-30	-41	-2	6	41	45
Balance as at 31 December	150	141	935	1,226	170	226	971	1,368

Impairment charges (releases) on loans and advances	-17	-79	202	106	-65	-68	174	41
Recoveries and other charges (releases)			-76	-76			-83	-83
Total impairment charges for the period	-17	-79	125	29	-65	-68	91	-42
1. Remeasurements represents the current year change of expected credit loss allowances mainly attributable to changes in volumes such as partial repayments and changes in the credit quality of existing loans remaining in their stage.
2. Including POCI.

Impairment charges of EUR 20 million (consisting of on-

balance sheet charges of EUR 29 million and an off-

balance-sheet release of EUR 9 million) were recorded

for 2025 (2024: a release of EUR 42 million and

off‑balance sheet charges of EUR 22 million charges).

Impairment charges were primarily related to corporate

loans and, to a lesser extent, consumer loans, and were

partly offset by impairment releases related to

residential loans.

For corporate loans, charges of EUR 55 million were

recorded in 2025, primarily due to an increase in

individual files over different sectors. In 2024, there

were charges of EUR 48 million. The increase in 2025

was partly offset by a decrease in management overlays

of EUR 51 million, which was largely attributable to the

decommissioning of the management overlay that had

been put in place to deal with the potential impact of

the government’s nitrogen-reducing measures on


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clients active in livestock farming. This risk is now taken

into account in the client’s credit risk assessment. In

addition, there was a reduction of the overlay for

climate and environmental transition risk. This reduction

reflects updated figures and the incorporation of the

CER materiality framework methodology improvements

when estimating the impact of the CER on the expected

credit losses. Furthermore, the in-model adjustment for

the small business loans portfolio model was reduced,

based on model monitoring results.

For residential mortgages, releases of EUR 18 million

were recorded in 2025, compared with releases of

EUR 75 million in 2024. The release in 2025 was mainly

caused by the improved House Price Index, which also

led to a decrease in the management overlay for

interest-only mortgages.

Individual and collective loan impairment allowances and management overlays

Audited


						31 December 2025
(in millions)	Banks	Residential mortgages	Consumer loans	Corporate loans	Other loans	Total loans and advances	Off-balance
Individual impairments
Stage 3¹			41	685	1	728	50
Total individual impairments			41	685	1	728	50

Collective impairments
Stage 1	4	29	8	109		150	9
Stage 2		39	5	96		141	3
Stage 3¹		52	20	136		208
Total collective impairments	4	120	33	341		498	13
- of which management overlay		72		5		77

Total impairments	4	120	74	1,026	1	1,226	63

Carrying amount of loans, determined to be impaired, before deducting any assessed impairment allowance		1,952	152	3,309	4	5,417
1. Including POCI.


						31 December 2024
(in millions)	Banks	Residential mortgages	Consumer loans	Corporate loans	Other loans	Total loans and advances	Off-balance
Individual impairments
Stage 3¹			42	600	2	643	80
Total individual impairments			42	600	2	643	80

Collective impairments
Stage 1	4	36	12	119		170	6
Stage 2		42	15	170		226	10
Stage 3¹		55	60	212		327
Total collective impairments	4	133	88	500		724	16
- of which management overlay		85		56		140

Total impairments	4	133	130	1,100	2	1,368	96

Carrying amount of loans, determined to be impaired, before deducting any assessed impairment allowance		1,919	222	3,110	6	5,258
1. Including POCI.

Total collective impairments amounted to

EUR 498 million as at 31 December 2025

(31 December 2024: EUR 724 million). These

impairments included expected credit losses (ECL) as

calculated by our IFRS 9 models and the management

overlays we recorded. The ECL calculations take into

account a probability-weighted average of three

economic scenarios. As the ECL model outcomes do not

always reflect the current economic environment and

circumstances, additional management overlays are

applied to incorporate novel risks not fully captured by

the model.

During 2025, management overlays significantly

decreased to a total of EUR 77 million

(31 December 2024: EUR 140 million). Some of the

management overlays were recorded for risks in

corporate loans portfolios, where impairments declined


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sharply from EUR 56 million to EUR 5 million. This was

mainly due to the following factors:

• Discontinuation of the management overlay

introduced to address the potential impact of the

government’s nitrogen reducing measures on clients

active in livestock farming. This decision reflects the

sector’s demonstrated ability to manage associated

risks effectively. Furthermore, recent credit risk

assessments did not reveal any material increase in

client-level credit risk. The discontinuation resulted in

a release of EUR 29 million.

• Reduction of EUR 14 million in the climate and

environmental risk-related overlay, reflecting updated

figures and the incorporation of the CER materiality

framework methodology improvements in estimates

of the impact of the CER on the expected credit

losses.

• Discontinuation of the overlays covering potential

additional risk costs relating to the wind-down of

portfolios, leading to a release of EUR 7 million.

The overlays recorded for risks in the interest-only

mortgages portfolio decreased from EUR 85 million to

EUR 72 million, primarily as a result of improved

collateral indexation.

All management overlays represent best estimates of

the risks involved. The underlying reasoning and

calculations are documented and are discussed and

approved by the Impairments and Provisioning

Committee (IPC).

Macroeconomic scenarios and ECL sensitivity

The expected credit losses (ECL) scenarios in the table

below reflect the expectations of our economists at the

end of December 2025. Economic developments that

occurred after that date will be reflected in our ECL

calculation for the first quarter of 2026.

GDP growth in the Netherlands is expected to remain

subdued on the back of US tariffs and international and

domestic uncertainty, and estimates predict growth of

1.2% in 2026 and 1.4% in 2027. Labour market

tightness is easing on the whole: unemployment is

projected to rise slightly but remain low from a

historical perspective, supported by elevated labour

demand and limited labour supply. We forecast the

unemployment rate to increase to 4.2% in 2026 and

4.3% in 2027. Higher wages, lower interest rates and

supply shortages contributed to strong growth in the

housing markets in 2025. We expect price growth to

normalise in 2026, moving close to the long term

average of 3.0%.

International developments, such as the unrest in the

Middle East and US tariffs, are evolving rapidly, leading

to increasing geopolitical uncertainties. The direct

impact on the bank’s credit portfolio is considered

limited, given its concentration on the Netherlands

(Dutch residential mortgages) and other portfolios in

Northwest Europe with limited direct exposure to

current macro-economic developments. We will

continue to keep a close eye on such developments,

including potential second order impacts (such as a

slow down in global trade and deteriorating consumer

confidence).

Macroeconomic scenarios in 2025

Audited


(in millions)	Weight	Macroeconomic variable¹	2026	2027	2028	2029	Unweighted ECL ⁵	Weighted ECL ⁵
		Real GDP Netherlands²	2.4%	2.0%	1.4%	1.5%
Positive	15%	Unemployment³	3.7%	3.7%	3.7%	3.7%	449
		House price index ⁴	5.7%	3.9%	3.2%	3.1%
		Real GDP Netherlands²	1.2%	1.4%	1.4%	1.3%
Baseline	55%	Unemployment³	4.2%	4.3%	4.4%	4.4%	479	498
		House price index ⁴	3.0%	2.3%	3.6%	3.7%
		Real GDP Netherlands²	-0.3%	0.6%	1.3%	1.2%
Negative	30%	Unemployment³	6.0%	5.9%	5.8%	5.5%	559
		House price index ⁴	-2.2%	-0.9%	1.7%	3.6%
1. The variables presented in this table are a selection of the key macroeconomic variables.
2. Real GDP Netherlands, % change year-on-year.
3. Unemployment Netherlands, % of labour force.
4. House price index Netherlands, average % change year-on-year.
5. Excluding ECL for stage 3 and POCI for exposures not affected by macroeconomic scenarios.


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Macroeconomic scenarios in 2024

Audited


(in millions)	Weight	Macroeconomic variable¹	2025	2026	2027	2028	Unweighted ECL ⁵	Weighted ECL ⁵
		Real GDP Netherlands²	2.6%	2.1%	1.7%	1.3%
Positive	15%	Unemployment³	3.5%	3.5%	3.6%	3.5%	639
		House price index ⁴	7.5%	3.8%	3.0%	3.0%
		Real GDP Netherlands²	1.5%	0.8%	1.2%	1.3%
Baseline	55%	Unemployment³	3.9%	4.2%	4.4%	4.4%	692	724
		House price index ⁴	7.0%	3.5%	2.1%	2.5%
		Real GDP Netherlands²	0.5%	-0.4%	0.7%	1.2%
Negative	30%	Unemployment³	6.0%	6.0%	5.8%	5.7%	826
		House price index ⁴	0.2%	-4.5%	1.5%	2.6%
1. The variables presented in this table are a selection of the key macroeconomic variables.
2. Real GDP Netherlands, % change year-on-year.
3. Unemployment Netherlands, % of labour force.
4. House price index Netherlands, average % change year-on-year.
5. Excluding ECL for stage 3 and POCI for exposures not affected by macroeconomic scenarios.

Credit risk mitigation

Audited

Collateral reporting is based on the net collateral value

(NCV). The NCV represents the amount expected to be

recovered from the collateral pledged to the bank if the

client defaults. Where necessary, certain discounts are

applied. The NCV is approached by an average recovery

rate observed for the specific type of collateral and,

where applicable, by applying haircuts, for example in

the event of currency mismatches. Surplus collateral is

the amount of over-collateralisation, calculated on an

individual basis. A surplus is not included for

guarantees, as the debtor cannot be held liable for

more than the maximum debt.


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Financial assets: offsetting, netting, collateral and guarantees

Audited


									31 December 2025
	Offset in the statement of financial position			Not offset in the statement of financial position						Net exposure ⁵
(in millions)	Carrying amount before balance- sheet netting	Less: balance- sheet netting with gross liabilities	Carrying amount²	Master netting agree- ment³	Financial instru- ments collateral	Property & equip- ment	Other collateral and guar- antees	Total risk mitigation	- of which surplus collateral ⁴
Financial assets held for trading	2,044		2,044							2,044
Derivatives	3,933		3,933	2,295	1,181			3,476	37	494
Financial investments	50,231		50,231							50,231
Securities financing	44,214	4,041	40,173	985	43,772			44,757	5,453	870
Interest-bearing deposits	1,137		1,137	33				33		1,104
Loans and advances	708		708	468	816			1,284	814	238
Other	326		326							326
Total loans and advances banks	2,170		2,170	501	816			1,316	814	1,668
Residential mortgages	163,065		163,065		2,816	347,227	628	350,670	191,335	3,729
Consumer loans	6,192	1	6,192		3,489	3,705	36	7,229	2,691	1,653
Corporate loans	86,218	728	85,490	1,414	31,317	52,051	3,333	88,115	33,171	30,546
Other loans and advances customers	5,934		5,934	11		19	2	31	11	5,914
Fair value adjustment from hedge accounting	-5,434		-5,434							-5,434
Total loans and advances customers¹	255,975	729	255,247	1,424	37,622	403,002	3,998	446,045	227,208	36,409
Loans at fair value through P&L	514		514			1,867	20	1,887	1,376	3
Total loans and advances customers	256,489	729	255,760	1,424	37,622	404,868	4,018	447,932	228,584	36,412
Other assets	3,877		3,877	9			423	432		3,446
Total on-balance sheet subject to netting and pledged agreements	362,959	4,769	358,190	5,214	83,390	404,868	4,441	497,913	234,888	95,165
Assets not subject to netting and pledged agreements	55,020		55,020							55,020
Total assets	417,979	4,769	413,210	5,214	83,390	404,868	4,441	497,913	234,888	150,185
Total off-balance sheet	98,832		98,832		1,336	10,883	618	12,837	3,910	89,904
Total on- and off-balance sheet	516,811	4,769	512,041	5,214	84,726	415,751	5,059	510,750	238,798	240,090
1. Excluding loans at fair value through P&L.
2. Carrying amount includes loan impairment allowances where applicable.
3. Collateral in the column Master netting agreement is mainly markets related and consists of master netting agreements which also includes cash collateral as part of these agreements. Cash collateral not part of master netting agreements has been reported under the column Financial instruments.
4. Surplus collateral is the amount of over-collateralisation, calculated on an individual basis.
5. Net exposure represents the portfolio corrected for the surplus amount and gives a view on the potential shortfall in collateral on the total portfolio.


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									31 December 2024
	Offset in the statement of financial position			Not offset in the statement of financial position						Net exposure ⁵
(in millions)	Carrying amount before balance- sheet netting	Less: balance- sheet netting with gross liabilities	Carrying amount²	Master netting agree- ment³	Financial instru- ments collateral	Property & equip- ment	Other collateral and guar- antees	Total risk mitigation	- of which surplus collateral ⁴
Financial assets held for trading	2,503		2,503							2,503
Derivatives	4,347		4,347	3,176	639			3,815	103	635
Financial investments	47,173		47,173							47,173
Securities financing	32,192	5,203	26,989	847	32,348			33,195	6,452	246
Interest-bearing deposits	1,169		1,169	16				16		1,153
Loans and advances	707		707	527	728			1,255	721	173
Other	174		174							174
Total loans and advances banks	2,049		2,049	543	728			1,271	721	1,500
Residential mortgages	156,076		156,076		2,695	325,975	372	329,041	176,542	3,577
Consumer loans	7,446	1	7,445		2,866	3,958	48	6,873	2,928	3,501
Corporate loans	83,433	705	82,727	1,759	30,917	54,489	3,303	90,468	37,508	29,767
Other loans and advances customers	6,491	4	6,487	49		31		80	10	6,417
Fair value adjustment from hedge accounting	-4,584		-4,584							-4,584
Total loans and advances customers¹	248,863	711	248,152	1,808	36,478	384,453	3,723	426,463	216,988	38,677
Loans at fair value through P&L	630		630			1,715		1,715	1,252	167
Total loans and advances customers	249,493	711	248,782	1,808	36,478	386,168	3,723	428,178	218,239	38,843
Other assets	4,652		4,652	7	584		1,163	1,754	584	3,482
Total on-balance sheet subject to netting and pledged agreements	342,409	5,914	336,496	6,380	70,777	386,168	4,887	468,212	226,099	94,383
Assets not subject to netting and pledged agreements	48,551		48,551							48,551
Total assets	390,960	5,914	385,047	6,380	70,777	386,168	4,887	468,212	226,099	142,934
Total off-balance sheet	97,348		97,348		1,952	11,547	845	14,344	5,478	88,482
Total on- and off-balance sheet	488,308	5,914	482,394	6,380	72,729	397,715	5,732	482,556	231,577	231,415
1. Excluding loans at fair value through P&L.
2. Carrying amount includes loan impairment allowances where applicable.
3. Collateral in the column Master netting agreement is mainly markets related and consists of master netting agreements which also includes cash collateral as part of these agreements. Cash collateral not part of master netting agreements has been reported under the column Financial instruments.
4. Surplus collateral is the amount of over-collateralisation, calculated on an individual basis.
5. Net exposure represents the portfolio corrected for the surplus amount and gives a view on the potential shortfall in collateral on the total portfolio.

Total risk mitigation increased owing to an increase in

property and equipment for residential mortgages,

which was mainly due to rising house prices and loan

portfolio growth. As a result, surplus collateral also

increased. For consumer loans, net exposure declined

because of the reclassification of loan portfolios of our

subsidiary Alfam. For corporate loans, there was an

increase in exposure, which was mainly attributable to

the acquisition of HAL. This increase, in combination

with a decrease in collateral, led to a decline in surplus

collateral and, to a lesser extent, an increase in net

exposure.

The total net exposure of loans and advances customers

decreased to EUR 36.4 billion in 2025

(31 December 2024: EUR 38.8 billion). The main cause

of this decrease was the decline in net exposure on

consumer loans and in the net exposure on fair value

adjustment from hedge accounting, due to rising

interest rates. The decrease was partly offset by the

increase in corporate loans.


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Financial assets: offsetting, netting,

collateral and guarantees for credit-impaired

assets

Audited

Collateral and guarantees for credit-impaired assets

(stage 3 and POCI) represent credit risk mitigation based

on the net collateral value (NCV) for clients in default. The

carrying amount includes expected credit loss

allowances, based on the probability-weighted present

value of all expected cash shortfalls over the remaining

life of the financial instrument for both on- and off-

balance sheet exposures. The Financial Restructuring &

Recovery department identifies the most likely scenarios

for non-programme lending defaulted clients (going

concern or gone concern) and estimates the amounts and

timing of expected future cash flows. This explains why a

net exposure remains after taking into account collateral

pledged to the bank.


									31 December 2025
	Offset in the statement of financial position			Not offset in the statement of financial position						Net exposure ⁴
(in millions)	Carrying amount before balance- sheet netting	Less: balance- sheet netting with gross liabilities	Carrying amount¹	Master netting agree- ment²	Financial instru- ments collateral	Property & equip- ment	Other collateral and gua- rantees	Total risk mitigation	- of which surplus collateral³
Loans and advances banks
Residential mortgages	1,899		1,899		13	3,478	1	3,493	1,593
Consumer loans	91		91		8	54		62	19	48
Corporate loans	2,488		2,488		464	1,237	407	2,107	592	973
Other loans and advances customers	3		3				2	2		1
Total loans and advances customers	4,481		4,481		485	4,769	410	5,664	2,204	1,022
Total loans and advances	4,481		4,481		485	4,769	410	5,664	2,204	1,022
1. Carrying amount includes loan impairment allowances where applicable.
2. Collateral in the column Master netting agreement is mainly markets related and consists of master netting agreements which also includes cash collateral as part of these agreements. Cash collateral not part of master netting agreements has been reported under the column Financial instruments.
3. Surplus collateral is the amount of over-collateralisation, calculated on an individual basis.
4. Net exposure represents the portfolio corrected for the surplus amount and gives a view on the potential shortfall in collateral on the total portfolio.


									31 December 2024
	Offset in the statement of financial position			Not offset in the statement of financial position						Net exposure ⁴
(in millions)	Carrying amount before balance- sheet netting	Less: balance- sheet netting with gross liabilities	Carrying amount¹	Master netting agree- ment²	Financial instru- ments collateral	Property & equip- ment	Other collateral and gua- rantees	Total risk mitigation	- of which surplus collateral³
Loans and advances banks
Residential mortgages	1,863		1,863		13	3,333	1	3,348	1,483	-1
Consumer loans	120		120		18	62		80	27	66
Corporate loans	2,299		2,299		774	1,768	230	2,773	825	351
Other loans and advances customers	5		5							5
Total loans and advances customers	4,287		4,287		805	5,163	232	6,201	2,335	421
Total loans and advances	4,287		4,287		805	5,163	232	6,201	2,335	421
1. Carrying amount includes loan impairment allowances where applicable.
2. Collateral in the column Master netting agreement is mainly markets related and consists of master netting agreements which also includes cash collateral as part of these agreements. Cash collateral not part of master netting agreements has been reported under the column Financial instruments.
3. Surplus collateral is the amount of over-collateralisation, calculated on an individual basis.
4. Net exposure represents the portfolio corrected for the surplus amount and gives a view on the potential shortfall in collateral on the total portfolio.

The stage 3 carrying amount (including POCI) rose

marginally to EUR 4.5 billion (31 December 2024:

EUR 4.3 billion), while total risk mitigation decreased to

EUR 5.7 billion in 2025 (31 December 2024:

EUR 6.2 billion). This decrease in risk mitigation was

mainly observed in corporate loans, and was caused by

a decrease in collateral at Corporate Banking. The

carrying amount of the stage 3 portfolio (including

POCI) increased, while the total risk mitigation

decreased. This led to a EUR 601 million increase in the

net exposure, which was EUR 1,022 million as at

31 December 2025.


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During 2025 ABN AMRO obtained property and

equipment by taking possession of collateral held as

security for loans and advances. The total amount of

such assets held on 31 December 2025 amounted to

EUR 3 million (2024: EUR 4 million). ABN AMRO does

not intend to use these assets in its operations and will

pursue timely and orderly realisation of the collateral.

Financial liabilities: offsetting, netting, collateral and guarantees

Audited


							31 December 2025
	Offset in the statement of financial position			Not offset in the statement of financial position				Net exposure³
(in millions)	Carrying amount before balance- sheet netting	Less: balance- sheet netting with gross assets	Carrying amount	Master netting agree- ment¹	Financial instru- ments collateral	Total risk mitigation	- of which surplus collateral²
Financial liabilities held for trading	1,631		1,631					1,631
Derivatives	1,967		1,967	1,397	116	1,513	37	492
Securities financing	19,361	4,041	15,320	978	19,774	20,752	5,467	34
Deposits	4,319		4,319	829		829		3,491
Other	1		1					1
Due to banks	4,320		4,320	829		829		3,491
Deposits	278,768	728	278,040	1,027		1,027		277,013
Other borrowings	1,086		1,086	982		982		104
Due to customers	279,854	728	279,126	2,010		2,010		277,117
Other liabilities	3,918	1	3,918					3,918
Total liabilities subject to netting arrangements	311,051	4,769	306,281	5,214	19,890	25,104	5,505	286,682
Remaining liabilities not subject to netting	79,886		79,886					79,886
Total liabilities	390,937	4,769	386,167	5,214	19,890	25,104	5,505	366,568
1. Collateral in the column Master netting agreement is mainly markets related and consists of master netting agreements which also includes cash collateral as part of these agreements. Cash collateral not part of master netting agreements has been reported under the column Financial instruments.
2. Surplus collateral is the amount of over-collateralisation, calculated on an individual basis.
3. Net exposure represents the portfolio corrected for the surplus amount and gives a view on the potential shortfall in collateral on the total portfolio.


							31 December 2024
	Offset in the statement of financial position			Not offset in the statement of financial position				Net exposure³
(in millions)	Carrying amount before balance- sheet netting	Less: balance- sheet netting with gross assets	Carrying amount	Master netting agree- ment¹	Financial instru- ments collateral	Total risk mitigation	- of which surplus collateral²
Financial liabilities held for trading	1,163		1,163					1,163
Derivatives	2,499		2,499	1,590	207	1,797	27	729
Securities financing	15,555	5,203	10,352	846	15,792	16,638	6,305	19
Deposits	2,329		2,329	658		658		1,671
Due to banks	2,329		2,329	658		658		1,672
Deposits	254,998	710	254,288	1,589		1,589		252,699
Other borrowings	1,899		1,899	1,698		1,698		200
Due to customers	256,896	710	256,186	3,287		3,287		252,900
Other liabilities	4,247	1	4,247					4,247
Total liabilities subject to netting arrangements	282,689	5,914	276,776	6,380	15,999	22,379	6,332	260,728
Remaining liabilities not subject to netting	82,163		82,163					82,163
Total liabilities	364,852	5,914	358,939	6,380	15,999	22,379	6,332	342,892
1. Collateral in the column Master netting agreement is mainly markets related and consists of master netting agreements which also includes cash collateral as part of these agreements. Cash collateral not part of master netting agreements has been reported under the column Financial instruments.
2. Surplus collateral is the amount of over-collateralisation, calculated on an individual basis.
3. Net exposure represents the portfolio corrected for the surplus amount and gives a view on the potential shortfall in collateral on the total portfolio.


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Developments in specific portfolios

The following section provides a more detailed

overview of developments in specific portfolios and

products.

Residential mortgages

Housing market developments

House prices on the Dutch housing market continued to

increase in 2025. According to the Dutch Land Registry

(Kadaster), prices of existing owner-occupied homes

increased by 8.6% in 2025 (2024: 8.7%). The increase

in property prices reflects household income growth,

and therefore affordability, as well as housing supply

shortages.

The total number of house sales in 2025 increased as

well. According to the Dutch Land Registry, 239,000

homes were sold in 2025 compared with 206,000 in

2024, which is an increase of 15.6%. According to NVM

(Dutch Association of Real Estate Agents and

Appraisers), the primary driver of this growth is the rise

in the number of homes being brought to market. The

sale of rental properties (divestments) contributed to a

temporary increase in transaction volumes. NVM noted,

however, that the strongest growth was mainly seen in

transactions involving terraced and end‑of‑terrace

houses.

According to NVM, the number of houses for sale as at

31 December 2025 was up 16% compared with one

year earlier. The supply of homes for sale remains tight.

On average, each buyer could only choose from 1.9

available homes at the end of 2025 (2024: 1.8;

2023: 2.1; 2022: 3.2).

Residential mortgage indicators


(in millions)	31 December 2025	31 December 2024
Gross carrying amount excluding fair value adjustment from hedge accounting	163,185	156,209
- of which Nationale Hypotheek Garantie (NHG)	36,736	31,897
Fair value adjustment from hedge accounting	-5,477	-4,686
Carrying amount excluding fair value adjustment from hedge accounting	163,065	156,076
Exposure at Default	168,507	164,134
Risk-weighted assets (Credit risk)	22,184	23,620
RWA/Exposure at Default	13.2%	14.4%
Forbearance ratio	0.6%	0.7%
Past due ratio	0.6%	0.8%
Stage 3 ratio	1.2%	1.2%
Stage 3 coverage ratio	2.7%	2.9%
Cost of risk (in bps)¹	-1	-5
Average LtMV (indexed)	54%	54%
Average LtMV - excluding NHG loans (indexed)	52%	53%
Total risk mitigation	350,670	329,041
Total risk mitigation/carrying amount excluding fair value adjustment from hedge accounting	215.0%	210.8%
1. Impairment charges on loans and advances customers for the period divided by the average loans and advances customers on the basis of gross carrying amount and excluding fair value adjustment from hedge accounting.

The residential mortgage portfolio increased by

EUR 7.0 billion to EUR 163.2 billion in 2025

(31 December 2024: EUR 156.2 billion). ABN AMRO’s

market share of new mortgage production in 2025 was

19% (2024: 19%). In Q4 2025, EUR 1.2 billion in

mortgage loans was reclassified to assets held for sale.

The proportion of amortising mortgages increased to

55% as at 31 December 2025 (31 December 2024:

50%). Total redemptions were 13% higher than in

2024. Extra repayments in 2025 amounted to

EUR 2.0 billion (2024: EUR 1.9 billion). The share of

mortgages covered by the National Mortgage

Guarantee (NHG) scheme increased to 23%

(2024: 20%).

Credit quality indicators

In general, the credit quality indicators for residential

mortgages improved. The mortgage arrears ratio

decreased to 0.6% as at 31 December 2025

(31 December 2024: 0.8%). The coverage ratio for

stage 3 fell from 2.9% to 2.7%.

Risk-weighted assets and EAD

The RWA for credit risk in the residential mortgage

portfolio decreased to EUR 22.2 billion

(31 December 2024: EUR 23.6 billion). Exposure

at default (EAD) rose to EUR 168.5 billion

(31 December 2024: EUR 164.1 billion).


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Residential mortgages to indexed market value


			31 December 2025				31 December 2024
	Gross carrying amount	Percentage of total			Gross carrying amount	Percentage of total
(in millions)			- of which guaranteed¹	- of which unguaranteed			- of which guaranteed¹	- of which unguaranteed
LtMV category
< 50%	78,764	48.3%	10.3%	37.9%	72,625	46.5%	9.9%	36.6%
50% - 80%	57,649	35.3%	6.5%	28.8%	60,462	38.7%	6.9%	31.8%
80% - 90%	11,962	7.3%	2.3%	5.0%	10,969	7.0%	1.5%	5.5%
90% - 100%	11,584	7.1%	3.0%	4.1%	9,363	6.0%	2.0%	4.0%
>100%	2,879	1.8%	0.4%	1.4%	2,421	1.5%	0.2%	1.3%
Unclassified	347	0.2%			368	0.2%
Total	163,185	100%			156,209	100%
1. NHG guarantees.

The gross carrying amount of mortgages with a loan-to-

market value (LtMV) in excess of 100% increased to a

total of EUR 2.9 billion at year-end 2025 (2024:

EUR 2.4 billion) and represented 1.8% of total

mortgages (2024: 1.5%). Approximately 4% of extra

repayments relate to this category. New inflow of

mortgages with an LtMV in excess of 100% mainly

relates to sustainable home improvements in

accordance with the temporary Dutch scheme for

mortgage loans (Tijdelijke Regeling Hypothecair

Krediet). The LtMV on those loans is capped at 106%.

Breakdown of residential mortgage portfolio by loan type


	31 December 2025		31 December 2024
(in millions)	Gross carrying amount	Percentage of total	Gross carrying amount	Percentage of total
Interest-only (partially)	39,356	24%	40,824	26%
Interest-only (100%)	19,441	12%	20,949	13%
Redeeming mortgages (annuity/linear)	89,124	55%	78,081	50%
Savings	7,582	5%	8,158	5%
Life (investment)	4,462	3%	5,051	3%
Other¹	3,220	2%	3,144	2%
Total	163,185	100%	156,209	100%
1. Other includes hybrid and unclassified mortgage types. The hybrid portfolio consists of a combination of savings and investment mortgages.

Residential mortgages to indexed market value for 100% interest-only


	31 December 2025	31 December 2024
	Percentage of total	Percentage of total
Loan-to-Market Value category
< 50%	11%	12%
50% - 70%	1%	1%
70% - 100%	0%	0%
>100%	0%	0%
Total¹	12%	13%
1. Percentages of the total mortgage portfolio.

The proportion of fully interest-only mortgages

decreased from 13% to 12% of the total mortgage

portfolio in 2025, while approximately 17%

(2024: 17%) of the extra repayments related to this type

of loan. The amount of fully interest-only mortgages

with an LtMV in excess of 100% remains very limited.


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Breakdown of the residential mortgage portfolio by year of latest adjustment¹

(in billions)

¹ Includes the new mortgage production and all mortgages with an adjustment date.

² Other includes universal life, life investment, hybrid and unclassified mortgage types. The hybrid portfolio consists of a combination of savings and

investment mortgages.

In 2025, mortgage loan type originations (defined as

new production and mortgages with a loan type

modification) were as follows: 12.1% interest-only,

80.6% amortising mortgages and 1.0% savings

mortgages. Interest-only and savings mortgages can

still be provided to clients who want to refinance loans

originated before 2013.

Commercial Real Estate (CRE)

Market developments

In 2025, the Dutch CRE market continued its gradual

recovery path, as evidenced by growth in investment

volumes and valuations, as well as stabilising gross

reversionary yields. While macroeconomic conditions

improved, geopolitical tensions and uncertainties

throughout the year led investors to remain somewhat

cautious, focusing on prime assets with good energy

labels, stable tenants and favourable financing

conditions.

In 2025 the ECB further reduced its deposit facility rate

by 100 basis points, from 3.00% at the beginning of

2025 to 2.00% at the end of the year. Conversely,

during the same period the EUR 5-year interest rate

swap rate increased from 2.24% to 2.57%, while the

EUR 10-year swap rate increased from 2.36% to 2.94%,

resulting in an upward-sloping yield curve at year-end

2025. Year-on-year CPI inflation at the beginning of

2025 stood at 3.30% but fell to 2.80% by year-end.

Overall, the impact of stabilised economic conditions

and solid growth seems to have outweighed the effects

of increased financing (and refinancing) costs.

Investment volumes in the Dutch CRE sector continued

to recover from the 2023 dip, and increased to

EUR 11.3 billion in 2025. This represents a year-on-year

growth of 12% compared with 2024. Prime yields

showed stable trends. For all asset classes, the gross

revisionary yields in 2025 were on a par with the yields

in 2024. Furthermore, the Dutch quarterly MSCI

property index saw total capital value increase by 5.2%

and a total year-on-year return of 9.1% in 2025 across

all CRE asset classes (Q4 2025). The strongest

performing asset class was residential, with year-on-

year capital growth of 6.5% and a total return of 9.9%.

New real estate development activity remains inhibited

by structural bottlenecks, such as electricity grid

congestion and nitrogen emission caps.

Offices

The Dutch office market in 2025 was characterised by a

dual dynamic, as growth in the prime office market

continued while low-quality office locations were

avoided by investors. High-quality offices with solid

sustainability performance and good access to public

transportation are still priced at a premium. There is a

continued trend of falling demand for low-quality

offices. Overall, the gross reversionary yield remained

stable at 7.8%, with a total year-on-year return of 5.7%

for Q4 2025, which represents an improvement on the

figures for Q4 2024. The median rental price per square

metre also remained stable at EUR 136. The supply and

uptake of office space also remained stable and

comparable to 2024.

Residential

Out of all Dutch CRE asset classes, residential

investments performed best in 2025. The total year-on-

year return for Q4 2025 was 9.9% and average year-on-

year capital growth was 6.5%. The main causes of the

price increase were the relatively low interest rates,

stable household income growth and the ongoing

housing shortage. Moreover, changes in tax regulation

and the implementation of the Affordable Rent Act

2025 (Wet Betaalbare Huur 2025) led to an increase in

transaction volume, which was predominantly driven by

sales of rental properties by private investors. In 2025,

transaction volume was 16% higher than in 2024.


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However, concerns regarding housing shortages

remain. There have been limited improvements in the

areas of development permits and regulatory

impediments (such as nitrogen regulation and objection

procedures). On a more positive note, inflation in

construction material costs stabilised in 2024 and 2025.

Retail

The retail market showed signs of improvement in the

four largest cities, but there was limited growth in other

regions. On average, yields remained steady compared

with 2024. The gross reversionary yield on retail rose

slightly, from 5.8% in Q4 2024 to 5.9% in Q4 2025.

Capital returns and total returns also remained stable

from 2024 to 2025. There was a shift in pace in the

supply of retail real estate in 2025 compared with

2024. Year-on-year, total available floor space fell by

110,000 square meters. Compared with 2024, total

transaction volume decreased in 2025.

Industrial

Issues such as electricity grid congestion and nitrogen

emissions have become more pressing in the industrial

and logistics sectors. However, while industrial

producer sentiment has remained negative due to the

structural bottlenecks in the Dutch economy, there has

been an increase in production volume and in export

volume in the eurozone. Uptake of the largest industrial

and logistics spaces has been limited, but there has

recently been a boom in the availability of smaller

industrial spaces. The supply of logistical and business

floor space increased by 1.4 million square

metres between Q4 2024 and Q4 2025. Overall, the

total year-on-year return for industrial real estate was

9.1% at Q4 2025.

CRE portfolio

The exposure reported in the CRE portfolio relates to

loans aimed at acquiring CRE property or secured by

CRE property. In this context, CRE means any income-

producing real estate, either existing or under

development or renovation. It excludes social housing,

property owned by end-users, buy-to-let housing below

a market value of EUR 2 million and unsecured general

purpose lending. The credit exposure covered by the

above definition is monitored on a quarterly basis and

subject to an EAD and RWA limit.

The outstanding volume of CRE financing increased

during the year. In 2025 the gross carrying amount rose

to EUR 13.6 billion (31 December 2024:

EUR 13.1 billion). This growth was primarily driven by

the origination of new sustainable propositions, which

more than compensated for outflow resulting from

stricter sustainability-related financing and refinancing

requirements. For all new CRE transactions, and all

revisions of existing exposures, refinancing and

sustainability risks are assessed in line with our risk

framework. Where appropriate, mitigating actions are

taken. The CRE portfolio is largely collateralised by

Dutch properties and mainly consists of well-diversified

investment loans across multiple asset classes. The

portfolio composition remained broadly unchanged

compared with 2024.

Breakdown of CRE portfolio by asset type

(in %)

2025 ¹ GCA

EUR 13.6 billion

2024 ¹ GCA

EUR 13.1 billion

1 Distribution excluding collateral not defined as

commercial real estate collateral, such as currency and

deposits, financial guarantees and life insurance policies

pledged.

2 Other asset types includes mixed objects, hotels &

hospitality facilities and parking real estate.


ABN AMRO	Annual Report 2025	96


≡	Risk, funding & capital	Risk management	Market risk in the trading book

Market risk in the trading book



	This section provides information on: • Total market risk exposure • Market risk management for the trading book • Market risk measurement for the trading book • Valuation adjustments • Review of 2025 results

Total market risk exposure

Market risk exposure - traded and non-traded

risk

ABN AMRO is exposed to market risk in its trading book

and banking book. The following table presents the

market risk factors to which the assets and liabilities in

the balance sheet are sensitive.


		31 December 2025			31 December 2024
	Carrying amount	Market risk measure		Carrying amount	Market risk measure
(in millions)		Traded risk	Non-traded risk		Traded risk	Non-traded risk
Assets subject to market risk
Cash and balances at central banks	49,486		49,486	44,464		44,464
Financial assets held for trading	2,044	2,044		2,503	2,503
Derivatives	3,933	3,474	460	4,347	3,891	455
Financial investments	50,231		50,231	47,173		47,173
Securities financing	40,173		40,173	26,989		26,989
Loans and advances banks	2,170		2,170	2,049		2,049
Loans and advances customers	255,760		255,760	248,782		248,782
Other assets	9,411		9,411	8,739		8,739
Total assets	413,210	5,518	407,692	385,047	6,394	378,652
Liabilities subject to market risk
Financial liabilities held for trading	1,631	1,631		1,163	1,163
Derivatives	1,967	1,472	495	2,499	2,125	374
Securities financing	15,320		15,320	10,352		10,352
Due to banks	4,320		4,320	2,329		2,329
Due to customers	279,126		279,126	256,186		256,186
Issued debt	74,072		74,072	74,542		74,542
Subordinated liabilities	4,946		4,946	6,613		6,613
Other liabilities	4,786		4,786	5,254		5,254
Total liabilities	386,167	3,103	383,064	358,939	3,288	355,651
Equity	27,043		27,043	26,108		26,108
Total liabilities and equity	413,210	3,103	410,107	385,047	3,288	381,759

Market risk management for

the trading book

Audited

Positions held with trading intent and hedges for

positions held with trading intent must be included in

the bank's trading book. The Central Trading Risk Policy

describes the positions included in the trading book and

the criteria for transferring risk and positions between

the trading and banking books. As part of its business

strategy, ABN AMRO facilitates client orders as principal

in key financial markets where our clients are active.

Market risk in the trading book is the risk of losses in

market value due to adverse market movements. The

following market risks are inherent in the trading book:

• Interest rate risk, arising from adverse changes in

interest rate risk curves and/or interest rate volatilities;

• Credit spread risk, arising from adverse changes in the

term structure of credit spreads and/or from changes

in the credit quality of debt securities or CDS

reference entities, with an impact on default

probabilities;

• Foreign exchange risk, arising from adverse changes

in FX spot and forward rates and/or FX volatility.

ABN AMRO has in place a detailed risk management

framework to identify, measure and control market risk

in the trading book. This risk management framework is

in line with the three lines of defence model and

provides assurance that the bank’s trading activities are

consistent with its client-focused business strategy and

strict risk focus. In accordance with the strategy, the

trading mandates and limits, which define the nature

and amount of the permitted transactions and risks, are

reviewed and approved annually, together with the

associated constraints. The limit utilisation is monitored

and discussed by the first and second line of defence on

a daily basis.


ABN AMRO	Annual Report 2025	97


≡	Risk, funding & capital	Risk management	Market risk in the trading book

Market risk measurement for

the trading book

Audited

ABN AMRO measures and manages market risk in the

trading book on a daily basis. The key metrics used are

economic capital, regulatory capital, value at risk (VaR),

stressed VaR (SVaR) and the incremental risk charge

(IRC), together with a wide array of stress and scenario

tests, sensitivity measures, concentration limits and

notional limits. These metrics are measured and

monitored on a daily basis. Appropriate limits are set at

bank level in the Risk Appetite Statement and at bank and

client-unit levels in the limit framework, in line with the

general risk principles in the Central Trading Risk Policy.

Metrics and models are managed, reviewed, assessed

and, if required, adjusted in a similar way as in the

banking book. Other important tools to ensure the

adequacy of the models, alongside the formal

validation and review of models, are the daily

explanation of risk reporting figures, periodic portfolio

reviews and regular back-testing.

Validation procedure

For all models, including market risk models, we have a

model risk policy in place. This policy requires model

assumptions and limitations to be documented and

independently validated by Model Validation. For material

changes, the regulator performs an on-site investigation

before such a model change is applied in production.

Economic capital

The calculation of economic capital for market risk in

the trading book is based on the daily VaR, SVaR and

IRC at a 99.9% confidence level.

Stress testing and scenario analysis

Stress testing and scenario analysis are designed to

focus specifically on the impact of tail events occurring

outside the VaR confidence interval. We perform daily

stress tests for large movements in risk factors. Scenario

analyses are also conducted frequently to evaluate the

impact of extreme market events that cover multiple

risk factors, and the results of these tests are monitored.

These scenarios can be based on historical or

hypothetical events, or on a combination of the two.

For each risk type, sensitivities are monitored against

limits. This includes all risk types mentioned above and

the basic risks in the trading portfolio. In addition, the

holding period is monitored as a measure of the

positions’ liquidity.

Valuation adjustments

For the trading book, we take into account adjustments

for counterparty credit risk on our clients (credit

valuation adjustment), ABN AMRO funding costs

(funding valuation adjustment) and ABN AMRO credit

risk (debt valuation adjustment).

Trading book positions are subject to prudent valuation

standards in accordance with regulatory requirements.

The prudent value is derived from IFRS fair value

accounting and includes additional value adjustments.

Review of 2025 results

Internal aggregated diversified and

undiversified VaR for all trading positions

Audited

ABN AMRO applies a diversified portfolio VaR approach

that takes into account the fact that returns across risk

factors may offset one another to a certain extent and

consequently reduce risk. As long as these returns are

not perfectly correlated to one another, VaR figures

based on a diversified portfolio approach will be lower

than if the figures are calculated using undiversified

VaR. Undiversified VaR means that the VaR figures

computed for the different risk factors are aggregated

without taking into account any offset across risk

factors, negating the potential for risk reduction. The

following graph shows the total one-day VaR at a 99%

confidence level (‘VaR diversified’) and aggregation of

the stand-alone risk factors (‘VaR undiversified’).

Internal aggregated diversified and undiversified VaR for all trading positions

Audited


			31 December 2025
(in millions)	Foreign exchange	Interest rate	Total undiversified VaR	Diversified VaR
VaR at last trading day of the period	0.4	3.0	3.4	3.1
Highest VaR	0.6	6.6	6.7	6.6
Lowest VaR	0.1	1.3	1.6	1.3
Average VaR	0.3	3.3	3.6	3.2

				31 December 2024
VaR at last trading day of the period	0.1	5.0	5.2	5.1
Highest VaR	0.4	7.3	7.5	7.3
Lowest VaR		1.3	1.4	1.3
Average VaR	0.1	4.0	4.1	4.0


ABN AMRO	Annual Report 2025	98


≡	Risk, funding & capital	Risk management	Market risk in the trading book

Diversified and undiversified VaR

(in millions)

The average 1-day VaR at a 99% confidence level

decreased from EUR 4.0 million in 2024 to

EUR 3.2 million in 2025. In the same period, the average

1-day undiversified VaR at a 99% confidence level fell

from EUR 4.1 million to EUR 3.6 million. Interest rates

remained the largest VaR component.

Regulatory capital

Market risk regulatory capital decreased to

EUR 129 million (31 December 2024: EUR 169 million)

while risk-weighted assets decreased to EUR 1.6 billion

(31 December 2024: EUR 2.1 billion). The decrease was

driven by all three components (VaR, SVaR and IRC).


ABN AMRO	Annual Report 2025	99


≡	Risk, funding & capital	Risk management	Market risk in the banking book

Market risk in the banking book



	This section provides information on: • Market risk management • Interest rate risk • Credit spread risk • Funding spread risk • Foreign exchange risk • Market risk in the banking book metrics

Market risk in the banking book arises when market

movements, for instance in interest rates, credit spreads

and foreign exchange rates, negatively affect the bank’s

value and earnings. The banking book positions are

intended to be held for the long term (or until maturity)

and capture all positions that are not held for trading

purposes.

Market risk management for

the banking book

Audited

ABN AMRO has a detailed risk management framework

in place to identify, measure and control market risk in

the banking book. This framework provides assurance

that the banking book activities remain consistent with

the bank’s strategy and are aligned with the defined risk

appetite. The Asset & Liability Committee (ALCO) has

delegated the day-to-day management to the Asset

and Liability Management and Treasury department

(ALM/Treasury). This department’s activities include the

execution of hedge transactions. ALM/Treasury forms

the first line of defence. Financial Risk Management acts

as the second line of defence.

The risk appetite is articulated in terms of supervisory

outlier test (SOT) on net interest Income (NII), SOT on

economic value of equity (EVE) and economic capital

(EC) for market risk in the banking book, and expresses

the maximum loss the bank is willing to accept. The risk

appetite is cascaded into a limit framework.

Interest rate risk in the banking book

Interest rate risk is the risk of losses in the economic

value of equity (EVE) or the bank’s net interest income

(NII) due to unfavourable yield curve developments. In

order to measure interest rate risk, models are used and

assumptions on client behaviour are made, most

importantly with respect to the maturity of savings and

the prepayment of mortgages. These assumptions

influence the anticipated interest cash flow pattern. The

profile of assets and liabilities on the balance sheet can

change if client behaviour changes. Therefore, interest

rate risk is actively managed in line with the risk

appetite.

The main sources of interest rate risk are:

• The maturity mismatch between assets and liabilities.

ABN AMRO provides mortgages and loans with fixed

rates. These assets are funded mainly by non-

maturing deposits and wholesale funding which

typically have a shorter average interest maturity than

the assets;

• Client behaviour, which determines the maturity

profile of certain products. As we use models to

predict this behaviour, we are exposed to model risk.

ABN AMRO uses a combination of portfolio (macro)

hedges and specific asset or liability (micro) hedges to

manage the interest rate sensitivity in the banking book

and keep it in line with the bank’s strategy and risk

appetite. Micro hedges are used to swap fixed rate

funding transactions and fixed interest rate investments

in the liquidity buffer for floating interest rate positions.

In addition, macro hedging is applied in order to align

with the bank’s strategy to contribute to a stable NII

while protecting the economic value of equity.

Key assumptions for modelling client behaviour

From an interest rate risk perspective, the following

aspects of client behaviour are the most important:

• Client behaviour with respect to early redemption of

residential mortgages. This has a significant impact on

the average interest maturity of the mortgage

portfolio. Clients have the option to fully or partially

prepay mortgages before maturity. Prepayments may

be triggered by, for example, relocation, redemption

or curtailment. An important driver of prepayments is

the interest rate incentive, i.e. the difference between

a client’s current mortgage rate and prevailing

mortgage rates. Future mortgage rates are simulated

using a Monte Carlo approach. In addition to the

interest rate incentive, other drivers such as loan age,

seasonality and house price developments are taken

into account;

• Client acceptance of the residential mortgage volume

offered and the deviation between the offered rate

and the actual coupon;

• Client behaviour with respect to non-maturing

deposits that are callable on demand. The volume

migrating to term deposits is subject to rate changes.

Future client rates for savings accounts are modelled

using a replicating portfolio model. Modelled client

rates depend on current or lagged yield curves and

funding costs. A maximum maturity of 10 years is

assumed. The resulting duration depends on product

type and client behaviour.


ABN AMRO	Annual Report 2025	100


≡	Risk, funding & capital	Risk management	Market risk in the banking book

The market risk in the banking book metrics are derived

from behavioural models which rely on assumptions

based on extensive research and historical client

behaviour data. The models undergo independent

validation and are approved by the mandated risk

committees. Models are periodically assessed to

determine whether they behave appropriately and are

statistically sound; if required, they are adjusted.

Risk measurement for interest rate risk

Interest rate risk is measured by NII-at-Risk and various

economic value measures such as the present value

change of one basis point shock (PV01) and the EVE-at-

Risk. To ensure a comprehensive approach to risk

management and identify potential weaknesses, the

metrics are complemented by stress testing and

scenario analysis. A combination of market and product

floors is applied. These floors are reviewed periodically.

For management purposes, the interest rate risk

position is monitored by the Asset & Liability Committee

(ALCO) on a monthly basis. The above metrics are also

regularly reported to the Executive Board.

Credit spread risk in the banking book

Credit spread risk refers to the risk of financial losses

resulting from unfavourable movements in credit

spreads within the balance sheet. From a value

perspective, credit spread risk is primarily associated

with products valued at fair value. It is quantified as the

impact on economic value of a one basis point change

in credit spreads (CS01). The primary sources of this risk

are bonds held for liquidity purposes and wholesale

funding.

From an earnings perspective, credit spread risk in the

banking book (CSRBB) impacts the spreads at which

new positions are originated, such as during

reinvestments. This risk is assessed using a net interest

income (NII) at risk approach, where origination spreads

are stressed and compared to a base scenario. The main

sources of this earnings-based risk are loans and

savings.

Foreign exchange risk

Foreign exchange (FX) risk is the risk arising from

unfavourable movements in FX spot and forward rates

and/or FX volatility. It is managed within the bank by

ALM/Treasury. As a general rule, foreign exchange risk

is hedged by using cross-currency swaps to swap the

exposure in foreign currency to euros. If, for operational

reasons, it is inefficient to hedge exposures in foreign

currencies, an open currency position (OCP) remains.

This is measured by the aggregated net position per

foreign currency.

Economic capital

Economic capital for market risk in the banking book is

calculated using a parametric Monte Carlo simulation

model that determines the economic capital needed to

absorb losses resulting from unfavourable movements

in interest rates, client behaviour for mortgages and

non-maturing deposits, volatility, credit spreads and

foreign exchange rates.

Market risk in the banking book metrics

Interest rate risk

Audited


(in millions)	31 December 2025	31 December 2024
NII impact from an instantaneous increase in interest rates of 200bps	683	277
NII impact from an instantaneous decrease in interest rates of 200bps	-599	-106
EVE impact from an instantaneous increase in interest rates of 200bps	-2,132	-1,916
EVE impact from an instantaneous decrease in interest rates of 200bps	215	210

NII-at-Risk is the difference in NII between a base

scenario and an alternative scenario observed over a

1-year horizon. This is calculated for a 200bps

instantaneous increase in interest rates (parallel move

up) and for a 200bps instantaneous decrease in interest

rates (parallel move down). NII-at-Risk includes all

expected cash flows, including commercial margins

and other spread components, from all interest rate-

sensitive assets, liabilities and off-balance sheet items in

the banking book. NII-at-Risk assumes a constant

balance sheet.

As at 31 December 2025, the NII-at-Risk was

EUR 683 million for the scenario in which there is an

instantaneous increase in interest rates of 200bps and

EUR 599 million negative for the scenario in which there

is an instantaneous decrease in interest rates of 200bps.

The change in NII-at-Risk is mainly attributable to

increased loan volumes and lower fixed-term deposit

volumes.


ABN AMRO	Annual Report 2025	101


≡	Risk, funding & capital	Risk management	Market risk in the banking book

EVE-at-Risk is the loss in economic value of equity as

a result of various yield curve shocks. This is also

calculated for a 200bps instantaneous increase (parallel

move up) in interest rates and for a 200bps

instantaneous decrease (parallel move down) in interest

rates. The impact is calculated for cash flows from all

interest-bearing assets, liabilities and off-balance sheet

items in the banking book. An assumption of a run-off

balance sheet is made, where banking book positions

amortise and are not replaced by new business. The

projected cash flows include commercial margins and

other spread components and are discounted at the

risk-free rate.

The EVE-at-Risk scenario with the highest impact at

year-end 2025 remains the scenario in which interest

rates increase by 200bps instantaneously. We see a

higher EVE impact in both the upward and downward

scenarios, as the duration of equity has increased

slightly since year-end 2024.

Open currency position

Audited

The OCP is monitored regularly and limits apply at a

local and aggregate level. USD is the largest non-EUR

exposure for assets and liabilities. The total OCP

showed a slight decrease in 2025 compared with the

previous year.


	31 December 2025	31 December 2024
Total OCP (long, in EUR million)	135	151
OCP as % total capital	0.5%	0.5%
P&L Sensitivity to 100bps increase in largest non-EUR exposure (USD, in EUR million)	0.7	0.6


ABN AMRO	Annual Report 2025	102


≡	Risk, funding & capital	Risk management	Liquidity risk & funding

Liquidity risk & funding



	This section provides information on: • Liquidity risk management • Funding strategy • Risk management approach • Going-concern management • Contingency risk management

Liquidity risk is the risk that actual and potential

payments or collateral posting obligations cannot be

met on a timely basis, or only at excessive costs. There

are two types of liquidity risk:

• Funding liquidity risk is the risk of not being able to

accommodate expected and unexpected cash

outflows and collateral needs because insufficient

cash is available. This can eventually affect the bank’s

daily operations and its financial condition;

• Market liquidity risk is the risk that the bank cannot

liquidate instruments, mainly from its liquidity buffer,

in a timely manner at a reasonable market price due

to insufficient market depth (insufficient supply and

demand) or market disruption. Market liquidity risk

includes the sensitivity in liquidity value due to

changes in the applicable haircuts and market value.

It also concerns uncertainty about the time that would

be needed to liquidate assets in periods of stress.

Framework

Liquidity risk management

We have in place a liquidity risk management

framework that helps us maintain a moderate risk

profile and that safeguards the bank’s reputation from a

liquidity perspective. We aim to meet regulatory

requirements and payment obligations at a reasonable

cost, even under severely adverse conditions. A set of

liquidity risk metrics and limits help manage the

liquidity position. We target a prudent liquidity profile

through a smooth long-term maturity profile, managing

dependence on wholesale funding and holding a solid

liquidity buffer in key currencies. The liquidity position is

monitored on a daily basis.

Funding strategy

Our main source of funding is our strong client deposit

base. The remainder is largely raised through various

types of wholesale funding instruments. Our wholesale

funding strategy targets a stable and diversified funding

mix that takes into account the nature of our loan book

and supports the bank’s commercial activities. This

strategy aims to optimise the bank’s funding sources in

order to maintain market access and the targeted

funding position with a diverse, stable and cost-efficient

funding base. The maturity profile of wholesale funding

is optimised to avoid a concentration of outflows and to

control repricing risks. The funding strategy takes into

account the following guidelines:

• Maintain market access by diversifying funding

sources in different funding markets (Europe, the US

and the Asia-Pacific region).

• Continually monitor attractive funding opportunities

and maintain strong relationships with the investor

base through active marketing.

• Optimise the planning and execution of funding in

different market windows and currencies.

• Optimise funding costs within the targets set for

volumes and manage credit curves and maturities in

different instruments and currencies.

• Optimise the balance between public benchmark

deals, club deals and private placements.

Risk management approach

Audited

The natural maturity mismatch between our loan book

and funding portfolio requires liquidity risk

management. As we consider maturity transformation

to be an integral part of the business model, we closely

monitor our liquidity position and the resulting risks. We

hold a portfolio of highly liquid assets that can swiftly

be converted into cash in the event of unforeseen

market disruptions, thus allowing us to meet payment

and collateral obligations at all times. Funding and

liquidity risk are managed centrally within ALM/

Treasury. We incorporate liquidity costs into the pricing

of our day-to day business activities. When managing

funding and liquidity risk, a clear distinction is made

between going-concern and contingency risk

management.

Going-concern management

The most important metrics for going-concern risk

management and the management of the day-to-day

liquidity position within specified limits are:

• Stress testing: In monthly and ad hoc stress tests we

evaluate the impact of cash inflows and outflows

under various stress scenarios, based on historic stress

events. Market-wide and bank-specific stress

scenarios are defined and analysed. The goal of stress

testing is twofold. Firstly, it helps us to review our risk

management framework, i.e. the liquidity buffer size,

risk appetite and risk limits. Secondly, it allows us to

identify ways to reduce outflows in times of crisis.

• Liquidity coverage ratio (LCR): The LCR is used to

assess the short-term resilience of the liquidity

position and ensure sufficient high-quality liquid


ABN AMRO	Annual Report 2025	103


≡	Risk, funding & capital	Risk management	Liquidity risk & funding

assets to survive a significant stress scenario lasting

30 calendar days.

• Survival period: This is the period the liquidity

position is expected to remain positive in an internally

developed stress scenario in which wholesale funding

markets deteriorate and clients withdraw a material

proportion of their deposits.

• Net stable funding ratio (NSFR): This ratio is used to

assess resilience over a longer time horizon. The NSFR

requires banks to hold sufficient stable funding to

cover the duration of their long-term assets on an

ongoing basis.

• Loan-to-Deposit ratio (LtD): The LtD ratio measures

the relationship between the loan book (loans and

advances customers) and deposits from clients (due

to customers), and includes all client-related loans

and deposits. The ratio gives an indication of our

dependence on wholesale funding for financing

client loans.

Contingency risk management

Contingency risk management aims to ensure that, in

the event of a bank-specific or general market stress

event, the bank is able to generate sufficient liquidity to

withstand a short or long-term liquidity crisis.

Contingency risk management entails:

• Contingency Funding Plan: This plan sets out the

guidelines and responsibilities for addressing possible

liquidity shortfalls in emergency situations. This only

comes into effect if the liquidity position is threatened

or if there are strong indications that liquidity stress is

imminent. The Contingency Funding Plan is aligned

with the Recovery Plan, as required by the regulators.

It aims to manage the liquidity position without

unnecessarily jeopardising commercial activities,

while limiting excessive funding costs in severe

market circumstances.

• Collateral posting in the event of a rating

downgrade: Credit rating downgrades may result in

increased collateral requirements. We monitor these

potential additional collateral postings in our liquidity

risk management framework. Our collateral

capabilities are set out in our collateral management

framework.

• Collateral posting to guarantee access to critical

financial market infrastructures (FMI): Access to

critical FMI is essential for conducting our business

and collateral requirements may increase in times of

stress. We monitor these potential additional

collateral postings in our liquidity risk management

framework.

• Liquidity buffer: Treasury manages our liquidity

buffer, of which the liquidity portfolio comprises a

substantial part. This portfolio should at all times be

highly liquid to accommodate liquidity outflows

during stress. The buffer consists of unencumbered,

high-quality liquid assets, including government

bonds, retained covered bonds and cash.

Environmental, social and governance bonds

For our liquidity buffer we target investments in bonds

whose proceeds are allocated in line with the

International Capital Market Association (ICMA) Green

Bond Principles, the Social Bond Principles or a

combination of the two. Inclusion of such bonds in the

liquidity portfolio is subject to availability of ESG

reporting, a thorough project selection process and

sound management of proceeds. To preserve the

portfolio’s high quality and liquidity value, these bonds

must also meet the high-quality liquid assets (HQLA)

criteria of the European Banking Authority (EBA). By

actively investing in the euro-denominated ESG bond

market, we aim to support the growth of this market.

We are also an issuer of green bonds. The Green Bonds

Framework specifies the green assets to which we

allocate the issuance proceeds and how those assets

are EU Taxonomy aligned. Under the framework we can

issue green bonds with the EU Green Bond label and/or

ICMA green bond label. The Green Bonds Framework

also describes how we allocate the issue proceeds to

eligible assets, evaluate and select eligible assets,

obtain independent assurance on the allocation of

proceeds to eligible green assets, and comply with

external reporting requirements. More information is

available on our website.

Liquidity risk

The objective of our liquidity risk management is to

manage the liquidity position and to comply at all times

with internal, regulatory and other relevant liquidity

requirements. Various indicators are used to measure

the liquidity objectives.


ABN AMRO	Annual Report 2025	104


≡	Risk, funding & capital	Risk management	Liquidity risk & funding

Liquidity risk management

Liquidity risk indicators


	31 December 2025	31 December 2024
Available liquidity buffer (in billions)¹	130.4	112.2
Survival period (moderate stress)	> 6 months	> 6 months
LCR²	153%	138%
NSFR³	141%	137%
Loan-to-Deposit ratio	92%	97%
1. The mandatory cash reserve with the central bank has been deducted from the cash and central bank deposits in the liquidity buffer.
2. Consolidated LCR based on a 12-month rolling average.
3. Consolidated NSFR reflects a fixed point in time.

The survival period is an internally developed metric

which reflects the period that the liquidity position is

expected to remain positive in an internally developed

moderate stress scenario. This scenario assumes

wholesale funding markets deteriorate and clients

withdraw part of their deposits.

The survival period was consistently above six months in

2025. The liquidity coverage ratio (LCR) and the net

stable funding ratio (NSFR) both remained above 100%

throughout 2025. The loan-to-deposit (LtD) ratio

decreased to 92%, mainly as a result of the

consolidation of HAL deposits in the statement of

financial position as of 1 July 2025.

Liquidity buffer composition

Audited


	31 December 2025			31 December 2024
	Liquidity buffer		LCR eligible	Liquidity buffer		LCR eligible
(in billions, liquidity value)		Level 1	Level 2		Level 1	Level 2
Cash & central bank deposits¹	47.2	47.2		42.3	42.3
Government bonds	37.4	36.7	1.5	35.9	34.4	2.1
Supranational & Agency bonds	12.9	13.4		10.5	10.8
Covered bonds	9.6	9.2	0.2	5.9	5.6
Retained covered bonds	20.6			17.4
Other	2.7		1.7	0.3		0.2
Total liquidity buffer	130.4	106.5	3.4	112.2	93.1	2.3
- of which ESG bonds²	5.4	5.6		5.1	4.9
1. The mandatory cash reserve with the central bank has been deducted from the cash and central bank deposits in the liquidity buffer.
2. ESG bonds are bonds whose proceeds are invested in line with the International Capital Market Association Green Bond Principles, the Social Bond Principles or a combination of the two. Inclusion of such bonds in our ESG portfolio is subject to the availability of ESG reporting, a thorough project selection process and sound management of proceeds. To preserve the portfolios’ high quality and liquidity, these bonds must also meet the high quality liquid assets criteria of the European Banking Authority.

The liquidity buffer increased to EUR 130.4 billion as at

31 December 2025 (31 December 2024:

EUR 112.2 billion) and consisted largely of cash and

deposits at central banks, government bonds and

securities. Most of the securities in the liquidity buffer,

with the exception of retained covered bonds, qualify

for the LCR. The liquidity buffer faces haircuts based on

the market value. These haircuts are used to determine

the liquidity value. Haircuts may vary between the

liquidity buffer and the LCR eligible buffer because the

internal assessment of the liquidity buffer may deviate

from the LCR definition.

ESG bond holdings increased by 6% in 2025 and

amounted to EUR 5.4 billion in liquidity value at year-

end (31 December 2024: EUR 5.1 billion), reflecting 7%

of total bonds in the liquidity buffer.

The following table shows the breakdown per currency

in the liquidity buffer. The currency composition reflects

the composition of the balance sheet, which mainly

consists of EUR and USD exposures.


ABN AMRO	Annual Report 2025	105


≡	Risk, funding & capital	Risk management	Liquidity risk & funding

Liquidity buffer - currency diversification

Audited


		31 December 2025		31 December 2024
	Liquidity value (in billions)	Percentage of total	Liquidity value (in billions)	Percentage of total
EUR	115.9	88.9%	98.3	87.6%
USD	10.4	8.0%	9.9	8.8%
JPY	1.7	1.3%	2.4	2.2%
GBP	0.6	0.4%	0.2	0.2%
SGD	1.6	1.3%	1.4	1.2%
Other	0.2	0.2%		0.0%
Total	130.4	100.0%	112.2	100.0%

The following table shows the monthly average volume

of individual components within the liquidity buffer.

Liquidity buffer composition - monthly average

Audited


(in billions, liquidity value)	2025	2024
Cash & central bank deposits¹	42.9	39.0
Government bonds	35.9	31.4
Supranational & Agency bonds	11.2	9.4
Covered bonds	6.8	5.7
Retained covered bonds	19.3	17.6
Other	3.8	2.2
Total	120.0	105.3
1. The mandatory cash reserve with the central bank has been deducted from the cash and central bank deposits in the liquidity buffer.

Funding

Liability and equity breakdown

Audited

Client deposits are our main source of funding,

complemented by a well-diversified book of wholesale

funding. The following table shows the liability and

equity breakdown for the consolidated statement of

financial position.

Liability and equity breakdown

Audited


(in billions)	31 December 2025	31 December 2024
Due to customers	279.1	256.2
Issued debt & Subordinated liabilities	79.0	81.2
Due to banks	4.3	2.3
Securities financing	15.3	10.4
Equity	27.0	26.1
Other	8.4	8.9
Total	413.2	385.0

The following table shows the development of client

deposits per segment in 2025. The main driver of the

increase in deposit volumes is the consolidation of

the deposits of HAL in the statement of financial

position as of 1 July 2025.


ABN AMRO	Annual Report 2025	106


≡	Risk, funding & capital	Risk management	Liquidity risk & funding

Developments in client deposits by segment

(in billions)

Available wholesale instruments

Audited

A key goal of the funding strategy is to diversify funding

sources. Our funding programmes allow us to issue

various instruments in different currencies and markets,

enabling diversification in our investor base.

The following table shows a breakdown of total

wholesale instruments.

Overview of outstanding wholesale instruments

Audited


(in millions)	31 December 2025		31 December 2024
Commercial Paper/Certificates of Deposit		11,773		17,922
Covered bonds	26,035		23,921
Secured funding (long-term)		26,035		23,921
Senior preferred	18,638		13,373
- of which ESG bonds¹	5,415		3,947
Senior non-preferred	17,625		19,327
- of which ESG bonds¹	7,393		6,620
Unsecured funding (long-term)		36,264		32,700
Total issued debt		74,072		74,542
Subordinated liabilities		4,946		6,613
Other long-term funding ^{2, 3}		717		723
Wholesale funding		79,735		81,879
AT1 capital securities (classified as IFRS equity)		3,233		3,475
Total wholesale instruments ⁴		82,967		85,353
- of which matures within one year		20,319		29,421
1. Our Green Bond Framework comprises a set of criteria for the issuance of green bonds, including how we allocate the issue proceeds from green bonds to eligible assets, and independent assurance on the allocation of proceeds to eligible green assets. Green bonds have been issued since 2015, with a focus on sustainable real estate and renewable energy, and enable investors to invest in, for example, energy efficiency through residential mortgages.
2. Includes funding obtained apart from our long-term programmes and consists mainly of unsecured funding.
3. Funding with either the European Investment Bank and the Dutch State Treasury Agency as counterparty (recorded in due to banks and due to customers respectively) has been included in other long-term funding.
4. Includes FX effects, fair value adjustments and interest movements.

Total wholesale instruments fell to EUR 83.0 billion as at

31 December 2025 (31 December 2024:

EUR 85.4 billion). This mainly reflects a decrease in

short-term funding from seasonal balance-sheet

developments, which was partly offset by an increase in

long-term wholesale funding. The increase in long-term

funding reflects a rise in covered bond and senior

preferred funding, which was partly offset by a decline

in senior non-preferred and subordinated debt.

Total ESG bonds outstanding increased by 21% in 2025

to EUR 12.8 billion at year-end (31 December 2024:

EUR 10.6 billion), which is 35% of total unsecured long

term funding and 17% of total issued debt.


ABN AMRO	Annual Report 2025	107


≡	Risk, funding & capital	Risk management	Liquidity risk & funding

Wholesale issuance in 2025

Audited

Total long-term wholesale instruments issued in 2025

amounted to EUR 16.4 billion, which included

EUR 3.0 billion in covered bonds, EUR 11.8 billion in

senior preferred funding, EUR 0.9 billion in senior non-

preferred funding and EUR 0.8 billion in AT1 capital

securities. Of this EUR 16.4 billion, EUR 5.1 billion was

non-EUR denominated and consisted mainly of USD

and GBP issuances (2024: EUR 2.2 billion).

In February 2025, we issued our inaugural green bond

under the new European Green Bond Standard (EuGBS),

making ABN AMRO the first financial institution to issue

a European Green Bond (EuGB). In 2025, we issued four

green bonds in total under the EuGBS, in senior

preferred and senior non-preferred format, in EUR and

GBP. The issuance activities in 2025 received several

awards. ABN AMRO was named ‘Financial Issuer of the

Year’ by IFR and ‘Best FIG Issuer’ by CMD Portal, and

received the award for ‘Financial Institution ESG bond of

the year’ from Global Capital.

Wholesale instruments raised

in 2025 and 2024

(notional amounts at issuance, in billions)

Maturity calendar for wholesale instruments

Audited


									31 December 2025
(notional amounts, in billions)		2026	2027	2028	2029	2030	2031	2032	2033	2034	2035	≥ 2036	Total
Covered bonds		1.6	1.9	2.1	1.9	1.9	3.1	2.3	2.3	0.9	2.3	8.8	29.1
Senior preferred		3.6	4.3	3.1	2.4	2.3	1.7	0.8			0.1	0.4	18.6
Senior non-preferred		2.1	3.1	4.1	1.0	2.1		1.8	1.0	2.7	0.1		17.9
Subordinated liabilities		0.9	1.5	0.8			1.9						5.0
AT1 capital securities (classified as IFRS equity)			1.0				0.8		0.8	0.8			3.3
Other long-term funding¹		0.3	0.2			0.3							0.7
Total wholesale instruments		8.4	11.9	10.1	5.3	6.5	7.4	4.8	4.1	4.4	2.4	9.2	74.5

									31 December 2024
	2025	2026	2027	2028	2029	2030	2031	2032	2033	2034	≥ 2035		Total
Total wholesale instruments	11.4	8.9	9.3	5.9	1.7	3.5	6.8	4.0	3.3	4.5	10.9		70.2
1. Includes funding obtained apart from our long-term programmes and consists mainly of unsecured funding.

We target a maturity profile in which redemptions of

funding instruments are well spread over time. The

average remaining maturity of outstanding wholesale

instruments decreased to 5.0 years at year-end 2025

(5.3 years at year-end 2024). The average remaining

maturity of newly issued wholesale instruments

decreased to 3.6 years at year-end 2025

(year-end 2024: 5.4 years).

The maturity calendar assumes redemption on the

earliest possible call date or the legal maturity date.

That does not imply that the instruments will be called

at the earliest possible call date. Early redemption of

senior non-preferred instruments, subordinated

liabilities and AT1 capital securities is subject to

regulatory approval.


ABN AMRO	Annual Report 2025	108


≡	Risk, funding & capital	Risk management	Business risk

Business risk

Business risk is the risk that earnings and franchise value

(i.e. value of the business as a whole) decline as a result

of the changes in business volumes, margins, income

and/or expenses. Such an impact can stem from

internal and/or external factors that are not covered by

the other risk types. The short-term viability and

adaptability of the strategy and business model are

essential to mitigate the business risk and create

sustainable long-term value.

ABN AMRO manages business risk by seeking to

minimise the effect of expected and unexpected

internal and/or external developments that can lead to:

• uncertainty in present or future business earnings

and/or franchise value;

• changes in the drivers of business earnings such as

uncertainty in volumes, margins, fee and commission

rates and/or business expenses.

Factors impacting business risk

We consider the short, medium and long-term horizon

uncertainties that can affect the expected business

earnings. Various internal and external developments,

scenarios and market movements are considered:

• Key macroeconomic variables relevant for the bank in

line with our main geographies. Examples include

gross domestic product (GDP), unemployment rates,

interest rates, inflation rates and house price indices.

• The competitive landscape and how it is likely to

evolve, considering the activities of the bank’s peers

and other relevant competitors.

• Expected growth in target markets and activities of

key competitors (banks and non-banks).

• Overall trends in the market that may have an effect

on performance and profitability. This should include,

as a minimum, the regulatory, technological and

societal/demographic trends.

• Contamination effects from other risk types or indirect

risks from the clients’ supply chain. For more

information on impact of climate change, please see

Effect of climate risk on traditional risk types -

Business risk.

Business risk appetite

The thresholds are set annually based on the expected

one-year profit horizon forming the basis for a

quantitative Red, Amber or Green (RAG) status. The

qualitative RAG status is based on expert judgements,

taking into account elements such as pressure from

external factors and internal strategic objectives.

Monitoring and response

The bank continually monitors the business risk drivers

and mitigates sensitivity to these drivers through

discussions at senior management and board level. This

ensures effective and timely responses. ABN AMRO’s

business risk management framework is supported by

the three lines of defence model. Business risk is also

accounted for in the capital buffer that is meant to

safeguard our capital position if extreme events occur.

Components of business risk

We consider business risk to have two components:

• Strategic risk: the risk of internal and external events

that may have an effect on ABN AMRO achieving its

objectives and strategic goals. The strategy of the

bank incorporates mitigation of expected and

unexpected events and changes in business risk

drivers. Regular review of the bank strategy ensures

alignment with developments in business risk drivers.

For more information about the resilience of our

business model and strategy to ESG risks, please see

Current and anticipated effects of material matters-

Effect on strategy and business model.

• Strategic equity investment risk: the risk of deviation

in the value of strategic equity investments. These

investments are not fully consolidated in the bank’s

financial accounts, but are represented as an equity

investment in the statement of financial position.

Investments related to clients and involving unlisted

private equity or held for trading purposes are not

considered to be strategic equity investments.


ABN AMRO	Annual Report 2025	109


≡	Risk, funding & capital	Risk management	Business risk

Economic capital for business risk

The economic capital (EC) for business risk reflects the

maximum downward deviation of actual versus

expected net operating profit in one year, excluding any

impact already covered by other risk types (e.g.

impairments for credit risk).

The model combines EC based on forward looking

scenarios with EC based on historical revenue data. The

model determines the sensitivity of client units’ income

to macroeconomic variables and sector indicators. This

sensitivity is used to determine the volatility of income

and any correlation between client units. EC is

calculated for both approaches, and the greater of the

two is used. The model is sensitive to the projections for

the negative and adverse scenarios and their

probabilities.

Economic capital for strategic equity investment risk is

also calculated, referring to the maximum downward

deviation of a strategic equity investment's economic

value from the current book value.


ABN AMRO	Annual Report 2025	110


≡	Risk, funding & capital	Risk management	Non-financial risk

Non-financial risk



	This section provides information on: • Non-financial risk management • Specific non-financial risk areas • Non-financial risk measurement • Review of 2025 results

Non-financial risk management

Non-financial risks (NFRs) refer to the category of risks

that could result in loss due to inadequate or failed

internal processes, people and systems or due to

external events. This definition is in line with the

definition applied by the Basel Committee on Banking

Supervision (BCBS).

ABN AMRO has a holistic approach to managing

non‑financial risks (NFRs), providing the business with a

clear and fair view on these risks, their relevance to the

bank and how they should be managed. For this

purpose, ABN AMRO has in place a framework that

enables non-financial risks to be managed with a focus

on the key risks.

Non-financial risk framework


	Continuous risk dialogue			In control?
Forward looking	. Assessments
• Scope • Assess • Respond • Act	. Assessments				Backward looking
		Process		Learning loop	• Monitoring controls & testing • Root cause analysis • Event learning
Forward looking / Backward looking	Triggers
• Continuous risk dialogue • Periodically driven • Event-driven • Alarm bells	Triggers

	Enhance controls	Risk response Action	Adjust process
	. Adjust product	Risk response Action	. Adjust policy
Boundaries: policies/procedures, taxonomy, governance (three lines of defence), data model
Professionals executing the framework


ABN AMRO	Annual Report 2025	111


≡	Risk, funding & capital	Risk management	Non-financial risk

Framework for non-financial risk

management

We deploy our NFR framework to make sure that we

stay in control of all the bank’s NFRs and adhere to all

existing laws and regulations of relevance. ABN AMRO’s

NFR framework may be partly described as a toolkit of

assessments, alarm bells and feedback. But while tools

are consequently at the heart of the NFR framework,

they are not enough in themselves. We rely on

professionals to execute the NFR framework, especially

in a continuous dialogue about risks. The activities

performed in executing the NFR framework are

contextualised by boundaries established through a

range of NFR policies and procedures; a taxonomy of

material risks, roles and responsibilities for professionals

working according to the ‘three lines of defence model’

practices and behaviours, and data management

systems.

Assessments are conducted to identify non-financial

risks and assess risk exposures. They are performed

either periodically or when concerns arise as a result of,

for example, changes in internal processes or external

developments that pose risks to strategic priorities. We

also rely on alarm bells from internal and external

sources, such as the effectiveness of the internal control

environment, the status of key risk indicators (KRIs)

relative to established risk thresholds, and complaints

from clients, to understand what actions are necessary

to continue maturing the efficacy of the NFR framework.

Despite preventive measures being in place, incidents

and operational losses are inherent to our business.

ABN AMRO tracks and analyses these events as part of

feedback mechanisms that enable us to learn from

operational failures and use them as early warnings. We

also scan external developments and identify emerging

risks for further assessment.

During our continuous risk dialogues, risk professionals

from the first (1LoD) and second (2LoD) lines of defence

evaluate the level of threat from NFRs and determine

appropriate responses to keep control. Our risk

professionals combine relevant internal data (e.g. scale

of changes to processes), external data (e.g. climate

science) and professional judgements to arrive at a

holistic risk view. Once NFR exposures have been

agreed by 1LoD and 2LoD and evaluated against risk

thresholds, an appropriate risk response can be

implemented. Common risk responses include

enhancing controls by expanding coverage to capture

new and evolving areas of risks, as well as adjusting

processes to reduce opportunities for errors.

The results of the risk dialogues executed in line with

the NFR framework are provided in risk reports at

various levels within the bank, up to the Executive Board

and Supervisory Board. This enables senior

management to steer the bank’s overall profile of NFRs.

Specific non-financial risk areas

In 2025, ABN AMRO defined 11 non-financial sub-risk

types (see below), as well as an overall NFR generic

category, to provide a holistic profile of non-financial

risks. The bank has in place dedicated functional areas

with specific knowledge and expertise to deal with each

material type of NFR. The NFR risk category and

individual non-financial risk types are governed by the

broader enterprise risk management approach to

ensure that structured, coherent, systematic and

consistent risk management processes are applied

throughout the bank’s three lines of defence.

Starting in 2026, the focus of NFR management will be

recalibrated as per our revised risk taxonomy. Please

refer to the Risk management framework section for

more information on our risk taxonomy.


Non-financial risk types
Compliance risk	Data risk		ICT risk		Third-party and outsourcing risk
Change risk	Model risk		Fraud risk		Legal risk
HR risk		Tax risk		Behavioural risk


ABN AMRO	Annual Report 2025	112


≡	Risk, funding & capital	Risk management	Non-financial risk

Compliance risk

Compliance risk is defined as the risk of failure to

comply with laws and regulations, self-regulatory

organisational standards, company values and business

principles, codes of conduct or generally accepted

market standards applicable to ABN AMRO’s services

and activities. Non-compliance can result in legal or

regulatory sanctions, material financial loss and/or harm

to ABN AMRO’s reputation.

ABN AMRO must continuously live up to regulatory

expectations and obligations. The bank is expected to

act as a gatekeeper in detecting financial and economic

crime, to fulfil its obligations arising from its duty of care

towards clients, to preserve market integrity, and to

address and incorporate key topics such as privacy and

sustainability in the bank’s strategy and compliance

programmes.

Failing to meet these expectations could lead to

reputational damage, fines, claims and adverse changes

in ABN AMRO’s income, costs or capital base, all of

which could endanger its long-term goals. The main

areas with a risk of non-compliance with regulations are

anti-money laundering, counter‑terrorism financing, the

duty of care to the bank’s clients and privacy risk.

Compliance programmes and the Compliance function

remain the foundation of effective compliance with

rules and regulations within ABN AMRO. They are

essential for ABN AMRO’s licence to operate, for

enabling and supporting values-led business and for

protecting the bank’s integrity and reputation. In 2025,

the Compliance function focused on advising on the

AML Program, supporting improvements in transaction

monitoring, guiding high-risk client file remediation,

addressing data protection risks, and enhancing client

protection to ensure regulatory compliance.

Data risk

Throughout 2025, ABN AMRO demonstrated strong

commitment to advancing its data strategy by maturing

the Federated Data Governance Model and enhancing

data management capabilities, ensuring clear

accountability and supporting its ambition to become a

data-driven bank. The bank has made progress in

strengthening its data risk and controls framework,

contributing to a more robust foundation for risk

management and regulatory compliance. The growing

use of advanced analytics and AI applications, although

at an early stage, has already begun to demonstrate its

potential in driving informed business decisions and

improving efficiency in supporting processes. Despite

these improvements, some challenges remain.

Remedying deficiencies in risk reporting capabilities

and related information systems, including addressing

weak risk data aggregation and risk reporting

frameworks and IT infrastructure gaps, and ensuring

accurate risk data, remains a priority. These areas are

crucial for further strengthening decision-making and

strategic planning. Looking ahead, ABN AMRO is

committed to embedding and enhancing its data

capabilities to support its strategic vision for 2026 and

beyond, ensuring its continued focus on leveraging data

for commercial success, operational excellence and

effective risk management.

ICT risk

Information remains one of ABN AMRO’s most critical

assets. As digitalisation continues to accelerate, the

bank maintains a strong focus on the resilience and

security of its IT landscape. Our systems operate within

complex infrastructures that connect internal

environments to external networks, making proactive

risk management essential.

In 2025, we further strengthened our ICT risk profile by

means of a targeted emphasis on key risk indicators and

close collaboration between the business, IT and

relevant stakeholders. This integrated approach has

enabled us to identify and address areas with room for

improvement while maintaining high standards for the

protection of financial and client data.

We take ICT risks seriously and apply stringent

requirements to ensure the confidentiality, integrity and

availability of our systems and information. In line with

the Digital Operational Resilience Act (DORA), we have

intensified our engagement with third-party vendors to

ensure they meet our security expectations and do not

pose an undue risk to our operations or client data. This

includes embedding resilience criteria into vendor

management and fostering a culture of shared

responsibility.

Looking forward, we remain committed to further

refining our risk and control framework in response to

an increasingly dynamic threat landscape and evolving

regulatory requirements. By continuously adapting to

emerging risks and external developments, we aim to

ensure that our digital services remain secure, resilient

and compliant. In this context, we also maintain open

and transparent dialogues with supervisory authorities,

fostering mutual understanding and enabling alignment

on expectations.

Third-party and outsourcing risk

Adequate risk management of third-party and

outsourcing risks ensures that specific risks related to

the external and intragroup outsourcing of IT platforms,

software and business processes are properly managed.

Additionally, third-party risk management (TPRM)


ABN AMRO	Annual Report 2025	113


≡	Risk, funding & capital	Risk management	Non-financial risk

includes a framework of more generic risks and

mitigating measures related to external third parties.

In 2025, ABN AMRO made significant progress in

enhancing its management of third-party and

outsourcing risks, building on its commitment to

maintain robust controls aligned with regulatory

standards and industry best practices. Recognising the

importance of maintaining efficient and effective

oversight of supplier contracts, the bank introduced a

centralised contract management (CM) capability within

Procurement to further strengthen its approach to third-

party risk management.

This development reflects the bank’s proactive stance in

adapting to evolving regulatory requirements, such as

the European Banking Authority (EBA) guidelines on

outsourcing arrangements, the Digital Operational

Resilience Act (DORA) and other upcoming directives,

including CSRD and CS3D. The centralised CM

capability is designed to enhance standardisation,

ensure compliance with policies and regulations, and

provide greater control over supplier-related risks.

Key enhancements to the CM framework made in 2025

include:

• Centralised expertise: establishment of dedicated

roles for Contract Risk Managers and Supplier Risk

Managers to oversee and manage contract-specific

and supplier-level risks.

• Improved risk controls: implementation of enhanced

processes for risk identification, assessment and

mitigation across all supplier contracts, including

assurance on exit strategies and security controls.

• Strengthened oversight: integration of comprehensive

monitoring and reporting mechanisms to provide

holistic insight into contract management risks,

especially for high-impact contracts with broad

scopes of service delivery.

• Operational optimisation: adoption of standardised

tools and processes to improve efficiency, support

compliance with regulatory changes and ensure

alignment with the bank’s TPRM policy.

Change risk

The bank operates in a rapidly changing environment,

where stakeholder expectations, regulatory

requirements and the nature of financial services are

continuously evolving. In this dynamic context, our

ability to drive and execute change is essential to

achieving our strategic objectives and sustaining a

competitive edge. Our change portfolio is fundamental

to ABN AMRO’s strategy. Change is what makes us

innovative, forward-looking and entrepreneurial. During

2025 we continued to implement a broad range of

change programmes as part of our strategy execution.

These programmes are building a stronger, future-proof

foundation for our products and services, addressing

weaknesses in data and reporting capabilities, and

ensuring compliance with laws and regulations. In

2025, the strategy was updated. Delivery of the

updated strategic plan and continued execution of

remediation programmes requires monitoring and

active steering. We therefore reinforced our change

management framework and practices by reducing the

complexities in our change portfolio and by further

streamlining our prioritisation processes and improving

execution processes.

Model risk

Models are developed and applied to quantify the risk

for most of the risk types listed in ABN AMRO’s risk

taxonomy. We define model risk as the potential for

adverse consequences from decisions based

substantially or partly on model outputs. To identify and

assess risks arising from the use of these models, the

Model Risk Management & Model Validation

(MRM&MV) department acts as the 2LoD. As an

independent department, MRM&MV sets the model risk

framework for the bank in line with regulatory

requirements and independently validates models

before they can be used. For this purpose, ABN AMRO

has independent model validation standards and

procedures in place as part of its model risk

management framework. MRM&MV also reports to

senior management on the status of model risks in

ABN AMRO.

Fraud risk

Fraud is a rapidly changing and complex phenomenon

with an increasing impact on society, ABN AMRO and its

clients. It can arise from internal or external events and

result in financial losses, reputational damage and

regulatory fines. ABN AMRO’s three lines of defence

work closely together to maintain the Fraud Risk

Management Framework that enables the bank to

manage and mitigate fraud risk. ABN AMRO works to

safeguard the bank’s risk focus in relation to fraud risk,

especially as the bank is going through a process of

digitalisation and the proliferation of technology

presents unprecedented opportunities for fraud (e.g.

possibilities of using AI software).

In 2025, the most frequent forms of fraud (in terms of

the number of victims) observed by ABN AMRO

involved the impersonation of bank employees, debit

and credit card fraud and online sale scams. In some

instances, ABN AMRO itself was the victim of clients

falsifying information. With regard to internal fraud, the

bank continuously monitors and assesses fraud risks

related to employee fraud and bribery and corruption

risk. Due to increasing geopolitical volatility, insider risk


ABN AMRO	Annual Report 2025	114


≡	Risk, funding & capital	Risk management	Non-financial risk

will continue to be a relevant risk for the bank for the

foreseeable future.

In 2025, ABN AMRO continued its efforts to strengthen

the fraud resilience of its clients and employees to

manage the financial, emotional and reputational

impact of fraud:

• Maintaining the fraud risk management framework:

having a framework in place for fraud risk

management processes and a robust control

framework so that fraud and emerging fraud risks are

continuously identified, assessed, responded to,

monitored and reported.

• Awareness: encouraging employees to report fraud

incidents, corruption and suspicious or fraudulent

behaviours, and ensuring that the bank makes it

possible to report incidents and maintains its speak-

up programme, including the whistleblowing

procedure.

• Expertise: ABN AMRO employs dedicated resources

for in-depth fraud investigations, analyses, mitigation

and prevention, in order to monitor and assess fraud

and emerging fraud risks.

• Public-private partnerships: ABN AMRO partners

with public and private entities, including initiatives

such as the Electronic Crimes Taskforce, to combat

online fraud and scams. The bank also participates in

a Ministry of Justice and Security-led effort to create a

governance framework that unites service providers,

tech companies and consumers in addressing online

fraud. This collaborative approach aims to improve

information sharing, prevention and intervention,

resulting in stronger cooperation and enhanced client

protection that goes beyond payment systems.

Legal risk

ABN AMRO considers legal risk to be any risk of

financial loss or reputational effects that is the result of:

• uncertainty in the applicability, enforceability and

interpretation of contracts, laws and regulations

• the failure (or assumed failure) by the bank or any

third party to comply with statutory, contractual or

regulatory obligations or ‘best practices’, or

• uncertainty about the outcome of legal actions

against or initiated by the bank (including judicial

proceedings and litigation)

The following considerations may be taken into

account:

• ABN AMRO acknowledges that, especially in a

globalised business environment, there may not

always be a clear set of legal rules and that

ABN AMRO may face an abundance of legal

requirements, as well as a lack of legal clarity. Legal

obligations may be unclear, opaque and conflicting,

and can arise retroactively.

• Rules and regulations may also be interpreted and

applied by regulators or under case law in a manner

that goes beyond the original intention of the

legislator.

• Rules and regulations that are not directly binding on

the parties involved or third parties (such as

resolutions, recommendations and best practice

documents) may be issued by authorities and other

governmental or non-governmental bodies and may

have a de facto force that goes beyond formal laws

and regulations.

• Finally, the extraterritorial reach of certain national

laws increases the complexity of complying with all

these many layers, types and forms of rules and

regulations.

HR risk

Human resource (HR) risk is the risk that ABN AMRO is

unable to develop, retain and attract the required

critical skills and talents and maintain a diverse

workforce in line with applicable HR-related and other

laws and regulations so that ABN AMRO’s strategic

objectives can be realised. Internally, we distinguish HR

risks related to discrimination, employee relations,

personal health and safety, remuneration and suitability.

Adverse developments in these areas can potentially

compromise the bank’s viability. Management of HR risk

is consequently fundamental to the bank's achievement

of its strategic, business, operational, compliance and

reputational objectives.

Tax risk

A tax risk is the risk of unexpected tax charges,

including interest and penalties, and the risk of adverse

consequences arising from tax-related events, such as

damage to the bank’s reputation with the tax

authorities, investors, employees or the public. Tax risks

may materially affect the financial performance of the

bank, and may occur in relation to the bank’s own

activities, products or solutions and the tax integrity of

its clients.

Behavioural risk

Within ABN AMRO, behavioural risk refers to the risk

that actions, decisions and behaviours by ABN AMRO

(collectively) or by employees (as a group or

individually) lead to detrimental or poor outcomes for

clients, employees, society or ABN AMRO, the risk that

ABN AMRO fails to maintain high standards of market

behaviour and integrity, or the risk that ABN AMRO fails

to maintain the high expectations of clients, society and

other stakeholders with regard to the integrity of our

business. Behavioural risk is also considered an internal

causal factor of other ABN AMRO risk types.


ABN AMRO	Annual Report 2025	115


≡	Risk, funding & capital	Risk management	Non-financial risk

Behavioural risk management aims to safeguard an

enabling and supportive work environment. It

empowers employees to execute our strategy, take

sound risks and act in line with our purpose, core values

and Code of Conduct. Behavioural risk is embedded in

ABN AMRO’s enterprise risk management cycles. Tools

and processes are in place to identify, monitor, report

and mitigate behavioural risk. ABN AMRO addresses

identified behavioural risks by analysing organisational

root causes of undesired behaviours and non-

compliance, and by implementing targeted

interventions to drive behavioural change.

Product approval and review

ABN AMRO prioritises clients’ interests in its products

and services while maintaining a careful approach to

risk management. The product approval and review

process is a key part of executing this commitment

ensuring that all products are developed, managed, and

offered to clients in ways that support their interests,

create value for the bank, and align with its risk

appetite. These arrangements include:

• comprehensive product proposals

• solid risk assessments covering the various risk types

outlined in the bank’s risk taxonomy and their causal

factors

• well-structured approvals involving both 1LoD and

2LoD representatives

Business continuity management

Business continuity management ensures organisational

resilience at all levels within ABN AMRO. It focuses on

setting up and maintaining ABN AMRO’s crisis

management capability (i.e. framework, process,

tooling, people) to enable the organisation to remain

well-prepared and sufficiently responsive in the face of

severe threats. Our business continuity management

capabilities proved effective in 2025.

The business continuity process involves scanning the

operating environment for threats, analysing their

impact, and determining strategies such as emergency

management to ensure safety and business continuity.

These strategies are documented, periodically assessed,

and tested to maintain their effectiveness.

Mitigations are in place to prepare for and deal with

incidents and crises threatening the continuity of critical

business processes. These mitigations include business

continuity plans, crisis management, business relocation

plans and IT disaster recovery plans. We also perform

evaluations and root cause analyses on incidents and

implement lessons learned. Equally importantly, we

carry out forward looking analyses to prepare for

evolving threats such as those related to climate

change, where data and methodologies from climate

science are increasingly incorporated into our risk

assessments on critical infrastructure, such as our data

centres.

Physical security is an important pillar of continuity

management. ABN AMRO’s Physical Security Policy

enables a fit-for-purpose framework that safeguards

people, information, buildings and company assets

against damage and disruptions. We operate a

multidisciplinary approach by combining insights from

key areas such as Business Continuity Management,

Security & Integrity Management, HR/Workplace

Management, Corporate Information Security and client

units.

The Physical Security Policy includes governance

procedures that distribute roles and responsibilities

across various internal departments, branches, critical

corporate buildings and international offices, with the

aim of coordinating complex physical security issues

such as events associated with chronic or acute climate

change. Evaluations such as physical security risk

assessments are regularly executed for data centres,

critical corporate buildings and sites in the Netherlands

and abroad. ABN AMRO did not experience any material

financial loss due to extreme weather linked to climate

change in 2025.

Non-financial risk measurement

Under the Basel IV Standardised Approach, the own

funds requirement for operational risk is calculated on

the basis of the three-year average income of the bank.

For economic capital, a simple Pillar 2 approach is in

place. This approach takes the bank’s operational risk

Pillar 1 capital levels as a starting point, but also adds

risk-based elements from historical loss data, stress

testing and control effectiveness data to the calculation.


ABN AMRO	Annual Report 2025	116


≡	Risk, funding & capital	Risk management	Non-financial risk

Review of 2025 results

ABN AMRO uses a holistic approach to managing

non‑financial risks, considering capital, losses and the

effectiveness of the control environment.

Capital for non-financial risk

In Q4 2025, operational risk RWA increased by

EUR 1.7 billion, from EUR 16.0 billion (Q4 2024) to

EUR 17.6 billion. This RWA increase can be attributed to

the bank’s income growth in the past few years, which

forms the basis for the RWA calculation, and to the

inclusion of HAL in Q3 2025. Furthermore, in keeping

with the CRR III regulations regarding the operational

risk framework, the three-year period used for the

calculations is based on full calendar years, with

updates occurring in the fourth quarter. Accordingly,

the Q4 2025 operational risk own funds requirements

are based on financial figures from the period

2023-2025.

Losses related to non-financial risks

Losses related to operational risks include direct losses,

as well as provisions for legal claims. A total net

operational loss of EUR 130 million was recorded in

2025, mainly related to the event categories Execution,

Delivery & Process Management (45%) and Clients,

Products & Business Practices (38%).

A bank-wide protocol is in place designed to ensure

that all relevant stakeholders are promptly notified of

operational risk events with substantial impact

occurring within the bank. This notification is mandatory

for any operational risk incident where the gross actual

or potential financial impact reaches EUR 1 million or

more, whether positive or negative, as well as for any

event with a significant potential impact on the bank’s

reputation. In 2025, these notified events were primarily

associated with incidents involving software failures,

remuneration matters, processing errors and a tax-

related issue. Senior management remained fully

apprised of these events, and appropriate management

actions were effectively implemented.

Effectiveness of the control environment

A robust risk control framework is a fundamental

element of ABN AMRO’s risk management system. The

bank continuously adapts its risk control framework to

changes in both the internal and external environment

to ensure it has well-designed and operationally

effective controls. Throughout 2025, ABN AMRO

continued to improve the control environment. The

bank is implementing initiatives to strengthen end-to-

end process governance, enhance the risk and control

framework and methodologies, and reinforce

accountability across the organisation.


ABN AMRO	Annual Report 2025	117


≡	Risk, funding & capital	Capital

Capital

Capital management strategy

The primary objective of the bank’s capital

management strategy is to ensure that capital adequacy

requirements are met at all times and that sufficient

capital is available to support the bank’s strategy.

ABN AMRO has complied with all applicable capital

adequacy requirements. Capital is a necessary resource

for doing business and defines the bank’s commercial

possibilities. The balance between available and

required capital is managed centrally to optimise the

use of available capital. The basis of the capital

management strategy is the bank’s risk appetite and its

business plans. Other important factors of managing

the capital position are expectations and requirements

of external stakeholders (such as regulators, investors,

shareholders, equity analysts, rating agencies and

clients), the bank’s position in the market, market

developments, contingent capital needs and the

feasibility of capital management actions. Although

ABN AMRO manages its capital centrally, the group

companies are sufficiently capitalised to comply with all

local regulatory solvency requirements and to meet any

local business needs. Apart from prevailing statutory

and regulatory legislation, there are no specific material

impediments for prompt transfer of the bank’s

regulatory capital.

Capital framework and distribution policy

Our target is a CET1 ratio above 13.75%, which reflects

our regulatory requirements. We are committed to

generating capital for and returning capital to

shareholders, targeting an ordinary distribution of up to

100% after deduction of AT1 coupon payments and

minority interests. Ordinary distributions will be in the

form of a combination of cash dividend and share

buybacks (subject to regulatory approval), with at least

50% of reported net profit distributed in the form of

cash dividend. Interim cash dividends of 40% of the

reported H1 net profit will be considered, provided

profit is expected to be sustainable throughout the year,

at the discretion of the Board.

If the CET1 ratio is expected to remain significantly

above the 13.75% target level, additional distributions

can be considered. This is subject to successful strategy

execution, macroeconomic developments and

regulatory approval.

We will communicate the outcome of our capital

assessment once a year with the Q4 results. Any

distribution will take into account matters including

economic conditions, capital requirements and business

opportunities, and ABN AMRO may propose deviations

from the above distribution policy.

Capital measurement and allocation

Capital adequacy is measured and monitored on an

ongoing basis against target capital ratios, which are

derived from the bank’s overall risk appetite and

strategy. Capital projections and stress test scenarios,

both market-wide and bank-specific, are used to ensure

that actual and future capital levels remain above the

targets. Capital is allocated to businesses in a way that

optimises the long-term value of the bank while serving

the bank’s strategic objectives. In the capital allocation

process, both risk-based and non-risk-based return

parameters are considered, taking into account

economic and regulatory capital requirements. This

process ensures the bank meets its return targets while

maintaining a risk profile that is in line with its risk

appetite.

Contingency capital management

Contingency plans are in place to address any potential

capital adequacy issues. The Contingency Capital Plan

provides a framework for detecting capital stress by

defining a set of early warning indicators. The plan also

sets out a range of actions that can be undertaken,

based on the severity and urgency of the situation.

Recovery and resolution planning

The Bank Recovery and Resolution Directive (BRRD)

requires a recovery plan and a resolution plan to be in

place. ABN AMRO submitted a reviewed and updated

version of its bank recovery plan to the European

Central Bank (ECB) in December 2025. The Single

Resolution Board (SRB) has prepared a resolution plan,

identifying a Single Point of Entry as the preferred

resolution strategy, with ABN AMRO Bank N.V.

designated as the resolution entity and bail-in as the

preferred resolution tool.


ABN AMRO	Annual Report 2025	118


≡	Risk, funding & capital	Capital

Capital structure

Regulatory capital structure


	31 December 2025		31 December 2024
(in millions)		CRR III		CRR II
Total equity (EU IFRS)		27,043		26,108
Dividend reserve		-826		-625
AT1 capital securities (EU IFRS)		-3,233		-3,475
Share buyback reserve		-250
Regulatory and other adjustments		-1,835		-1,652
Common Equity Tier 1		20,899		20,357
AT1 capital securities (EU IFRS)		3,233		3,475
Regulatory and other adjustments		-5		-1
Tier 1 capital		24,127		23,831
Subordinated liabilities (EU IFRS)	4,946		6,613
Regulatory and other adjustments	-831		-1,967
Tier 2 capital		4,114		4,646
Total regulatory capital		28,241		28,477
Senior non-preferred instruments (EU IFRS)		17,861		18,302
Subordinated liabilities not eligible for regulatory capital				711
Regulatory and other adjustments		-65		-20
Total Subordinated MREL eligible liabilities		46,037		47,470
Senior unsecured debt		1,005		1,314
Total MREL eligible liabilities		47,042		48,784

Total risk-weighted assets		135,398		140,871

Exposure measure		453,650		420,932

Capital ratios
Common Equity Tier 1 ratio		15.4%		14.5%
Tier 1 ratio		17.8%		16.9%
Total capital ratio		20.9%		20.2%
Subordinated MREL		34.0%		33.7%
Total MREL		34.7%		34.6%
Leverage ratio		5.3%		5.7%


ABN AMRO	Annual Report 2025	119


≡	Risk, funding & capital	Capital

Main developments in capital position

As of 1 January 2025, we report our regulatory capital

metrics and risk exposures in line with Capital

Requirements Regulation (CRR) III (Basel IV).

Comparative figures for 31 December 2024 are

reported under CRR II (Basel III).

As at 31 December 2025, the Common Equity Tier 1

(CET1), Tier 1 and total capital ratios were 15.4%,

17.8% and 20.9% respectively (31 December 2024:

14.5%, 16.9% and 20.2% respectively). The CET1

capital ratio increased compared with

31 December 2024 due to a decrease in RWA and an

increase in CET1 capital. The EUR 5.5 billion decrease in

RWA was mainly reflected by a significant decrease of

EUR 6.6 billion in credit risk RWA. Credit risk RWA

decreased mainly due to RWA optimisation initiatives,

including methodological enhancements and data

quality improvements, and business steering. Risk

transfers also contributed to the decrease.

The decrease in credit risk RWA was partly offset by the

transition of certain portfolios to the Standardised

Approach and the acquisition of HAL. Furthermore,

operational risk RWA increased by EUR 1.7 billion

compared with 2024. This RWA increase can be

attributed to the bank’s income growth in the past few

years, which forms the basis for the RWA calculation,

and to the inclusion of HAL in Q3 2025. The CET1

capital position increased mainly due unrealised gains

on investments in debt securities due to market

movements, as well as the addition of the 2025 net

profit after deduction of AT1 coupons and distributions,

and was partly offset by higher capital deductions. The

deduction of distributions includes the EUR 250 million

additional cash dividend and the EUR 250 million share

buyback (pending regulatory approval). All capital ratios

were in line with the bank’s risk appetite and were

comfortably above regulatory requirements.

The following chart shows the primary drivers of the

Basel IV capital ratios in 2025.

Developments impacting capital ratios in 2025

(in %)

-0.9

0.8

1.7

-0.3

-0.4

0.2

20.9

17.8

15.4

20.2

16.9

14.5

31 December

2025


Common Equity Tier 1	Additional Tier 1	Tier 2	Move up	Move down

The maximum distributable amount (MDA) trigger level

remained stable at 11.2% (31 December 2024: 11.2%).

This resulted in a buffer of 4.2% above the MDA trigger

level. From 1 January 2026, the MDA trigger level

increased to 11.4% due to an increase of the Pillar 2

requirement of 0.35% to 2.60% (up from 2.25%), of

which 0.20% should be filled by CET1 capital.

MREL

Based on the subordinated eligible liabilities (i.e. own

funds, subordinated instruments and senior non

preferred (SNP) notes), the Minimum Requirement for

Own Funds and Eligible Liabilities (MREL) ratio

increased to 34.0% as at 31 December 2025

(31 December 2024: 33.7%). This increase was mainly

driven by a decrease in RWA and an increase in

subordinated MREL-eligible liabilities. The subordinated

MREL ratio is well above all risk appetite and regulatory

requirements for 2025 and 2026. The total MREL ratio

increased to 34.7% (31 December 2024: 34.6%). As at

31 December 2025, the reported total MREL ratio

includes EUR 0.5 billion in newly issued MREL-eligible

senior preferred instruments and EUR 0.5 billion of

grandfathered senior preferred liabilities.

Since MREL-eligible senior preferred instruments have

now been issued, historical figures on the total MREL-

eligible liabilities have been adjusted to include

grandfathered senior preferred liabilities. As a result, the


ABN AMRO	Annual Report 2025	120


≡	Risk, funding & capital	Capital

total MREL ratio as at 31 December 2024 increased to

34.6% (was 33.7%).

The total MREL requirement as at 31 December 2025

was 28.4%, of which 22.1% must be met by own funds,

subordinated instruments and SNP notes. This includes

a combined buffer requirement (CBR) of 5.4%. The

Single Resolution Board (SRB) has notified ABN AMRO

of the final outcome of the MREL requirements for

2026. The total MREL requirement as of 1 January 2026

is 28.2%, of which 21.8% must be met by own funds,

subordinated instruments and SNP notes. This is based

on an unchanged CBR.

Developments impacting capital ratios in 2025

Common Equity Tier 1 capital

CET1 capital increased in 2025. This increase mainly

reflected unrealised gains on investments in debt

securities due to market movements as well as the

addition of the 2025 net profit after deduction of AT1

coupons and distributions, and was partly offset by

higher capital deductions. The deduction of

distributions includes the EUR 250 million additional

cash dividend and the EUR 250 million share buyback

(pending regulatory approval). The reported CET1 ratio

of 15.4% is well above the MDA trigger level of 11.2%.

Additional Tier 1

A total of EUR 3.3 billion of AT1 instruments was

outstanding as at 31 December 2025, which equates to

2.4% of RWA versus a requirement of 1.9%. Following

the aforementioned increase of the Pillar 2 requirement,

the required level of the Additional Tier 1 layer will

increase to 2.0% as of 1 January 2026.

One AT1 instrument was issued during 2025.

A EUR 750 million AT1 instrument was issued on

19 February 2025 (settlement on 26 February 2025).

The bank also called a EUR 1.0 billion AT1 instrument.

The instrument was redeemed on 22 September 2025.

The AT1 instruments have triggers at the bank’s

consolidated level (7.0% CET1) and at its solo level

(5.125% CET1). If the CET1 ratio breaks through the

trigger level, the AT1 is temporarily written down.

ABN AMRO is comfortably above the trigger levels,

as the bank’s consolidated CET1 ratio is 15.4% and the

bank’s solo CET1 ratio is 14.6%. Available distributable

items on 31 December 2025 amounted to

EUR 23.0 billion (31 December 2024: EUR 21.7 billion).

Tier 2 capital

The total capital ratio increased to 20.9% as at

31 December 2025 (31 December 2024: 20.2%). This

increase was mainly attributable to the decrease in

RWA. The increase was partly offset by lower Tier 2

capital and higher capital deductions.

The reported Tier 2 layer of 3.0% is above the required

level of 2.6% (combined requirement for Pillars 1 and

2). Following the aforementioned increase in the Pillar 2

requirement, the required level of the Tier 2 layer

increased to 2.7% as of 1 January 2026.

Senior non-preferred instruments

A total of EUR 17.9 billion of senior non-preferred

instruments was outstanding as at 31 December 2025.

The bank issued a total of GBP 750 million of senior

non-preferred notes during the year under review. The

senior non-preferred layer combined with the total

capital resulted in a total of EUR 46.0 billion of

subordinated MREL-eligible instruments as at year-end

2025.

MREL-eligible senior preferred instruments

The bank issued a total of EUR 205 million and

GBP 250 million of MREL-eligible senior preferred

instruments during 2025. As at 31 December 2025,

total MREL-eligible liabilities amounted to

EUR 47.0 billion. This includes EUR 0.5 billion of newly

issued MREL-eligible senior preferred instruments and

EUR 0.5 billion of grandfathered senior preferred

liabilities.

Risk-weighted assets

Total RWA decreased to EUR 135.4 billion

(31 December 2024: 140.9 billion), mainly driven by

a significant decrease in credit risk RWA of

EUR 6.6 billion. Credit risk RWA mainly decreased due

to RWA optimisation initiatives, including

methodological enhancements and data quality

improvements, and business steering. Besides that, risk

transfers contributed to the decrease. The decrease in

credit risk RWA was partly offset by the transition of

certain portfolios to the Standardised Approach and the

acquisition of HAL. Furthermore, operational risk RWA

increased by EUR 1.7 billion compared with 2024. This

RWA increase can be attributed to the bank’s income

growth in the past few years, which forms the basis for

the RWA calculation, and to the inclusion of HAL in

Q3 2025. Market Risk RWA decreased by

EUR 0.5 billion, while CVA risk RWA (counterparty credit

risk) increased by EUR 0.1 billion over the year.

Further information on share capital, dividend and

capital instruments

Share capital

As at 31 December 2025, the authorised share capital

amounted to EUR 2,400 million, distributed as

2,200 million class A ordinary shares and 200 million


ABN AMRO	Annual Report 2025	121


≡	Risk, funding & capital	Capital

class B ordinary shares. Class A and B ordinary shares

have a nominal value of EUR 1.00 each.

As at 31 December 2025, issued and paid-up capital

amounted to EUR 823,201,264 (31 December 2024:

EUR 833,048,566) and consisted entirely of class A

ordinary shares. Further information is provided in

Note 33 Equity attributable to owners of the parent

company in the Consolidated Annual Financial

Statements.

Capital framework and distribution policy

We updated our capital framework and distribution

policy as announced at the Capital Markets Day on

25 November 2025. Our target is a CET1 ratio above

13.75%, reflecting our regulatory requirements. We are

committed to returning capital to shareholders. We aim

for an ordinary distribution up to 100% of the reported

net profit, after deduction of AT1 coupon payments and

minority interests. Ordinary distributions are expected

to be in the form of a combination of cash dividends

and share buybacks (subject to regulatory approval),

with at least 50% of the reported net profit distributed

in the form of cash dividends. Interim cash dividends of

40% of the reported H1 net profit will be considered,

provided the profit is expected to be sustainable

throughout the year, at the discretion of the Executive

Board.

If the CET1 ratio is expected to remain significantly

above the 13.75% target level, additional distributions

can be considered. This is subject to successful strategy

execution, macroeconomic developments and

regulatory approval.

We expect to communicate the outcome of our capital

assessment annually with the Q4 results. Any

distribution will take into account factors such as

economic conditions, capital requirements and business

opportunities, and ABN AMRO may propose deviations

from the above distribution policy.

Distributions

Based on the distribution policy, the reported net profit

for 2025 of EUR 2,036 million (after deduction of AT1

and minority interests) and the interim dividend of

EUR 0.54 per share that was already paid in 2025, we

propose a final cash dividend for 2025 of EUR 0.70 per

share (2024: EUR 0.75). This is equivalent to a final

dividend of EUR 576 million (2024: EUR 625 million),

based on 823,201,264 outstanding shares at year-end

2025. This corresponds to a payout ratio of 50% of the

reported net profit and brings the total dividend for

2025 to EUR 1.24 per share (2024: EUR 1.35), for a total

of EUR 1,025 million. The proposed ex-dividend date is

24 April 2026, with a record date of 27 April 2026 and

the dividend being paid on 22 May 2026. The Q4 2025

capital assessment confirmed the robustness of our

capital position and included the intended acquisition of

NIBC. In view of this, we plan to distribute an additional

EUR 500 million, consisting of an additional cash

dividend of EUR 250 million, corresponding to around

EUR 0.30 per share (based on the amount of shares

outstanding at year-end 2025), and a EUR 250 million

share buyback (subject to regulatory approval).

Together with the ordinary cash dividend and the

EUR 250 million share buyback realised in Q3 2025, this

would bring the total payout over 2025 to EUR

1,775 million, equal to a payout ratio of 87% of the

reported net profit (after deduction of AT1 and minority

interests).

A EUR 250 million share buyback programme was

announced on the same day as the Q2 2025 results.

The programme commenced on 7 August 2025 and

was completed on 10 September 2025. Under the

share buyback programme, a total of 9,847,302

ordinary shares and depositary receipts were

purchased. Following completion of the share buyback

programme and cancellation of the ordinary shares and

depositary receipts, the outstanding number of ordinary

shares and depositary receipts of ABN AMRO Bank N.V.

is 823,201,264. As a majority shareholder, NLFI has

participated pro-rata in the share buyback programme

(30.5% of the total programme), thereby maintaining its

relative stake in the company.

On 9 September 2025, NLFI announced its intention to

sell depositary receipts in ABN AMRO through a pre-

arranged trading plan, in order to reduce its stake in

ABN AMRO from 30.5% to approximately 20%.

Minimum capital requirements

The Pillar 1 capital requirement is the absolute

minimum amount of capital required to cover the three

major types of risk a bank faces: credit risk, operational

risk and market risk, as determined in the

Capital Requirements Directive (CRD) VI Pillar 1

framework. The following table provides an overview of

RWA and minimum capital requirements per risk type,

category of exposure and regulatory approach.


ABN AMRO	Annual Report 2025	122


≡	Risk, funding & capital	Capital

Minimum capital requirements


	31 December 2025		31 December 2024
(in millions)	Capital requirement	RWA	Capital requirement	RWA
Credit risk IRB
Institutions¹	100	1,247	130	1,624
Corporates	42	520	4,680	58,499
Retail	1,213	15,166	1,480	18,495
- of which secured by immovable property	1,213	15,158	1,390	17,369
- of which qualifying revolving exposures			12	153
- of which other retail	1	8	78	973
Equities not held for trading	261	3,265	274	3,423
Other ^{2, 3}			125	1,568
Total credit risk IRB³	1,616	20,198	6,689	83,609
Credit risk SA
Central governments and central banks	29	357	54	675
Institutions¹	153	1,915	92	1,149
Corporates	3,961	49,510	418	5,226
Retail	284	3,554	190	2,377
Covered bonds	8	95
Secured by mortgages on immovable property	2,035	25,436	17	209
Exposures in default	252	3,145	17	213
Collective investments undertakings (CIU)	44	550	2	19
Other ^{2, 3}	157	1,968	9	110
Total credit risk SA³	6,923	86,532	798	9,978
Other risks
Other credit risk³	754	9,422	2,335	29,191
- of which Securitisation positions³	55	689	30	371
- of which Credit valuation adjustment³	15	186	10	122
- of which other³	684	8,548	2,296	28,697
Market risk	129	1,618	169	2,115
- of which Standardised Approach		2
- of which Internal Model Approach	129	1,616	169	2,115
Operational risk	1,410	17,628	1,278	15,977
- of which TSA approach	1,410	17,628	1,278	15,977
Total other risks³	2,293	28,668	3,783	47,283
Total	10,832	135,398	11,270	140,871
1. Institutions include exposures to banks and investment companies, regional and local governments and pension funds.
2. Other includes non-credit obligations.
3. Figures of 2024 have been adjusted for comparison reasons. For more information, we refer to the credit risk review section.

Main regulatory developments

EU implementation of Basel IV via CRR III and CRD VI

has been finalised and endorsed by the European

Council and Parliament.

The new CRR rules were implemented as of

1 January 2025.


ABN AMRO	Annual Report 2025	123


≡	Risk, funding & capital	Capital

Leverage ratio


	31 December 2025	31 December 2024
(in millions)	CRR III	CRR II
Tier 1 capital	24,127	23,831
Exposure measure
On-balance sheet exposures	413,210	385,047
Off-balance sheet exposures	30,038	31,025
On-balance sheet netting	4,231	4,334
Derivative exposures	6,623	4,662
Securities financing exposures	3,421	2,238
Other regulatory measures	-3,873	-6,372
Exposure measure	453,650	420,932
Leverage ratio	5.3%	5.7%

The Capital Requirements Regulation (CRR) includes a

non-risk-based leverage ratio. The leverage ratio

decreased to 5.3% at 31 December 2024

(31 December 2024: 5.7%), mainly due to an increase

of the exposure measure, which was partly offset by the

increase in Tier 1 capital. The reported leverage ratio

remained well above the required 3.0%. The exposure

measure is reported to the Asset and Liability

Committee (ALCO) and monitored closely in order to

ensure the leverage ratio remains within the bank’s risk

appetite.

The leverage ratio outlook takes account of business

specific plans, as well as macroeconomic conditions,

regulatory developments and capital-related

uncertainties. If the leverage ratio breaches the risk

appetite, the bank-wide escalation paths for capital and

funding are followed.


ABN AMRO	Annual Report 2025	124


≡	Risk, funding & capital	Management Control Statement

Management Control

Statement

ABN AMRO publishes this Management Control

Statement to demonstrate its accountability for risk

management and culture, as stipulated in provisions 1.4

and 2.5 of the Dutch Corporate Governance Code.

• By virtue of provision 1.4 (Risk management

accountability) of the Dutch Corporate Governance

Code, ABN AMRO’s Executive Board is required to

account for the effectiveness of the design and

operation of the bank’s internal risk management and

control systems.

• By virtue of provision 2.5 (Culture) of the Code, the

Executive Board is responsible for creating a culture

aimed at sustainable long-term value creation for the

company and its affiliated enterprises.

• By virtue of Principle 2.5.4 (Reporting on culture), the

Executive Board is required to explain the bank’s

values and how these values are incorporated into the

activities of the company and its affiliated enterprises,

and to account for the effectiveness of and the bank’s

compliance with the Code of Conduct.

• As from 2025, ABN AMRO has integrated the VOR

(Verklaring Omtrent Risicobeheersing; Statement on

Risk Management) requirements in this Management

Control Statement – as part of the revised Dutch

Corporate Governance Code.



	The Management Control Statement consists of four sections: A. insights into our risk management governance processes and control systems during 2025 B. factors that potentially impact ABN AMRO’s current business model C. areas at risk of non-compliance with regulations and heightened regulatory scrutiny D. areas of attention for ABN AMRO identified by senior management

Section A: Risk management governance

ABN AMRO’s internal risk management and control

process aims to provide a certain level of assurance

and/or comfort regarding the achievement of objectives

related to:

• strategic and business goals;

• compliance with laws, regulations and internal

policies;

• reliability of both financial and non-financial

reporting;

• effectiveness and efficiency of operations;

• safeguarding of assets alongside the identification

and management of liabilities.

ABN AMRO’s first and second lines of defence perform

a variety of activities – risk assessments, stress tests,

and evaluations of the effectiveness of controls –

related to our risk management and control systems.

Formal reports are produced in order to bring the

results to the attention of, and discuss them with, senior

management.

The third line of defence, Group Audit, evaluates the

design and effectiveness of ABN AMRO’s governance,

as well as its risk management and control systems. In

2025, Group Audit’s reports were discussed with

relevant Executive Board members. Group Audit

attended the Executive Board meetings every quarter to

discuss the Quarterly Audit Opinions.

The Executive Board is responsible for establishing and

maintaining adequate internal risk management and

control systems. This includes interventions to foster

strong risk awareness and practices by, for example,

entering into a dialogue with management teams to

reflect on decision making and sound risk taking, and by

elevating financial risk management (credit risk, ALM

risk, etc.) and non-financial risk management (data risk,

IT risk, financial reporting, etc.). During 2025, the

Executive Board assessed the design and effectiveness

of these systems. The results were discussed with the

Audit Committee, the Risk & Capital Committee, the

Supervisory Board and Group Audit.

Based on its assessment and with reference to Best

Practice Provision 1.4.3 of the 2025 Dutch Corporate

Governance Code, the Executive Board of ABN AMRO

confirms that, to the best of its knowledge:

• The Executive Board report, which is an integral part

of the Annual Report 2025, provides sufficient insight


ABN AMRO	Annual Report 2025	125


≡	Risk, funding & capital	Management Control Statement

into deficiencies in the effectiveness of the internal

risk management and control systems during 2025

(best practice 1.4.3.i);

• These internal risk management and control systems

provide reasonable assurance that the financial

reporting for 2025 does not contain material

inaccuracies (best practice 1.4.3.ii);

• These internal risk management and control systems

provide limited assurance that sustainability reporting

for 2025 does not contain material inaccuracies (best

practice 1.4.3.iii);

• These internal risk management and control systems

provide moderate comfort that for 2025 the

operational and compliance risks, as identified in the

Non-Financial Risk section of the Annual Report and

sections B, C and D of this Management Control

Statement, are effectively managed in view of

ABN AMRO’s risk appetite, on the understanding that

"moderate comfort", considering actions required to

effectively manage operational and compliance risks,

should be read in the context of our risk appetite, the

complexity of our organisation, inherent limitations to

these systems and other disclosures on these systems

in our Executive Board report (best practice 1.4.3.iv);

• Based on the current state of affairs, preparation of

the financial reporting for 2025 on a going-concern

basis is justified (best practice 1.4.3.iii). For further

information, please refer to Note 1 Accounting

policies in the Consolidated Annual Financial

Statements.

• The Executive Board report sets out any material risks

(best practice provision 1.2.1) and uncertainties, to

the extent that they are relevant to the expectation of

the company’s continuity for a period of 12 months

following the preparation of the report.

• The Executive Board report outlines the bank’s values

and how they are incorporated into the activities of

the bank and its affiliated enterprises. It discusses the

bank’s compliance with the Code of Conduct (best

practice 2.5.4).

• The COSO framework was used as a basis to assess

the design of the risk management and control

systems, in line with audit practices and industry

standards (best practice 1.4.2.ii).

The statements above are substantiated by several

review, assessment and analysis activities.

A review of the design of the risk management and

control systems has been performed, which included

benchmarking against an external standard (COSO).

Furthermore, assessments have been performed of the

client units’ risks regarding their strategic objectives and

continuity. In addition, assessments have been

performed regarding the internal risk management and

control systems of the main processes of the bank.

Finally, key opinions & observations from quarterly risk

& audit reports and supervisory inspections were taken

into account. The aforementioned assessments resulted

in an overview of observations, and the main items are

disclosed in Sections B, C and D of this Management

Control Statement and the Non-financial risk section of

the Annual Report.

The statements are substantiated by the following:

• Financial reporting: a process for monitoring of

controls & testing (MC&T) within Finance is in place to

address financial reporting risks related to the Annual

Financial Statements. On a quarterly basis, prior to the

publication of the financial figures, the Executive

Board and the Audit Committee are informed of any

deficiencies regarding financial reporting controls.

Throughout the 2025 reporting period, no material

weaknesses were reported to the Executive Board or

the Audit Committee.

• Sustainability reporting: similarly, a MC&T process is

in place to address sustainability reporting risks

related to the sustainability statements. On a bi-

annual basis, prior to the publication of the

sustainability information, the Executive Board and

the Audit Committee are informed of any deficiencies

regarding sustainability reporting controls.

Throughout the 2025 reporting period, no material

weaknesses were reported to the Executive Board or

the Audit Committee. For 2026, ABN AMRO aims to

further strengthen the Sustainability Control

Framework.

• Operational and compliance risk: outcomes of MC&T

(quarterly) are reported to the bank’s Group Risk

Committee, including overviews of risk events and of

issue and action management (monthly). In addition

to the review, assessment and analysis activities

performed in light of the VOR, these outcomes

substantiate the moderate comfort provided

regarding the identification and management of

operational and compliance risks. Starting in 2026,

the risk management and control systems will be

further improved and enhanced via the End-to-End

Non-Financial Risk programme.

Given the Supervisory Board’s responsibility to maintain

oversight, the Audit Committee and the Risk & Capital

Committee reviewed the evidence supporting these

Executive Board statements and reported on this to the

Supervisory Board (best practice 1.5.3.iv). It is important

to recognise that even a robust framework of internal

risk management and controls cannot eliminate all

risks, including risks that arise from poor judgement,

human error, deliberate circumvention or unforeseeable

circumstances. For more information, please refer to the

Risk framework section.


ABN AMRO	Annual Report 2025	126


≡	Risk, funding & capital	Management Control Statement

Section B: Factors that potentially impact

ABN AMRO’s current business

The Executive Board has identified the following factors

that could potentially have an impact on ABN AMRO’s

business model:

• macroeconomic developments and geopolitical

tensions

• an evolving regulatory landscape

• environmental, social and governance (ESG) matters

• significant corporate developments

Macroeconomic developments and geopolitical

tensions

In 2025, ABN AMRO had to cope with increasing

geopolitical tensions, as did all banks. The advent of AI,

China’s rise and the changing position of the US present

challenges but also offer opportunities. Tariffs have

made a comeback as threat to the outlook. In spite of

this, global growth has been resilient given the

headwinds. Our base case sees that resilience

continuing, albeit with considerable risks. ABN AMRO

aims to support European and national energy transition

policies and has set targets for itself and for client

portfolios in the bank’s climate strategy.

Regulatory landscape

ABN AMRO has to comply with the regulatory

landscape. Complying with the regulatory environment

includes adapting business processes in line with many

new and existing laws and regulations in areas related

to sustainability reporting (CSRD), the credit chain

(definition of default – DoD), privacy, capital, data

management, digital resilience and anti-money

laundering. This involves an accumulation of change

and cost pressure for ABN AMRO. ABN AMRO's related

change portfolio is large and complex, while at the

same time the bank is striving for cost containment and

is faced with a scarcity of skilled resources. Looking

forward, steering the complex change portfolio is

expected to require significant and ongoing attention by

ABN AMRO and its subsidiaries.

Environmental, social & governance (ESG)

ABN AMRO has incorporated ESG factors in its core

activities, such as strategy setting and risk management.

We support our clients in the transition towards a more

sustainable economy and we keep abreast of ESG

developments and regulations. However, there are also

challenges: sustainability regulations, commitments the

bank has made and societal pressure expose

ABN AMRO to a wide range of reputational and legal

risks if expectations are not met. For more information,

please refer to the Sustainability statements chapter.

Significant corporate developments

The highly competitive banking environment in

Northwest Europe combined with regulatory

requirements could lead to pressure on ABN AMRO’s

ability to grow. Given this, the bank’s strategic plan for

2026-2028 prioritises profitable growth, operational

efficiency and optimised capital allocation, underpinned

by robust risk management practices. The bank aims to

maintain a solid credit portfolio with low cost of risk by

enhancing proactive risk management and a strong

control framework. Strategic investments in technology

and AI will enhance risk measurement and mitigation

capabilities. Sustainability is integrated into business

activities to align client impact with risk-conscious

growth. Furthermore, the focus on simplifying

processes, leveraging digitalisation and optimising

capital allocation supports the bank's ability to manage

exposures effectively, ensure compliance and maintain

financial stability. The integration of HAL remains a high

priority for ABN AMRO, as does the upcoming

integration of NIBC (pending regulatory approval).

Section C: Areas with a risk of non-

compliance with regulations and

heightened regulatory scrutiny

Ensuring demonstrable compliance requires robust risk

governance, enhanced data management, and

sufficient and knowledgeable resources. Living up to

the bank’s own expectations and those of regulators,

clients and society at large is important to ABN AMRO.

Failure to meet these expectations could lead to

reputational damage, fines, claims and adverse changes

in ABN AMRO’s income, costs or capital base, all of

which could endanger the bank’s long-term goals. The

main areas with a risk of non-compliance with

regulations and heightened regulatory scrutiny are

described below. Updates on our progress with

remediation programmes are also provided.

• Financial economic crime – including anti-money

laundering (AML), combating the financing of

terrorism (CFT), sanctions and fraud. ABN AMRO is

highly dedicated to enhancing our internal processes

and systems that contribute to the prevention of

financial crime. In addition, ABN AMRO is committed

to increasing the effectiveness of our measures and is

working towards achieving an adequate and

sustainable level that meets regulatory requirements.

ABN AMRO is in an ongoing dialogue with the Dutch

central bank (DNB), which is regularly informed and

provides observations and continues to monitor

progress. These efforts are focused on, among other

things, improving and demonstrating the

effectiveness of our monitoring processes and the

quality of our client due diligence. DNB’s previous

findings on shortcomings, specifically in the event-


ABN AMRO	Annual Report 2025	127


≡	Risk, funding & capital	Management Control Statement

driven review processes, might still lead to

enforcement measures. These could include sanctions

of a remedial and/or punitive nature. The potential

financial impact cannot be reliably estimated and no

provision has been recorded. Given the current

geopolitical environment, increased attention

continues to be paid to sanctions, and specifically the

monitoring of embargoed goods and sanction evasion

through countries in the proximity of sanctioned

countries. With regard to criminal activities, technical

developments such as artificial intelligence are

closely monitored. Client losses and the number of

fraud victims increased in 2025, mainly as a result of

scams such as investment fraud and advanced fee

fraud. Fraud trends require constant close monitoring,

with evolving risks such as deepfake technologies

posing significant reputational and financial threats. In

addition, upcoming PSR3 fraud requirements will

have to be implemented adequately in 2026 and

beyond.

• Duty of care towards the bank’s clients. The goals of

ABN AMRO and the expectations of external

stakeholders continue to be high when it comes to

the bank’s duty of care. After the implementation of

the bank-wide Duty of Care programme in the regular

governance and processes, the bank’s practices

regarding duty of care have matured. The Duty of

Care and Client Centricity Policy, which establishes a

bank-wide approach and framework for managing

duty of care risk, further emphasises this. Upcoming

EU regulations and case law developments are raising

the bar for client protection expectations. The bank is

therefore staying focused on sufficiently monitoring

clients during the full client lifecycle and meeting all

requirements regarding the provision of accurate,

clear and non-misleading information to clients. This

also includes, among other things, paying ongoing

attention to compliance with MIFID II regulations.

Furthermore, the impact of sustainability

developments on the bank’s duty of care (e.g.

regarding product-specific sustainability claims and a

client’s sustainability preferences) is receiving

increased attention, as is accessibility of products and

services (including digital accessibility). ABN AMRO is

also continuing its efforts to inform and engage with

clients on the repayment of interest-only mortgages,

while adhering to strict prudential requirements for

these mortgages.

• Product pricing. There is a growing demand within

society for transparent pricing of banking products.

Examples of pricing topics include the use of variable

interest rates for consumer credit, mortgages and

loans to micro and small enterprises. ABN AMRO is

facing claims and litigation about alleged pricing

issues in the past and has initiated remediation

programmes for portfolios where this is considered

necessary. ABN AMRO continues to monitor pricing

risks to ensure prices are transparent and sufficient

information is communicated to clients.

• Privacy. Given its wide-ranging applicability and

principle-based nature, the implementation of the

privacy regulation is complex and requires ongoing

attention. In 2025, the bank made progress in

enhancing its privacy governance, design of privacy

controls and execution of privacy risk assessments, in

order to identify and mitigate privacy-related risks

more effectively. In 2026, the bank will, among other

things, focus on further embedding privacy controls

throughout the organisation, finalising required

privacy risk assessments for personal data processing

activities and enhancing monitoring activities. These

actions have the aim of further maturing privacy risk

management and demonstrating operating

effectiveness.

• Credit risk management. In 2025, the performance

of the credit book remained robust. However, as

developments in 2025 demonstrated, attention still

needs to be given to geopolitical and macroeconomic

developments. Regulatory attention regarding credit

risk management and controls remains high,

particularly in relation to credit risk processes, data

and IT infrastructure. In 2025, the updating of credit

risk core processes was initiated, which will support

higher data quality and the capture of more granular

data. ABN AMRO is further maturing the integration of

ESG risk management into core processes, client

assessments and external reporting. The Basel IV

regulation has been implemented, while tactical

solutions are being replaced by structural solutions

with improved data lineage and increasingly granular

data. Conservative proxies and measures are applied

in cases where data is not available yet or is not of the

required quality. Enhancement of core processes will

continue in 2026 through strategic programmes,

which are on track. ABN AMRO has defined the types

of exposures as well as objective criteria for

determining the capital approach for each type of

exposure. This process resulted in an update of the

‘return to compliance’ (RtC) plan, in which the

approaches for some types of exposure has been

changed to less sophisticated risk modelling

approaches. More information on this is provided in

the Credit risk management section.

• Dividend arbitrage. In the past, ABN AMRO’s legal

predecessor, Fortis Bank (Nederland) N.V., ABN AMRO

and several subsidiaries (including some former

subsidiaries) were directly or indirectly involved in


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≡	Risk, funding & capital	Management Control Statement

transactions relating to equity trading that extended

beyond dividend record dates, including several

forms of tainted dividend arbitrage, i.e. tainted

dividend stripping, including cum/ex and cum/cum

trading. ABN AMRO or subsidiaries could face

financial consequences as a result of their

involvement in those transactions. These could

include corporate administrative fines and other

measures under both criminal and civil law claims.

The bank has been implementing measures to

prevent any future involvement in tainted dividend

arbitrage.

Overall, continuous improvement to ensure compliance

with regulations requires a substantial, ongoing effort,

especially with regard to the regulatory areas

mentioned above.

Section D: Areas of attention identified by

senior management

The Executive Board has identified and agreed on the

following areas for improvement, which are being

actively managed by senior management:

• ICT risk: Economic and geopolitical challenges are

increasing the likelihood and severity of hybrid and

cyberattacks. To address cyber risks and disruptions,

and reduce vulnerability, ABN AMRO invests

continuously in solutions to prevent such attacks and

recover more quickly from potential incidents. The

effects of the DORA regulatory requirements that

have been implemented at the bank support a

resilient ICT environment. An initial target the bank

has achieved is compliance regarding most critical

payment functions for the bank. ABN AMRO continues

to make efforts to improve cybersecurity measures

while increasing the effectiveness of ICT risk

mitigation. ABN AMRO keeps abreast of emerging

trends, such as artificial intelligence, to ensure the ICT

landscape remains up to date in a controlled fashion.

Furthermore, ABN AMRO cooperates closely and

actively with other financial institutions, the Dutch

government and the Dutch central bank (DNB) to

prepare for unlikely but impactful events, in order to

ensure continuity of the Netherlands’ key payment

infrastructure. This task cannot be managed in

isolation.

• Third-party and outsourcing risk: The bank’s current

risk posture in relation to third-party and outsourcing

risk reflects a position of stronger control, while key

elements remain in transition towards full

effectiveness. The bank has moved from a

fragmented and partly compliance-driven set-up to a

more centralised and coordinated operating model in

the past two years, largely as a result of the DORA

implementation programme. Alongside these

improvements, several areas continue to require

focused management attention. Concentration risk,

particularly in relation to large IT and cloud service

providers, has increasingly become a structural

exposure that demands that we revisit our

outsourcing strategy. Geopolitical risk and broader

supply chain disruption are recognised as external

threat drivers of increasing relevance, while the

bank’s ability to demonstrate resilience in extreme but

plausible scenarios is growing. Although contract

management dashboards provide increased insight, a

fully consolidated overview across all relevant risk

domains is still being developed.

• Data risk: Data risk management is a critical enabler

of the bank’s strategic ambitions and regulatory

resilience. It underpins reliable decision-making,

supports innovation and digitalisation, and supports

the aim to comply with key regulatory requirements,

most notably BCBS239 for risk data aggregation and

reporting. To improve data quality, availability and

accountability, the bank applies a federated data

governance model, to ensure clear data ownership

and responsibilities / accountabilities across the data

value chain and fit-for-purpose data. Ongoing

enhancements to the data control framework are

aimed at further improving data completeness,

accuracy and timeliness to increase transparency

across the bank and strengthen control over data

distribution. In addition to enhancing regulatory

compliance and risk management, these

improvements also enable scalable reporting and the

responsible use of advanced analytics and artificial

intelligence, and therefore support the bank’s

strategic objectives directly.

• HR risk: Shifts in the labour market, such as ageing

workforces and skill mismatches, call for innovative

strategies (such as offshoring and nearshoring).

Additionally, the adoption of AI is transforming work

processes, creating a need for new skills, new roles

and collaboration between humans and machines.

Building internal expertise through upskilling and

mobility has become crucial to address these

changes. ABN AMRO's recruitment efforts attract vital

talent, but some specific vacancies can take longer to

fill than desired. To meet cost targets, ABN AMRO

introduced a hiring freeze in April 2025 and placed

restrictions on contract renewals. Despite the freeze,

focused sourcing remains essential to prevent gaps in

critical roles, such as data scientists and IT engineers,

as identified through the bank's strategic workforce

management processes. In a competitive labour

market characterised by persistent skill shortages,

ABN AMRO remains dedicated to attracting,


ABN AMRO	Annual Report 2025	129


≡	Risk, funding & capital	Management Control Statement

developing and retaining talent. In 2025, several

reorganisations were conducted within ABN AMRO

and its subsidiaries to ensure operational efficiency

and future readiness. In November 2025, it was

announced that the number of full-time employees

(FTEs) would be reduced by 5,200 by the end of 2028

compared with the end of 2024. Some of this

reduction was achieved during 2025 and a further

reduction will be achieved through natural attrition

over the next three years and through synergies and

efficiencies. All employees will be treated in a way

that honours local norms and ABN AMRO’s standards,

such as offering compensation in the Netherlands

through the bank’s social plan and assisting

employees in finding new employment opportunities.

Measures have been taken to minimise and mitigate

risks in the identified areas for improvement. These

include, among other things, the organisation-wide

initiatives to enhance ABN AMRO’s process landscape

and the initiatives to further strengthen its risk and

control framework.

Due to inherent limitations affecting risk management

and control systems, the foregoing does not imply that

these systems and procedures provide certainty as to

the achievement of strategic, operational, compliance

and reporting objectives or that they can prevent all

misstatements, inaccuracies, fraud, operational issues

and non-compliance with laws and regulations.


ABN AMRO	Annual Report 2025	130


≡	Risk, funding & capital	Additional risk, funding & capital disclosures	About risk, funding & capital

Additional risk, funding &

capital disclosures



	The following section includes additional disclosures on risk, funding and capital. This mandatory information is provided in accordance with EU IFRS and EDTF. This section is supplemental to the core analysis provided in the Risk, funding & capital review section and provides additional or more detailed information.

Additional information on exposure flows

Gross carrying amount – residential mortgages

Audited


				2025				2024
(in millions)	Stage 1¹	Stage 2¹	Stage 3 ^{1, 2}	Total ^{1, 2}	Stage 1¹	Stage 2¹	Stage 3 ^{1, 2}	Total ^{1, 2}
Balance as at 1 January	138,172	16,118	1,919	156,209	138,671	11,115	1,292	151,078
Transfer to stage 1	2,893	-2,850	-42		5,562	-5,523	-39
Transfer to stage 2	-4,058	4,442	-385		-11,651	11,966	-316
Transfer to stage 3	-283	-434	717		-795	-452	1,247
Additional drawdowns and partial repayments	-11,846	-1,276	-164	-13,286	-11,615	23	2	-11,591
Originated or purchased	24,058			24,058	18,978			18,978
Matured or repaid	-1,999	-522	-87	-2,608	-1,055	-931	-261	-2,247
Write-offs			-3	-3			-2	-2
Foreign exchange
Other movements	-1,032	-151	-2	-1,185	77	-80	-4	-7
Balance as at 31 December	145,906	15,327	1,952	163,185	138,172	16,118	1,919	156,209
1. Excluding fair value adjustments from hedge accounting.
2. Including POCI.

Gross carrying amount – consumer loans

Audited


				2025				2024
(in millions)	Stage 1¹	Stage 2¹	Stage 3 ^{1, 2}	Total ^{1, 2}	Stage 1¹	Stage 2¹	Stage 3 ^{1, 2}	Total ^{1, 2}
Balance as at 1 January	6,866	487	222	7,575	7,658	467	255	8,380
Transfer to stage 1	126	-121	-5		145	-136	-10
Transfer to stage 2	-150	156	-6		-237	265	-28
Transfer to stage 3	-24	-32	57		-43	-22	65
Additional drawdowns and partial repayments	-166	53	-8	-120	-512	56	-3	-460
Originated or purchased	1,409	9		1,418	1,237			1,237
Matured or repaid	-1,173	-130	-25	-1,328	-1,383	-143	-26	-1,552
Write-offs			-28	-28			-31	-31
Foreign exchange	-3			-3	1			1
Other movements	-1,134	-58	-56	-1,248
Balance as at 31 December	5,749	364	152	6,266	6,866	487	222	7,575
1. Excluding fair value adjustments from hedge accounting.
2. Including POCI.


ABN AMRO	Annual Report 2025	131


≡	Risk, funding & capital	Additional risk, funding & capital disclosures	About risk, funding & capital

Gross carrying amount – corporate loans

Audited


				2025				2024
(in millions)	Stage 1¹	Stage 2¹	Stage 3 ^{1, 2}	Total ^{1, 2}	Stage 1¹	Stage 2¹	Stage 3 ^{1, 2}	Total ^{1, 2}
Balance as at 1 January	72,227	8,490	3,110	83,827	73,324	10,308	3,152	86,784
Transfer to stage 1	2,554	-2,434	-119		2,983	-2,973	-10
Transfer to stage 2	-3,516	3,741	-226		-3,469	3,789	-320
Transfer to stage 3	-977	-748	1,726		-630	-713	1,343
Additional drawdowns and partial repayments	-6,028	-92	-418	-6,538	-4,054	1,175	-139	-3,019
Originated or purchased	26,600	40	81	26,721	22,541			22,541
Matured or repaid	-13,300	-1,781	-621	-15,703	-17,785	-3,082	-589	-21,456
Write-offs			-206	-206			-317	-317
Foreign exchange	-1,458	-62	-15	-1,535	854	50	21	925
Other movements	-45	-2	-3	-49	-1,536	-64	-30	-1,630
Balance as at 31 December	76,056	7,151	3,309	86,516	72,227	8,490	3,110	83,827
1. Excluding fair value adjustments from hedge accounting.
2. Including POCI.

Gross carrying amount – off-balance

Audited


				2025				2024
(in millions)	Stage 1	Stage 2	Stage 3¹	Total¹	Stage 1	Stage 2	Stage 3¹	Total¹
Balance as at 1 January	51,414	3,293	627	55,334	52,141	3,507	965	56,613
Transfer to stage 1	1,033	-1,024	-8		1,123	-1,120	-3
Transfer to stage 2	-1,352	1,411	-59		-1,171	1,260	-89
Transfer to stage 3	-233	-42	275		-160	-113	273
Additional drawdowns and partial repayments	-8,806	-246	-211	-9,263	-12,098	-246	-538	-12,882
Originated or purchased	12,749			12,749	11,397			11,397
Matured or repaid	-81	-47	-10	-138	-384		-4	-388
Foreign exchange	-676	-33	-6	-715	487	6	23	516
Other movements	80	3	2	85	79			79
Balance as at 31 December	54,127	3,316	610	58,052	51,414	3,293	627	55,334
1. Including POCI.

Additional information on impairment charges

Loan impairment charges and allowances – residential mortgages

Audited


				2025				2024
(in millions)	Stage 1	Stage 2	Stage 3²	Total²	Stage 1	Stage 2	Stage 3²	Total²
Balance as at 1 January	36	42	55	133	24	49	125	198
Transfer to stage 1	10	-12	-1	-3	19	-20	-3	-4
Transfer to stage 2	-2	20	-12	5	-2	37	-29	6
Transfer to stage 3		-3	11	8	-1	-5	21	16
Remeasurements¹	-18	-4	8	-14	-8	-17	-48	-73
Changes in risk parameters				-1	1	1	-1	1
Originated or purchased	6			6	4			4
Matured or repaid	-2	-3	-7	-12	-2	-3	-9	-14
Impairment charges (releases) on loans and advances	-6	-3	-1	-10	12	-7	-69	-64
Write-offs			-3	-3			-2	-2
Unwind discount / unearned interest accrued			1	1			1	1
Foreign exchange and other movements							1
Balance as at 31 December	29	39	52	120	36	42	55	133

Impairment charges (releases) on loans and advances	-6	-3	-1	-10	12	-7	-69	-64
Recoveries and other charges (releases)			-8	-8			-11	-11
Total impairment charges for the period	-6	-3	-9	-18	12	-7	-80	-75
1. Remeasurements represents the current year change of expected credit loss allowances mainly attributable to changes in volumes such as partial repayments and changes in the credit quality of existing loans remaining in their stage.
2. Including POCI.


ABN AMRO	Annual Report 2025	132


≡	Risk, funding & capital	Additional risk, funding & capital disclosures	About risk, funding & capital

Loan impairment charges and allowances – consumer loans

Audited


				2025				2024
(in millions)	Stage 1	Stage 2	Stage 3²	Total²	Stage 1	Stage 2	Stage 3²	Total²
Balance as at 1 January	12	15	102	130	18	11	118	147
Transfer to stage 1	5	-5	-4	-3	4	-3	-4	-4
Transfer to stage 2	-1	6	-6		-1	8	-6
Transfer to stage 3	-1	-2	35	32		-2	31	29
Remeasurements¹	-7	-5		-12	-9	1	-6	-15
Changes in models		1	1	1
Changes in risk parameters			1	1	-1		3	3
Originated or purchased	3			3	3			3
Matured or repaid	-1	-1	-3	-5	-1		-5	-6
Impairment charges (releases) on loans and advances	-1	-6	25	18	-5	4	12	11
Write-offs			-28	-28			-31	-31
Unwind discount / unearned interest accrued			1	1			3	3
Foreign exchange and other movements	-4	-3	-40	-47				-1
Balance as at 31 December	8	5	61	74	12	15	102	130

Impairment charges (releases) on loans and advances	-1	-6	25	18	-5	4	12	11
Recoveries and other charges (releases)			-25	-25			-25	-25
Total impairment charges for the period	-1	-6		-7	-5	4	-12	-13
1. Remeasurements represents the current year change of expected credit loss allowances mainly attributable to changes in volumes such as partial repayments and changes in the credit quality of existing loans remaining in their stage.
2. Including POCI.

Loan impairment charges and allowances – corporate loans

Audited


				2025				2024
(in millions)	Stage 1	Stage 2	Stage 3²	Total²	Stage 1	Stage 2	Stage 3²	Total²
Balance as at 1 January	119	170	811	1,100	192	228	833	1,254
Transfer to stage 1	66	-65	-4	-3	39	-47	-1	-10
Transfer to stage 2	-18	42	-21	3	-29	59	-8	23
Transfer to stage 3	-3	-26	112	83	-5	-23	164	137
Remeasurements¹	-99	-26	93	-33	-89	-29	102	-16
Changes in models	24	16	33	73
Changes in risk parameters	-2	-1		-3	-6	-5		-11
Originated or purchased	36			36	33			33
Matured or repaid	-15	-9	-35	-59	-15	-20	-25	-60
Impairment charges (releases) on loans and advances	-10	-70	178	98	-72	-64	232	96
Write-offs			-206	-206			-317	-317
Unwind discount / unearned interest accrued			29	29			22	22
Foreign exchange and other movements	1	-4	9	6	-2	6	40	45
Balance as at 31 December	109	96	821	1,026	119	170	811	1,100

Impairment charges (releases) on loans and advances	-10	-70	178	98	-72	-64	232	96
Recoveries and other charges (releases)			-43	-43			-48	-48
Total impairment charges for the period	-10	-70	135	55	-72	-64	184	48
1. Remeasurements represents the current year change of expected credit loss allowances mainly attributable to changes in volumes such as partial repayments and changes in the credit quality of existing loans remaining in their stage.
2. Including POCI.


ABN AMRO	Annual Report 2025	133


≡	Risk, funding & capital	Additional risk, funding & capital disclosures	About risk, funding & capital

Loan impairment charges and allowances – off-balance

Audited


				2025				2024
(in millions)	Stage 1	Stage 2	Stage 3²	Total²	Stage 1	Stage 2	Stage 3²	Total²
Balance as at 1 January	6	10	80	97	16	12	81	109
Transfer to stage 1	1	-2		-1	2	-2
Transfer to stage 2		2		2	-2	4		2
Transfer to stage 3		-1
Remeasurements¹	-4	-6	-4	-15	-10	-1	33	22
Changes in models				-1
Changes in risk parameters	5	1		6
Originated or purchased	5			5	5			5
Matured or repaid	-3	-2		-6	-4	-2		-7
Impairment charges (releases)	2	-7	-4	-9	-10	-1	33	22
Foreign exchange and other movements	1	1	-26	-24	1	-1	-34	-34
Balance as at 31 December	9	3	50	63	6	10	80	96

Impairment charges (releases) on off-balance	2	-7	-4	-9	-10	-1	33	22
Other charges (releases)
Total impairment charges for the period	2	-7	-4	-9	-10	-1	33	22
1. Remeasurements represents the current year change of expected credit loss allowances mainly attributable to changes in volumes such as partial repayments and changes in the credit quality of existing loans remaining in their stage.
2. Including POCI.

Additional information on forborne, past due and impaired (stage 3) loans

Forbearance credit quality

Audited


						31 December 2025
(in millions)	Total forborne assets	Forborne assets not past due and not stage 3 or POCI	Forborne assets past due, but not stage 3 or POCI	Impaired forborne assets	Specific allowance	Collective allowance	Total allowance
Loans and advances banks
Residential mortgages	979	469	112	397		19	19
Consumer loans¹	78	37		42	4	3	6
Corporate loans¹	3,703	2,096	6	1,602	319	76	394
Other loans and advances customers¹	2	2
Total loans and advances customers¹	4,762	2,603	118	2,040	322	97	419
Total loans and advances¹	4,762	2,603	118	2,040	322	97	419
Loans at FV through P&L	2	2
Total loans and advances	4,763	2,605	118	2,040	322	97	419
1. Excluding loans at fair value through P&L.


						31 December 2024
(in millions)	Total forborne assets	Forborne assets not past due and not stage 3 or POCI	Forborne assets past due, but not stage 3 or POCI	Impaired forborne assets	Specific allowance	Collective allowance	Total allowance
Loans and advances banks
Residential mortgages	1,045	525	106	413		23	23
Consumer loans¹	114	54	14	45	6	15	21
Corporate loans¹	3,932	2,107	100	1,725	342	96	438
Other loans and advances customers¹	1			1
Total loans and advances customers¹	5,092	2,687	220	2,186	349	134	483
Total loans and advances¹	5,092	2,687	220	2,186	349	134	483
Loans at FV through P&L	8	8
Total loans and advances	5,100	2,694	220	2,186	349	134	483
1. Excluding loans at fair value through P&L.


ABN AMRO	Annual Report 2025	134


≡	Risk, funding & capital	Additional risk, funding & capital disclosures	About risk, funding & capital

Forborne assets by geography

Audited


					31 December 2025
(in millions)	The Netherlands	Rest of Europe	USA	Asia	Rest of the world	Total
Loans and advances banks
Residential mortgages	975	3				979
Consumer loans¹	58	20				78
Corporate loans¹	2,587	1,050			67	3,703
Other loans and advances customers¹					2	2
Total loans and advances customers¹	3,620	1,073			69	4,762
Total loans and advances¹	3,620	1,073			69	4,762
Loans at FV through P&L	2					2
Total loans and advances	3,622	1,073			69	4,763
1. Excluding loans at fair value through P&L.


					31 December 2024
(in millions)	The Netherlands	Rest of Europe	USA	Asia	Rest of the world	Total
Loans and advances banks
Residential mortgages	1,020	24				1,045
Consumer loans¹	82	33				114
Corporate loans¹	2,969	846	42		76	3,932
Other loans and advances customers¹					1	1
Total loans and advances customers¹	4,070	902	42		78	5,092
Total loans and advances¹	4,070	902	42		78	5,092
Loans at FV through P&L	8					8
Total loans and advances	4,079	902	42		78	5,100
1. Excluding loans at fair value through P&L.

Forborne assets by business segment

Audited


(in millions)	31 December 2025	31 December 2024
Personal & Business Banking	2,108	1,924
Wealth Management	189	295
Corporate Banking	2,466	2,881
Total forborne assets	4,763	5,100

Forborne, past due and credit-impaired loans by geography


					31 December 2025
(in millions)	Forborne exposure	Exposures past due, but not stage 3 or POCI	Stage 3 exposures¹	Allowances for stage 3¹	Stage 3 charges for the period¹
The Netherlands	3,622	1,395	3,928	548	-32
Rest of Europe	1,073	544	1,373	332	170
USA		10	28	2	1
Asia			10	10	-9
Rest of the world	69	3	79	44	-5
Total loans and advances	4,763	1,953	5,417	935	125

					31 December 2024
	Forborne exposure	Exposures past due, but not stage 3 or POCI	Stage 3 exposures¹	Allowances for stage 3¹	Stage 3 charges for the period¹
The Netherlands	4,079	1,908	4,751	741	56
Rest of Europe	902	465	395	162	45
USA	42	15	1		-1
Asia			19	19
Rest of the world	78		91	48	-8
Total loans and advances	5,100	2,389	5,258	971	91
1. Including POCI.


ABN AMRO	Annual Report 2025	135


≡	Risk, funding & capital	Additional risk, funding & capital disclosures	About risk, funding & capital

Forborne and past due loans by industry


						31 December 2025
(in millions)	Gross carrying amount ^{4, 5}	Forborne exposures	Forborne ratio	Exposures past due, but not stage 3 or POCI	Past due ratio	Stage 3 exposures⁶	Stage 3 ratio ⁶
Loans and advances banks	2,174
Agriculture, forestry and fishing	6,574	442	6.7%	2	0.0%	200	3.0%
Mining and quarrying	1,499	19	1.2%	44	2.9%	15	1.0%
Manufacturing	5,448	588	10.8%	36	0.7%	427	7.8%
Electricity, gas, steam and air conditioning supply	2,661	74	2.8%	6	0.2%	112	4.2%
Water supply; sewerage, waste management and remediation activities	611	29	4.8%	11	1.8%	21	3.5%
Construction	3,077	168	5.5%	9	0.3%	112	3.6%
Wholesale and retail trade; repair of motor vehicles and motorcycles	7,712	610	7.9%	88	1.1%	509	6.6%
Transport and storage	7,908	211	2.7%	47	0.6%	156	2.0%
Real estate activities	13,189	333	2.5%	59	0.4%	206	1.6%
Accommodation and food service activities	1,909	221	11.6%	1	0.1%	147	7.7%
Information and communication	5,532	455	8.2%	3	0.1%	742	13.4%
Financial and insurance activities¹	19,166	111	0.6%	198	1.0%	114	0.6%
Professional, scientific & technical activities	2,464	73	3.0%	111	4.5%	231	9.4%
Administrative & support service activities	5,074	129	2.5%	6	0.1%	153	3.0%
Human health services & social work activities	2,636	166	6.3%	9	0.3%	102	3.9%
Other sectors²	1,057	73	7.0%	2	0.2%	62	5.9%
Total corporate loans	86,516	3,703	4.3%	633	0.7%	3,309	3.8%
Private individuals (residential mortgages and consumer loans)	169,450	1,057	0.6%	1,320	0.8%	2,104	1.2%
Other loans³	5,936	3	0.1%		0.0%	4	0.1%
Total non-industry classification	175,386	1,060	0.6%	1,320	0.8%	2,108	1.2%
Total loans and advances customers	261,902	4,763	1.8%	1,953	0.7%	5,417	2.1%
Total loans and advances	264,077	4,763	1.8%	1,953	0.7%	5,417	2.1%
1. Financial and insurance activities include asset managers, credit card companies and providers of personal financial services and securities, and brokers.
2. Other include loans to Public administration & defence, compulsory social security, Education, Arts, entertainment & recreation, Activities of households as employers, Activities of extraterritorial organisations & bodies and Other services.
3. Other loans include loans to Government and official institutions and default fund contributions for our clearing clients.
4. Excluding loans at fair value through P&L.
5. Excluding fair value adjustments from hedge accounting.
6. Including POCI.


ABN AMRO	Annual Report 2025	136


≡	Risk, funding & capital	Additional risk, funding & capital disclosures	About risk, funding & capital


						31 December 2024
(in millions)	Gross carrying amount ^{4, 5}	Forborne exposures	Forborne ratio	Exposures past due, but not stage 3 or POCI	Past due ratio	Stage 3 exposures⁶	Stage 3 ratio ⁶

Loans and advances banks	2,053
Agriculture, forestry and fishing	6,659	459	6.9%	40	0.6%	286	4.3%
Mining and quarrying	1,576	6	0.4%	7	0.4%		0.0%
Manufacturing	6,565	1,023	15.6%	130	2.0%	749	11.4%
Electricity, gas, steam and air conditioning supply	2,241	76	3.4%	6	0.3%	122	5.5%
Water supply; sewerage, waste management and remediation activities	664	144	21.7%	52	7.8%	43	6.4%
Construction	2,952	189	6.4%	123	4.2%	228	7.7%
Wholesale and retail trade; repair of motor vehicles and motorcycles	7,975	641	8.0%	46	0.6%	642	8.1%
Transport and storage	8,749	143	1.6%	32	0.4%	145	1.7%
Real estate activities	11,052	315	2.8%	113	1.0%	160	1.4%
Accommodation and food service activities	1,733	208	12.0%	13	0.7%	77	4.5%
Information and communication	4,851	125	2.6%	13	0.3%	97	2.0%
Financial and insurance activities¹	17,890	158	0.9%	77	0.4%	122	0.7%
Professional, scientific & technical activities	2,024	59	2.9%	29	1.4%	92	4.5%
Administrative & support service activities	5,358	139	2.6%	70	1.3%	141	2.6%
Human health services & social work activities	2,630	179	6.8%	14	0.5%	166	6.3%
Other sectors²	909	68	7.5%	7	0.8%	40	4.4%
Total corporate loans	83,827	3,932	4.7%	772	0.9%	3,110	3.7%
Private individuals (residential mortgages and consumer loans)	163,783	1,159	0.7%	1,616	1.0%	2,141	1.3%
Other loans³	6,489	9	0.1%		0.0%	6	0.1%
Total non-industry classification	170,273	1,168	0.7%	1,616	0.9%	2,147	1.3%
Total loans and advances customers	254,100	5,100	2.0%	2,389	0.9%	5,258	2.1%
Total loans and advances	256,153	5,100	2.0%	2,389	0.9%	5,258	2.1%
1. Financial and insurance activities include asset managers, credit card companies and providers of personal financial services and securities, and brokers.
2. Other include loans to Public administration & defence, compulsory social security, Education, Arts, entertainment & recreation, Activities of households as employers, Activities of extraterritorial organisations & bodies and Other services.
3. Other loans include loans to Government and official institutions and default fund contributions for our clearing clients.
4. Excluding loans at fair value through P&L.
5. Excluding fair value adjustments from hedge accounting.
6. Including POCI.


ABN AMRO	Annual Report 2025	137


≡	Risk, funding & capital	Additional risk, funding & capital disclosures	About risk, funding & capital

Maturity overview of assets and liabilities

Audited

The following tables show financial assets and liabilities

arranged by the earliest possible contractual maturity.

Contractual maturity of assets and liabilities

Audited


										31 December 2025
(in millions)	On demand	Trading deriva- tives	Up to one month	Between one and three months	Between three and six months	Between six and twelve months	Between one and two years	Between two and five years	More than five years	No maturity	Total
Assets:
Cash and balances at central banks	49,486										49,486
Financial assets held for trading	22		80	117	147	382	327	514	456		2,044
Derivatives		3,472	96	15	13	4	45	37	250		3,933
Financial investments	4		1,536	3,377	1,788	2,383	4,622	14,277	21,225	1,020	50,231
Securities financing	1,654		29,148	5,714	1,665	1,992					40,173
Loans and advances banks	876		737		1	201	12	146	198		2,170
Loans and advances customers	17,635		9,305	4,069	4,011	7,890	12,590	35,888	164,372		255,760
Other assets	1,768		2,670	671	1,527	25	128	789	1,832		9,411
Total assets	71,445	3,472	43,572	13,963	9,152	12,878	17,724	51,652	188,333	1,020	413,210
Liabilities:
Financial liabilities held for trading			166	41	150	76	268	494	436		1,631
Derivatives		1,472	42	50	16	10	1	52	324		1,967
Securities financing	179		14,130	454	395	162					15,320
Due to banks	1,105		1,680	534	476	29	58	269	169		4,320
Due to customers	235,543		21,766	5,206	3,955	4,051	2,227	1,627	4,751		279,126
Issued debt			4,626	4,565	7,316	2,648	9,287	20,992	24,638		74,072
- of which senior secured			1,260	72	164	111	1,883	5,930	16,616		26,036
- of which senior unsecured			776	16	2,445	2,536	7,403	15,063	8,022		36,263
- of which other			2,590	4,477	4,706						11,773
Subordinated liabilities					854		1,564	764	1,764		4,946
Other liabilities	1,282		2,548	440	389	22	78		26		4,786
Total liabilities	238,110	1,472	44,959	11,291	13,550	6,996	13,482	24,199	32,107		386,167
Total equity										27,043	27,043
Total liabilities and equity	238,110	1,472	44,959	11,291	13,550	6,996	13,482	24,199	32,107	27,043	413,210
Off-balance sheet liabilities
Committed credit facilities	55,240										55,240
Guarantees and other commitments	6,609										6,609
Total off-balance sheet liabilities	61,849										61,849


ABN AMRO	Annual Report 2025	138


≡	Risk, funding & capital	Additional risk, funding & capital disclosures	About risk, funding & capital


										31 December 2024
(in millions)	On demand	Trading deriva- tives	Up to one month	Between one and three months	Between three and six months	Between six and twelve months	Between one and two years	Between two and five years	More than five years	No maturity	Total
Assets:
Cash and balances at central banks	44,464										44,464
Financial assets held for trading	85		30	169	176	319	202	663	860		2,503
Derivatives		3,892	27		2	3	2	102	318		4,347
Financial investments	932		2,246	1,115	2,613	3,125	4,959	13,334	17,873	977	47,173
Securities financing	1,584		20,935	3,043	922	505					26,989
Loans and advances banks	788		783	12	3	52	34	225	152		2,049
Loans and advances customers	17,757		7,454	4,497	3,976	7,399	12,562	36,445	158,692		248,782
Other assets	2,513		3,115	906	1,423	23	277	190	292		8,739
Total assets	68,123	3,892	34,590	9,742	9,115	11,426	18,036	50,959	178,188	977	385,047
Liabilities:
Financial liabilities held for trading			85	159	9	64	60	263	523		1,163
Derivatives		2,119	54	3	4	18	36	37	228		2,499
Securities financing	101		9,649	601							10,352
Due to banks	1,128		632	377	78	6	5	2	102		2,329
Due to customers	194,039		38,379	7,202	4,515	3,013	1,091	1,453	6,493		256,186
Issued debt			6,471	7,608	10,988	1,910	7,638	13,449	26,478		74,542
- of which senior secured				51	38	485	1,589	2,988	18,770		23,921
- of which senior unsecured			1,862		5,218	1,401	6,050	10,462	7,707		32,700
- of which other			4,608	7,557	5,732	24					17,922
Subordinated liabilities			4			1,452	935	2,374	1,848		6,613
Other liabilities	3,255		829	494	543	21	102	6	5		5,254
Total liabilities	198,523	2,119	56,103	16,444	16,136	6,484	9,867	17,584	35,677		358,939
Total equity										26,108	26,108
Total liabilities and equity	198,523	2,119	56,103	16,444	16,136	6,484	9,867	17,584	35,677	26,108	385,047
Off-balance sheet liabilities
Committed credit facilities	52,617										52,617
Guarantees and other commitments	6,638										6,638
Total off-balance sheet liabilities	59,255										59,255


ABN AMRO	Annual Report 2025	139


≡	Risk, funding & capital	Additional risk, funding & capital disclosures	About risk, funding & capital

Maturity based on contractual undiscounted

cash flows

Audited

The following tables show financial assets and liabilities

arranged by their earliest possible contractual maturity.


										31 December 2025
	On demand	Trading deriva- tives	Up to one month	Between one and three months	Between three and six months	Between six and twelve months	Between one and two years	Between two and five years	More than five years	No maturity	Total
Assets:
Cash and balances at central banks	49,486										49,486
Financial assets held for trading	22		81	122	159	400	351	545	482		2,161
Derivatives		3,472	140	153	340	607	1,039	2,091	2,255		10,096
Financial investments	4		1,580	3,547	2,184	3,087	5,796	16,083	22,868	1,020	56,168
Securities financing	1,654		29,206	5,761	1,707	2,004					40,333
Loans and advances banks	876		760	39	99	334	230	473	497		3,307
Loans and advances customers	17,635		9,649	5,388	7,235	13,789	23,061	56,601	184,833		318,191
Other assets	1,768		2,671	672	1,530	30	136	803	1,845		9,455
Total undiscounted assets	71,445	3,472	44,088	15,683	13,253	20,250	30,612	76,596	212,779	1,020	489,197
- of which:
Gross settled derivatives not held for trading:
Contractual amounts receivable			148	128	61	69	73	61	1		541
Contractual amounts payable			65	70	45	54	81	75	4		395
Total undiscounted gross settled derivatives not held for trading			83	58	16	15	-8	-14	-3		146
Net settled derivatives not held for trading			71	110	83	256	465	1,264	2,321		4,571
Liabilities:
Financial liabilities held for trading			168	45	160	94	295	529	466		1,758
Derivatives		1,472	116	313	605	1,085	2,022	4,218	4,579		14,411
Securities financing	179		14,157	460	401	163					15,360
Due to banks	1,105		1,686	544	489	46	85	300	194		4,449
Due to customers	235,543		21,793	5,259	4,050	4,167	2,378	1,900	5,015		280,104
Issued debt			4,717	4,901	8,068	3,943	11,327	23,891	27,210		84,058
Subordinated liabilities			10	41	948	162	1,760	1,096	2,076		6,095
Other liabilities	1,282		2,539	431	381	17	76	-6	20		4,741
Total liabilities	238,110	1,472	45,187	11,996	15,102	9,676	17,943	31,928	39,561		410,975
- of which:
Gross settled derivatives not held for trading:
Contractual amounts receivable			123	147	67	50	90	191	62		730
Contractual amounts payable			61	80	43	41	70	148	48		490
Total undiscounted gross settled derivatives not held for trading			-62	-67	-24	-9	-20	-43	-14		-240
Net settled derivatives not held for trading			17	-19	-118	73	47	388	310		699
Net liquidity gap	-166,665	2,000	-1,099	3,687	-1,849	10,574	12,669	44,668	173,218	1,020	78,223
Off-balance sheet liabilities
Committed credit facilities	55,240										55,240
Guarantees and other commitments	6,609										6,609
Total off-balance sheet liabilities	61,849										61,849


ABN AMRO	Annual Report 2025	140


≡	Risk, funding & capital	Additional risk, funding & capital disclosures	About risk, funding & capital


										31 December 2024
(in millions)	On demand	Trading deriva- tives	Up to one month	Between one and three months	Between three and six months	Between six and twelve months	Between one and two years	Between two and five years	More than five years	No maturity	Total
Assets:
Cash and balances at central banks	44,464										44,464
Financial assets held for trading	85		32	176	191	343	242	722	912		2,702
Derivatives		3,892	96	260	649	1,223	2,300	4,393	4,332		17,146
Financial investments	932		2,286	1,265	2,969	3,738	5,952	14,812	19,203	977	52,134
Securities financing	1,584		20,981	3,070	940	509					27,083
Loans and advances banks	788		815	61	123	259	387	637	491		3,561
Loans and advances customers	17,757		7,824	5,926	7,462	13,783	23,881	58,666	180,604		315,901
Other assets	2,513		3,118	910	1,429	29	284	201	302		8,786
Total undiscounted assets	68,123	3,892	35,152	11,667	13,762	19,884	33,046	79,431	205,844	977	471,778
- of which:
Gross settled derivatives not held for trading:
Contractual amounts receivable			255	253	149	114	175	355	117		1,418
Contractual amounts payable			140	157	81	73	140	254	76		921
Total undiscounted gross settled derivatives not held for trading			115	96	68	41	36	101	41		497
Net settled derivatives not held for trading				183	128	243	495	1,076	1,636		3,761
Liabilities:
Financial liabilities held for trading			86	162	16	77	83	301	559		1,285
Derivatives		2,119	138	292	716	1,304	2,171	4,398	4,601		15,739
Securities financing	101		9,670	605							10,376
Due to banks	1,128		635	381	81	11	13	22	122		2,394
Due to customers	194,039		38,431	7,277	4,637	3,169	1,336	1,933	6,967		257,788
Issued debt			6,568	7,954	11,705	3,100	9,534	16,595	29,415		84,870
Subordinated liabilities			18	56	139	1,670	1,260	2,769	2,178		8,090
Other liabilities	3,255		826	486	535	17	101	5	4		5,228
Total liabilities	198,523	2,119	56,371	17,212	17,830	9,349	14,498	26,023	43,846		385,771
- of which:
Gross settled derivatives not held for trading:
Contractual amounts receivable			109	27	52	52	29	12	19		300
Contractual amounts payable			71	36	32	58	29	10	12		248
Total undiscounted gross settled derivatives not held for trading			-38	9	-20	6		-2	-7		-51
Net settled derivatives not held for trading			180	-153	20	98	39	379	961		1,525
Net liquidity gap	-130,400	1,773	-21,219	-5,545	-4,068	10,535	18,548	53,408	161,998	977	86,007
Off-balance sheet liabilities
Committed credit facilities	52,617										52,617
Guarantees and other commitments	6,638										6,638
Total off-balance sheet liabilities	59,255										59,255


ABN AMRO	Annual Report 2025	141


≡	Risk, funding & capital	Additional risk, funding & capital disclosures	About risk, funding & capital

Expected maturity based on behavioural

models

Audited

The following table provides an overview of the

amounts expected to be settled within twelve months

and after twelve months, based on the behavioural

maturity profile.


		31 December 2025			31 December 2024
(in millions)	Up to one year	More than one year	Total	Up to one year	More than one year	Total
Assets
Cash and balances at central banks	49,486		49,486	44,464		44,464
Financial assets held for trading	2,044		2,044	2,503		2,503
Derivatives	3,474	460	3,933	3,891	455	4,347
Financial investments	10,145	40,086	50,231	9,971	37,202	47,173
Securities financing	39,555	618	40,173	26,589	400	26,989
Loans and advances banks	1,780	390	2,170	1,510	540	2,049
Loans and advances customers	63,184	192,576	255,760	59,517	189,265	248,782
Equity-accounted investments		233	233		244	244
Property and equipment	1,014	207	1,221	801	267	1,068
Goodwill and other intangible assets	356		356	253		253
Assets held for sale	2,466		2,466	1,330		1,330
Tax assets	143		143	326		326
Other assets	4,727	266	4,993	4,911	607	5,518
Total assets	178,374	234,836	413,210	156,067	228,980	385,047
Liabilities
Financial liabilities held for trading	1,631		1,631	1,163		1,163
Derivatives	1,472	495	1,967	2,125	374	2,499
Securities financing	15,131	188	15,320	10,256	96	10,352
Due to banks	3,762	558	4,320	2,162	167	2,329
Due to customers	92,440	186,686	279,126	88,593	167,593	256,186
Issued debt	16,903	57,169	74,072	26,214	48,328	74,542
Subordinated liabilities	860	4,086	4,946	1,446	5,167	6,613
Provisions	661	5	666	605	7	612
Liabilities held for sale	20		20
Tax liabilities	183		183	395		395
Other liabilities	3,912	6	3,918	4,239	7	4,247
Total liabilities	136,974	249,193	386,167	137,199	221,740	358,939

The behavioural maturity profile is based on internally

developed liquidity risk models. These models cover

residential mortgages, consumer and corporate loans,

non-maturing assets (mainly current accounts), credit

cards, non-maturing liabilities (demand deposits and

current accounts) and term deposits. The liquidity risk

models predict the behavioural cash flows, which can

differ from the contractual cash flows as a result of, for

example, prepayments or because some products do

not have a defined contractual maturity date.

The models are based on historically observed client

behaviour and use a combination of internal and

external risk drivers. The models are used to monitor

the bank’s liquidity mismatch position.

The liquidity risk models are included in the bank’s

model risk management framework. This means that

the models have to follow a regular monitoring and

validation schedule. The Methodology Acceptance

Group (MAG) ALM/T gives approval for the models,

based on independent advice from Model Validation.


ABN AMRO	Annual Report 2025	142


≡	Risk, funding & capital	Additional risk, funding & capital disclosures	About risk, funding & capital

About risk, funding & capital

Regulatory requirements

The Risk, funding & capital chapter presents the

disclosures required under the Dutch Financial

Supervision Act (Wet op financieel toezicht – Wft),

Title 9, Book 2 of the Dutch Civil Code and EU IFRS.

ABN AMRO also embraces the Enhanced Disclosure

Task Force (EDTF) principles and recommendations.

Certain disclosures in the Risk, funding & capital chapter

are an integral part of the Consolidated Annual Financial

Statements (AFS) and contain audited information.

The parts concerning risk disclosures of financial

instruments (IFRS 7) have been audited. Information

that has been audited in these sections is labelled

‘Audited’ in the respective headings. The audited

sections run until the next same-level heading that is

not labelled ʻAudited’.

Risk exposure measurement and scope

differences

Risk measures vary according to the purpose for which

the exposure is calculated: EU IFRS or the determination

of regulatory or economic capital (CRD V/CRR III).

EU IFRS reporting scope

The objective of the financial statements is to provide

primary users of these financial statements with useful

financial information about the bank in order to support

their decisions. Financial information is useful when it is

relevant and reliably represents what it purports to

represent. Financial statements provide information

about the financial position of the bank and the effects

of transactions and other events that change the bank’s

financial position and performance. The consolidation

scope of ABN AMRO is determined in accordance with

IFRS 10 Consolidated Financial Statements. More

information can be found in Note 1 Accounting policies

in the Consolidated Annual Financial Statements.

Regulatory reporting scope

The objective of regulatory reporting is to take a risk

view on the bank’s portfolio and to ensure that the bank

maintains sufficient capital buffers to cover unexpected

losses, and sufficient liquidity buffers. The scope of

consolidation for the purpose of calculating regulatory

and economic capital (based on CRD V and CRR III) is

based on the same concept of control as applies for

EU IFRS. However, subsidiaries consolidated under

EU IFRS but active in sectors other than banking and

finance are excluded from the regulatory scope of

consolidation.


ABN AMRO	Annual Report 2025	143

Leadership & governance


ABN AMRO	Annual Report 2025	144


≡	Leadership & governance	Leadership and governance structure	Executive Board composition

Leadership and governance

structure

Executive Board composition

Introduction to leadership & governance

Good corporate governance is critical for us to realise

our ambition of being a trusted and professional partner

for all our stakeholders: our clients, investors,

employees and society at large.

ABN AMRO has a two-tier governance model consisting

of a Supervisory Board and an Executive Board. In this

chapter we report on the set-up of our corporate

governance, division of duties and responsibilities, and

decision-making during the year 2025.

Role and responsibilities of the Executive

Board

The Executive Board is the statutory managing board of

ABN AMRO within the meaning of Article 129, Book 2,

of the Dutch Civil Code. It is responsible, among other

things, for: (i) the general course of business of

ABN AMRO, ensuring compliance with laws and

regulations and the adequate financing of its activities,

(ii) the continuity of ABN AMRO and its business, aimed

at sustainable long-term value creation for ABN AMRO

and taking into account interests of stakeholders, and

(iii) setting and realising ABN AMRO’s mission, strategy,

risk appetite, risk framework, budgets, financial and

non-financial targets.

The Executive Board ensures close cooperation with the

Supervisory Board in the discharge of its responsibilities

and seeks the Supervisory Board’s approval for the

bank-wide strategy in line with the pursued culture

aimed at sustainable long-term value creation and

targets. The Executive Board is accountable to the

Supervisory Board and to the General Meeting for the

performance of its duties. In performing its duties, the

Executive Board develops a view on sustainable long-

term value creation for ABN AMRO and its business and

considers relevant stakeholder interests.

Composition and diversity

The Executive Board consisted of the Chief Executive

Officer (CEO), the Chief Financial Officer (CFO), the

Chief Risk Officer (CRO), the Chief Innovation &

Technology Officer (CI&TO), three Chief Commercial

Officers (CCOs) (Personal & Business Banking,

Corporate Banking and Wealth Management) and the

Chief Operations Officer (COO). The COO role ceased

to be part of the Executive Board with effect from

1 January 2026. The COO’s responsibilities have been

redistributed among members of the Executive Board.

The Executive Board’s composition is based on

ABN AMRO’s guiding principle that diversity of thought,

expertise, background, competences and interpersonal

styles is a prerequisite for effective management and,

by extension, for sustainable long-term value creation.

The vision set by ABN AMRO is to become a company

that mirrors, at all levels, the diversity of the

communities in which it operates. A diverse Executive

Board fosters a variety of views and experiences and

facilitates independent opinions and sound decision-

making within the Executive Board.

To that effect, the following diversity aspects are

relevant for the composition of the Executive Board:

gender, age, educational and professional background,

and geographical provenance. The Supervisory Board

considered these aspects for the appointment in 2025.

In line with ABN AMRO’s diversity policy, ABN AMRO

strives to meet its gender target. According to ABN

AMRO’s gender diversity target, at least one-third (1/3)

of ABN AMRO’s Executive Board should consist of the

underrepresented gender. As at 1 January 2026, the

Executive Board consisted of three male members and

four female members.

When vacancies arise and in succession planning,

ABN AMRO gives due consideration to any applicable

diversity requirements in its search for suitable new

members who meet the fit and proper requirements

stipulated in the Dutch Financial Markets Supervision

Act.

The Rules of Procedure of the Executive Board are

available on our website. These Rules of Procedure

were last updated in 2025, based on changes to our


ABN AMRO	Annual Report 2025	145


≡	Leadership & governance	Leadership and governance structure	Executive Board composition

organisational structure, relevant legislative and

regulatory guidance.

Diversity of Executive Board

ESRS

(female/male, average in %)

On 1 August 2024, ABN AMRO announced that Robert

Swaak would not complete his second term. In

consultation with the Supervisory Board, it was decided

that he would step down in the first half of 2025. To

ensure continuity of decision-making, it was agreed that

Robert Swaak would remain in his role until his

successor was appointed. On 10 January 2025, the

Supervisory Board announced in a press release its

intention to appoint Marguerite Bérard as a new

member of the Executive Board and as CEO of

ABN AMRO. Following the Annual General Meeting held

on 23 April 2025, Marguerite Bérard was appointed as

CEO and member of ABN AMRO’s Executive Board for a

period of four years, meaning her term will conclude at

the closure of the Annual General Meeting of

Shareholders in 2029.

On 12 November 2025, ABN AMRO announced that

Ton van Nimwegen, COO and member of the Executive

Board, would step down as COO and member of the

Executive Board as of 1 January 2026. Following the

announced departure, the Executive Board thoroughly

considered the possibilities to further simplify the bank,

in line with the strategic direction. As a result, the

decision was made not to replace the COO, and to

redistribute the current COO responsibilities among

members of the Executive Board.

On 25 November 2025, ABN AMRO announced that, at

the upcoming Annual General Meeting, the Supervisory

Board of ABN AMRO intends to nominate Chief

Commercial Officers Annerie Vreugdenhil (Personal &

Business Banking), Choy van der Hooft-Cheong (Wealth

Management) and Dan Dorner (Corporate Banking) for

a second term of four years as their current term will

expire in 2026. This continuity will ensure ownership of

the aforementioned plans and maintain the necessary

leadership to achieve the ambitions in our strategy.

Relevant experience

ESRS

All members of the Executive Board have passed the fit

and proper test required under the relevant legal

requirements stemming either from applicable EU law

or applicable national law. The Executive Board has

experience relevant to the sectors, products and

geographic locations of ABN AMRO. Further information

on relevant experience is provided in the Executive

Board’s résumés as published on our website.

Appointment, suspension and dismissal

The Supervisory Board (re)appoints members of the

Executive Board for a term of up to four years, provided

that the term of office continues up to and including the

first Annual General Meeting to be held after expiry of

the term. When preparing the appointment and

reappointment of the members of the Executive Board,

the Selection & Nomination Committee and the

Supervisory Board consider the diversity objectives laid

down in ABN AMRO’s internal policies. Only candidates

who meet the fit and proper test under the relevant

legal requirements stemming either from applicable EU

law or applicable national law are eligible for

appointment.

The Employee Council renders advice on the

appointment of members of the Executive Board. The

Supervisory Board notifies the General Meeting of the

intended appointment or reappointment of a member

of the Executive Board, accompanied by a short résumé

of the candidate including the candidate’s age, gender,

educational and professional background, and

geographical provenance.

The Supervisory Board may appoint one of the

members of the Executive Board as Chair (to be granted

the title of Chief Executive Officer). Pursuant to the

relationship agreement with NLFI, the Supervisory Board

will give NLFI the opportunity to advise on the decision

to appoint or reappoint any member of the Executive

Board, as long as NLFI directly or indirectly holds at

least 10% of the issued share capital of the bank. The

Supervisory Board may at all times suspend or dismiss

a member of the Executive Board.

Further information on the suspension and dismissal

procedure of the Executive Board is provided in

ABN AMRO’s Articles of Association and the Rules of

Procedure of the Executive Board as published on

our website.


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≡	Leadership & governance	Leadership and governance structure	Executive Board composition

Executive Board


	Executive Board (from left to right): Carsten Bittner, Serena Fioravanti, Marguerite Bérard, Ferdinand Vaandrager, Annerie Vreugdenhil, Dan Dorner, Choy van der Hooft-Cheong

Personal details of the members of the Executive Board

The personal details of all members of the Executive Board who were active in 2025 can be found on our website.

The information below refers to the members of the Executive Board as at 10 March 2026.



	Marguerite BérardFrench, female, 1977
	Marguerite Bérard was appointed as CEO and Chair of the Executive Board of ABN AMRO, effective 23 April 2025. As CEO, Marguerite Bérard is also responsible for Brand, Marketing & Communications, Group Audit, Group Economics, Human Resources, Legal & Corporate Office, Strategy & Transformation and the Sustainability Centre of Excellence. Her current term ends at the close of ABN AMRO’s Annual General Meeting in 2029.	Relevant positions pursuant to CRD V Chief Executive Officer and Chair of the Executive Board of ABN AMRO Bank N.V., member of the non- executive board, independent director and member of the Audit Committee of Carrefour Group S.A.

Chief Executive Officer and Chair of the Executive Board



	Dan Dorner Dutch, male, 1976
	Dan Dorner was appointed to the Executive Board of ABN AMRO as CCO Corporate Banking, effective 24 November 2021. As CCO Corporate Banking, he is responsible for the client unit Corporate Banking. Dan Dorner was appointed Vice-Chair of the Executive Board with effect from 1 April 2023. His current term ends at the close of ABN AMRO’s Annual General Meeting in 2026. On 25 November 2025, the Supervisory Board of ABN AMRO announced its intention to nominate Dan Dorner for a second term of four years.	Relevant positions pursuant to CRD V Chief Commercial Officer Corporate Banking and Vice-Chair of the Executive Board of ABN AMRO Bank N.V. Other relevant ancillary positions Member of the Advisory Board of Euronext, member of the general board and of the daily board of Vereniging VNO-NCW (Confederation of Netherlands Industry and Employers).

Chief Commercial Officer Corporate Banking and Vice- Chair of the Executive Board


ABN AMRO	Annual Report 2025	147


≡	Leadership & governance	Leadership and governance structure	Executive Board composition



	Carsten Bittner German, male, 1971
	Carsten Bittner was appointed to the Executive Board of ABN AMRO as CI&TO, effective 1 January 2023. As CI&TO, he is responsible for Innovation and Technology, including the Central Data Office, Change Management & Consultancy, the Corporate Information Security Office, IT, Platforms & Technology, Procurement, CC&OPS and BPM Process Management. His current term ends at the close of ABN AMRO’s Annual General Meeting in 2027.	Relevant positions pursuant to CRD V Chief Innovation & Technology Officer of the Executive Board of ABN AMRO Bank N.V.

Chief Innovation & Technology Officer



	Serena Fioravanti Italian and Swiss, female, 1973
	Serena Fioravanti was appointed to the Executive Board of ABN AMRO as Chief Risk Officer, effective 1 October 2024. As CRO, she is responsible for Risk Management, including Central Risk Management, Compliance, Credit Risk, Financial Restructuring & Recovery, Information & Operational Risk Management, Market & ALM/T Risk, Model Validation & Model Risk Management, Regulatory Model Management Unit, Risk Modelling, Security & Intelligence Management and First Line Risk & Privacy. Her current term ends at the close of ABN AMRO’s Annual General Meeting in 2029.	Relevant positions pursuant to CRD V Chief Risk Officer of the Executive Board of ABN AMRO Bank N.V. Other relevant ancillary position Lecturer at the University of Zurich, member of the Board of Directors of the Swiss Risk Association, member of the Supervisory Board of Migros Bank AG.

Chief Risk Officer



	Choy van der Hooft-Cheong Dutch, female, 1971
	Choy van der Hooft-Cheong was appointed to the Executive Board of ABN AMRO as CCO Wealth Management, effective 24 November 2021. As CCO Wealth Management, she is responsible for the client unit Wealth Management. Her current term ends at the close of ABN AMRO’s Annual General Meeting in 2026. On 25 November 2025, the Supervisory Board of ABN AMRO announced its intention to nominate Choy van der Hooft-Cheong for a second term of four years.	Relevant positions pursuant to CRD V Chief Commercial Officer Wealth Management and member of the Executive Board of ABN AMRO Bank N.V. Other relevant ancillary positions Founder and board member of Stichting Children’s Khazana Foundation, chair of the statutory board of Stichting Talent naar de Top, member of the Supervisory Council of Stichting de Oude Kerk Amsterdam, chair of the board of Stichting ABN AMRO Art & Heritage.

Chief Commercial Officer Wealth Management



	Ferdinand Vaandrager Dutch, male, 1970
	Ferdinand Vaandrager was appointed to the Executive Board of ABN AMRO Bank N.V. as interim Chief Financial Officer, effective 1 May 2023. He was appointed to the Executive Board of ABN AMRO Bank N.V. as Chief Financial Officer, effective 16 November 2023. As CFO, Ferdinand Vaandrager is responsible for Finance, including Asset & Liability Management and Treasury, Corporate Controlling, Corporate Development, Finance & Risk Business Grids, Financial Accounting, Investor Relations, Tax and Workplace Management. His current term ends at the close of ABN AMRO’s Annual General Meeting in 2027.	Relevant positions pursuant to CRD V Chief Financial Officer of the Executive Board of ABN AMRO Bank N.V.

Chief Financial Officer



	Annerie Vreugdenhil Dutch, female, 1963
	Annerie Vreugdenhil was appointed to the Executive Board of ABN AMRO as CCO Personal & Business Banking, effective 1 March 2022. As CCO Personal & Business Banking, she is responsible for the client unit Personal & Business Banking, including Detecting Financial Crime and Customer Data Solutions. Her term ends at the close of ABN AMRO’s Annual General Meeting in 2026. On 25 November 2025, the Supervisory Board of ABN AMRO announced its intention to nominate Annerie Vreugdenhil for a second term of four years.	Relevant positions pursuant to CRD V Chief Commercial Officer Personal & Business Banking and member of the Executive Board of ABN AMRO Bank N.V., member of the Supervisory Board of Stadsherstel Amsterdam N.V., non- executive member of the Board of EPI Company SE. Other relevant ancillary positions Member of the Board of Directors of the Nederlandse Vereniging van Banken (NVB), member of the Advisory Board of the Erasmus Centre for Data Analytics (ECDA), Chair of the Board of Stichting ABN AMRO Foundation.

Chief Commercial Officer Personal & Business Banking


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≡	Leadership & governance	Leadership and governance structure	Executive Board composition

Committees

The Executive Board has established a number of

committees that are responsible for preparing the

decision-making on certain subjects, taking certain

delegated decisions and advising the Executive Board

on certain matters.

Executive Board

Credit Chain

Oversight

Committee

Group

Risk

Committee

Group

Central Credit

Committee

Regulatory

Committee

Group Asset

& Liability

Committee

Group

Disclosure

Committee

Group Data

Committee

During 2025, the Executive Board established a Credit

Chain Oversight Committee (CCOC). The CCOC acts as

an oversight and decision-making committee of the

Executive Board for ABN AMRO Group’s end-to-end

credit chain change management, with a focus on

regulatory compliance. The purpose of the CCOC is to

maintain oversight and steer the delivery of change

along the end-to-end credit chain bank-wide, including

bank-wide programmes and change owners that

deliver change to components that are integral to an

efficient and compliant credit chain, and to decide on

the matters within the mandate determined by the

Executive Board.

The Executive Board has three risk-related committees:

• the Group Risk Committee;

• the Group Central Credit Committee.

• the Regulatory Committee;

More information on the delegated authority of these

committees is provided in the Risk, funding & capital

chapter.

In addition, the Executive Board installed a Group Asset

& Liability Committee, a Group Disclosure Committee

and a Group Data Committee.

The Group Asset & Liability Committee is mandated by

the Executive Board to decide on matters relating to the

interest rate and liquidity risk profile, as well as the

group’s solvency, within the parameters set by the

Executive Board.

The Group Disclosure Committee’s responsibilities

include advising and supporting the Executive Board in

relation to (i) supervision of the accuracy, effectiveness

and timeliness of public disclosures by the group, and

(ii) integrity with regard to the financial statements and

other public disclosures as required by Dutch and

European legislation, in particular (but not limited to)

financial and non-financial disclosures, changes to

group target ratios, prospectus disclosures, stress tests,

public corporate governance statements, changes in

key capital requirements (SREP), changes in dividend

policy, changes in ratings and disclosures about

environmental, social and governance (ESG)

performance, social and employee matters, human

rights performance and anti-corruption and anti-bribery

matters.

The Group Data Committee assists and supports the

Executive Board in the performance of its duties relating

to data management, data governance and data quality.

The Group Data Committee oversees the adoption of

the group’s governance with regard to data

management, data quality and reporting as part of the

overall risk management framework, as well as the

group’s key performance indicators, key risk indicators

and its performance in this respect.

During 2025, the Executive Board decided to disband

the Group Sustainability Committee to simplify and

strengthen the integration of sustainability-related

matters within the bank's governance and processes.

It was decided to integrate sustainability into the

committee structure rather than having a standalone

sustainability committee, and to rely on strong

coordination between the Executive Board and

Executive Board committees as well as the Supervisory

Sustainability Committee and Supervisory Board.

Sustainability topics are regularly discussed in the

decision-making bodies. More information on the

allocation of tasks and responsibilities in relation to

sustainability governance is provided in the Governance

section of the Sustainability Statements.


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≡	Leadership & governance	Leadership and governance structure	Supervisory Board composition

Supervisory Board composition

Role and responsibilities of the

Supervisory Board

The Supervisory Board supervises, advises, challenges

and supports the Executive Board in the exercise of its

powers and duties. Together with the Executive Board,

the Supervisory Board is responsible for ABN AMRO’s

sustainable long-term value creation. Members must

execute their duties in a sustainable manner with due

observance of the long-term viability of the pursued

strategy. In discharging its task, the Supervisory Board

takes into account the dynamics and the relationship

between the Executive Board and its members. The

Supervisory Board must be involved with the Executive

Board early and closely when formulating the bank-

wide strategy and targets (in line with the pursued

culture aimed at sustainable long-term value creation).

In performing their duties, the members of the

Supervisory Board are guided by the interests of

ABN AMRO and its associated businesses. They take due

consideration of the legitimate interests of all of

ABN AMRO’s stakeholders: our clients, investors,

employees and society at large. Certain decisions taken

by the Executive Board are subject to the approval of

the Supervisory Board.

Changes in 2025

At the Annual General Meeting of 23 April 2025,

Mariken Tannemaat was reappointed to the Supervisory

Board for a period of four years.

During the Annual General Meeting held on

24 April 2024, Arjen Dorland was re-appointed for

a period of two years. Arjen Dorland informed the

Supervisory Board that he would not apply for another

term and, if a successor became available, he would be

willing to step down before the close of the Annual

General Meeting in 2026 to focus on his other positions.

On 18 July 2025 ABN AMRO issued a press release

announcing the nomination of Daniel Hartert for a

four-year term, succeeding Arjen Dorland. At the

Extraordinary General Meeting on 11 September 2025,

Daniel Hartert was appointed as a member of

ABN AMRO’s Supervisory Board for a term of office

which ends at the close of the Annual General Meeting

in 2030.

Michiel Lap took over Arjen Dorland’s position as

Vice-Chair of the Supervisory Board with effect from

11 September 2025.

On 29 January 2026, ABN AMRO announced that its

Supervisory Board would appoint Michiel Lap as Chair

of the Supervisory Board of ABN AMRO with effect from

the closure of the Annual General Meeting on 22 April

2026. Michiel Lap will succeed Tom de Swaan, who will

retire as Chair after almost eight years. Furthermore,

ABN AMRO announced the nomination of Jean-Pierre

Mustier to its Supervisory Board for a term of four years.

The nomination is subject to the approval of the

European Central Bank. At the upcoming Annual

General Meeting, the Supervisory Board of ABN AMRO

intends to nominate Sarah Russell for a second term of

four years, as her current term will expire in 2026.

Appointment, suspension and dismissal

Members of the Supervisory Board are appointed by the

General Meeting, following nomination by the

Supervisory Board itself. Only candidates who have

passed the fit and proper test under the relevant legal

requirements stemming either from applicable EU law

or applicable national law are eligible for appointment.

The General Meeting and the Employee Council may

recommend candidates to the Supervisory Board to be

nominated as members of the Supervisory Board. The

diversity objectives laid down in ABN AMRO’s internal

policies are taken into consideration when preparing

the appointment and reappointment of the members of

the Supervisory Board. The Supervisory Board notifies

the General Meeting of the intended appointment or

reappointment of a member of the Supervisory Board,

accompanied by a short résumé of the candidate

including the candidate’s age, gender, educational and

professional background, and geographical

provenance.

In accordance with the best practice provisions of the

Dutch Corporate Governance Code, Supervisory Board

members are appointed for a period ending at the close

of the first Annual General Meeting held after four years

have passed since their previous appointment, unless a

shorter period was set at the time of the appointment.

The Supervisory Board may suspend any of its members

at any time. The General Meeting may dismiss the

Supervisory Board in its entirety due to a lack of

confidence in the Supervisory Board. This requires an

absolute majority of the votes cast, representing a

quorum of at least one-third of the issued share capital.

If this quorum is not met, it is not possible to hold a

second General Meeting at which no quorum applies.

Further information on the suspension and dismissal

procedure is provided in ABN AMRO’s Articles of


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≡	Leadership & governance	Leadership and governance structure	Supervisory Board composition

Association and the Supervisory Board Rules of

Procedure as published on the ABN AMRO website.

Employee representation

ESRS

The Supervisory Board is required to nominate a

candidate recommended by the Employee Council in

respect of one-third of the members of the Supervisory

Board (the ‘enhanced recommendation right’). The

Supervisory Board must accept the recommendation of

the Employee Council unless it believes that the

recommended candidate is unsuitable to fulfil the

duties of a member of the Supervisory Board or that the

Supervisory Board would not be properly composed if

the appointment was made as recommended.

Committees

The Supervisory Board has established five committees

to prepare its decision-making and to advise the

Supervisory Board on specific matters. These

committees are composed exclusively of Supervisory

Board members. These committees are the:

• Audit Committee;

• Risk & Capital Committee;

• Remuneration Committee;

• Selection & Nomination Committee;

• Supervisory Sustainability Committee.

Supervisory Board

Audit

Committee

Risk & Capital

Committee

Remuneration

Committee

Selection &

Nomination

Committee

Supervisory

Sustainability

Committee

Composition and diversity

ESRS

The Supervisory Board’s composition is based on the

guiding principle that diversity of thought, expertise,

background, competences and interpersonal styles is a

prerequisite for effective supervision and, by extension,

for sustainable long-term value creation. To that effect,

the following diversity aspects are relevant for the

composition of the Supervisory Board: gender, age,

educational and professional background, and

geographical provenance.

Diversity of Supervisory Board

ESRS

(female/male, average in %)

The gender diversity target has been reviewed in light

of new legislation to bring about a more balanced ratio

between men and women in boards of directors and

supervisory boards. According to ABN AMRO’s current

gender diversity target, at least one-third (1/3) of

ABN AMRO’s Supervisory Board should consist of the

underrepresented gender. ABN AMRO’s Supervisory

Board currently consists of three male and four female

members. When vacancies arise, the Supervisory Board

gives due consideration to any applicable gender

requirements in its search for suitable new members

who meet the fit and proper requirements stipulated in

the relevant legal requirements stemming either from

applicable EU law or applicable national law.

Relevant experience

Collectively, the members have expertise in personal

and business banking, wealth management and

corporate banking, investment banking, risk

management, financial management, strategy

formulation and execution, cultural and other change

management, IT, digitalisation, cybersecurity,

innovation, AI, economics, remuneration and human

resources management, sustainability and corporate

social responsibility, legal and compliance matters and

the development of products and services, and

experience in the key markets in which the bank

operates. The Supervisory Board has one financial

expert, in accordance with the formal definition and

requirements, accompanied by highly experienced

bankers, who collectively have broad and deep banking

experience across all key areas of domestic and

international banking.

All members of the Supervisory Board have passed the

fit and proper test required under the relevant legal

requirements stemming either from applicable EU law

or applicable national law.


ABN AMRO	Annual Report 2025	151


≡	Leadership & governance	Leadership and governance structure	Supervisory Board composition

Independence

The Supervisory Board confirms that all members of the

Supervisory Board are independent within the meaning

of best practice provision 2.1.10 of the Dutch Corporate

Governance Code.

Competence matrix

The competence matrix demonstrates the relevant

experience of ABN AMRO’s Supervisory Board.



	Tom de Swaan Chair	Michiel Lap Vice Chair	Laetitia Griffith Member	Daniel Hartert Member	Sarah Russell Member	Mariken Tannemaat Member	Femke de Vries Member
Competences
Executive experience	ÍÍ	ÍÍ	ÍÍ	ÍÍ	ÍÍ	ÍÍ	ÍÍ
Banking and finance experience	ÍÍ	ÍÍ	Í	Í	ÍÍ	ÍÍ	Í
Audit experience	ÍÍ	ÍÍ	ÍÍ	Í	ÍÍ	Í	Í
Risk experience	ÍÍ	ÍÍ	ÍÍ	ÍÍ	ÍÍ	ÍÍ	ÍÍ
IT, digitalisation and AI experience	ÍÍ	ÍÍ	Í	ÍÍ	ÍÍ	ÍÍ	Í
Transformation and innovation experience	ÍÍ	ÍÍ	ÍÍ	ÍÍ	ÍÍ	ÍÍ	ÍÍ
Environmental experience	ÍÍ	ÍÍ	ÍÍ	ÍÍ	Í	ÍÍ	ÍÍ
Social experience	ÍÍ	ÍÍ	ÍÍ	ÍÍ	ÍÍ	ÍÍ	ÍÍ
Governance experience	ÍÍ	ÍÍ	ÍÍ	Í	ÍÍ	ÍÍ	ÍÍ
Compliance and conduct experience	ÍÍ	Í	ÍÍ	Í	ÍÍ	ÍÍ	ÍÍ


Í	Has good understanding of the subject but is not expert		ÍÍ	Can make a balanced independent judgement on the subject (expert)


ABN AMRO	Annual Report 2025	152


≡	Leadership & governance	Leadership and governance structure	Supervisory Board composition

Supervisory Board


	Supervisory Board (from left to right): Sarah Russell, Tom de Swaan, Daniel Hartert, Mariken Tannemaat, Michiel Lap, Laetitia Griffith, Femke de Vries

Personal details of the members of the Supervisory Board

The personal details of all members of the Supervisory Board who were active in 2025 can be found on our website.

The information below refers to the members of the Supervisory Board as at 10 March 2026.



	Tom de Swaan Dutch, male, 1946
	Tom de Swaan was appointed to the Supervisory Board of ABN AMRO effective 12 July 2018 and reappointed for a second term effective 20 April 2022. His current term expires at the close of the Annual General Meeting in 2026. Last executive position held Interim CEO of Zurich Insurance Group Ltd.	Relevant positions pursuant to CRD V Chair of the Supervisory Board of ABN AMRO Bank N.V. Other relevant ancillary positions Member of the International Advisory Board of Akbank, Chair of the Management Board of Stichting Fondsen Nederlands Kankerinstituut, member of the Supervisory Board of Foundation Holland Festival, the Netherlands, member of the Artis-Ambassadors group of Stichting tot Instandhouding van de Diergaarde van het Koninklijk Zoölogisch Genootschap Natura Artis Magistra, member of the Board of Stichting Liszt Concours, member of the Board of Directors of The International Centre for Missing & Exploited Children, Chair of the Board of the Liberal Jewish Community of Amsterdam, member of the Board of Stichting Gan Hasjalom, member of the Committee of Recommendation of Stichting Het Stenen Archief, member of Scope Group’s Ambassadors Group.

Chair of the Supervisory Board



	Michiel Lap Dutch, male, 1962
	Michiel Lap was appointed to the Supervisory Board of ABN AMRO effective 24 April 2019 and reappointed effective 19 April 2023. His current term expires at the close of the Annual General Meeting in 2027. Last executive position held Partner, Goldman Sachs.	Relevant positions pursuant to CRD V Vice-Chair of the Supervisory Board of ABN AMRO Bank N.V., Chair of the Supervisory Board of Arcadis N.V. Other relevant ancillary positions Member of the Supervisory Board of Stichting Het Nederlands Kanker Instituut – Antoni van Leeuwenhoek Ziekenhuis.

Vice-Chair of the Supervisory Board


ABN AMRO	Annual Report 2025	153


≡	Leadership & governance	Leadership and governance structure	Supervisory Board composition



	Laetitia Griffith Dutch, female, 1965
	Laetitia Griffith was appointed to the Supervisory Board of ABN AMRO effective 17 December 2019 and reappointed effective 24 April 2024. Her current term expires at the close of the Annual General Meeting in 2028. Last executive position held Member of Parliament on behalf of the VVD (portfolio: Home Affairs), House of Representatives of the Netherlands.	Relevant positions pursuant to CRD V Member of the Supervisory Board of ABN AMRO Bank N.V., member of the Supervisory Board of Coca-Cola Europacific Partners Nederland B.V. Other relevant ancillary positions Chair of the Supervisory Board of the Dutch Film Fund, Chair of the Board of Stichting Nederlandse Vioolconcoursen, Chair of the Supervisory Council of Stichting Metropole Orkest, member of the Supervisory Council of the Kadaster, member of the Board of Stichting Assurances KLM, member of the Board of Koninklijke Verzamelingen, onderdeel van de Dienst van het Koninklijk Huis (Royal Collections of the Netherlands, part of the Royal Household).

Member



	Daniel Hartert German, male, 1958
	Daniel Hartert was appointed to the Supervisory Board of ABN AMRO effective 11 September 2025. His current term expires at the close of the Annual General Meeting in 2030. Last executive position held CIO of Bayer AG & CEO of Bayer Business Services GmbH.	Relevant positions pursuant to CRD V Member of the Supervisory Board of ABN AMRO Bank N.V. Other relevant ancillary positions CxO adviser to the management board of Capgemini SE, CxO adviser at Netskope Inc.

Member



	Mariken Tannemaat Dutch, female, 1971
	Mariken Tannemaat was appointed to the Supervisory Board of ABN AMRO effective 15 December 2020 and reappointed effective 23 April 2025. Her current term expires at the close of the Annual General Meeting in 2029. Last executive position held Chief Innovation Officer at Robeco N.V.	Relevant positions pursuant to CRD V Member of the Supervisory Board of ABN AMRO Bank N.V., Vice-Chair of the Supervisory Board of CM.com N.V. and member of the Supervisory Board of CM Payments B.V., non-executive director of Prudential Assurance Company Limited and non- executive director of Prudential International Assurance PLC. Other relevant ancillary positions Adviser to the Executive Board of Erasmus Enterprise B.V.

Member


ABN AMRO	Annual Report 2025	154


≡	Leadership & governance	Leadership and governance structure	Supervisory Board composition



	Sarah Russell Australian, female, 1962
	Sarah Russell was appointed to the Supervisory Board of ABN AMRO effective 20 April 2022. Her current term expires at the close of the Annual General Meeting in 2026. The Supervisory Board intends to nominate Sarah Russell for reappointment as a member of the Supervisory Board for a period of four years with effect from the close of the Annual General Meeting in 2026. Last executive position held CEO of AEGON Asset Management Holding B.V. and member of the Managing Board of AEGON N.V.	Relevant positions pursuant to CRD V Member of the Supervisory Board of ABN AMRO Bank N.V., member and Chair of the Supervisory Board of ABN AMRO Clearing Bank N.V., member and Vice-Chair of the Supervisory Board of APG Groep N.V., member and Vice-Chair of the Supervisory Board of APG Asset Management N.V., member and Vice-Chair of the Supervisory Board of The Currency Exchange Fund N.V.

Member



	Femke de Vries Dutch, female, 1972
	Femke de Vries was appointed to the Supervisory Board of ABN AMRO effective 29 June 2023. Her current term expires at the close of the Annual General Meeting in 2027. Last executive position held Managing Partner at &samhoud consultancy.	Relevant positions pursuant to CRD V Member of the Supervisory Board of ABN AMRO Bank N.V., board member of private consultancy firm Ms De Vries, member of the Supervisory Board of BNG Bank N.V. Other relevant ancillary positions Chair of the Advisory Board of Authority for Nuclear Safety and Radiation Protection, member of the Advisory Board of Human Environment and Transport Inspectorate (ILT), regular author of expert contribution to the Dutch financial daily gazette (Financieele Dagblad), Chair of the Advisory Council of the Dutch Healthcare Authority (Nederlandse Zorgautoriteit), member of the Advisory Council of the Inspectorate of Education (Inspectie van het Onderwijs).

Member


ABN AMRO	Annual Report 2025	155


≡	Leadership & governance	Supervisory Board	Interview with our Supervisory Board Chair

Tom de Swaan

Supervisory Board Chair of ABN AMRO

“We are

definitely

on the

right path”

Interview with our

Supervisory Board Chair

In his final interview as Chair of the

Supervisory Board, Tom de Swaan

looks back on an eventful year for

ABN AMRO. He discusses the bank’s

performance amid geopolitical

turbulence and reflects on key

developments, including the arrival of

Marguerite Bérard as CEO, the new

strategy and the intended acquisition

of NIBC Bank. “In an uncertain world,

ABN AMRO is doing very well – and

we are clearly on track.”

2025 was a tumultuous year for global business.

How do you look back on it?

“If we look at the world around us, the year was marked

by continued uncertainty. We are seeing persistent

conflicts in the Middle East, Ukraine and elsewhere,

claiming casualties every day, and a new administration

in the United States that is predictable in its

unpredictability. What I’m most concerned about are

the cracks in the international system we created after

World War II to keep us safe. Institutions such as NATO

or the United Nations – we all realise that these

multilateral organisations are of vital importance to an

open economy like the Netherlands.”

How do you view the bank’s performance in 2025

and what do you see as highlights?

“First of all, the impact of the global turbulence on

ABN AMRO was relatively limited. We saw strong top-

line performance, helped by the benign

macroeconomic environment in Northwest Europe.

Costs are clearly coming under control and the bank’s

capital optimisation is progressing well. For the

Supervisory Board, the most important event was the

arrival of Marguerite Bérard as the new CEO in April,

which injected a completely new energy into the

organisation. We are also very pleased with the closing

of the acquisition of Hauck Aufhäuser Lampe (HAL) and

the intended purchase of NIBC. All in all, the bank had a

gratifying year that provides a great starting point for

the implementation of the new strategy.”

What was the Supervisory Board’s role in creating

the new strategy?

“After appointing the new CEO, which is an important

task for a Supervisory Board, we were closely involved

in shaping the strategy. Throughout the year, we had

fruitful discussions with the broader leadership team

about the new strategy, culminating in the Capital

Markets Day at the end of November. The outcome is

a strategy focused on profitable growth and value

creation, which we believe is absolutely the right one

for the bank. That said, it’s not rocket science. From

strengthening our position in wealth management and

Dutch retail banking to supporting family wealth and

businesses and driving key European transitions, it’s

essentially sharpening the strategy we already had.

One of the differences is that our Clearing business has

also become an important focus for ABN AMRO. I’m

very pleased about that, because I think it’s a very good

business. Clearing is an innovative financial product and

a profitable and relatively low-risk activity that gives the

bank a global dimension.”


ABN AMRO	Annual Report 2025	156


≡	Leadership & governance	Supervisory Board	Interview with our Supervisory Board Chair

You already mentioned the intended acquisition

of NIBC. Was it an easy transaction for the

Supervisory Board to approve?

“NIBC is an interesting deal from a financial point of

view, and the strategic rationale is crystal clear as it

further strengthens our leading position in the Dutch

mortgage market. The Supervisory Board’s analysis of

the transaction was relatively simple. NIBC is a Dutch

savings bank with a large mortgage portfolio and a

small corporate book, so their balance sheet is a very

straightforward one for us. The whole transaction was

completed within the space of three months, which

included the summer month of August.”

How would you describe the new CEO’s initial

impact on the bank?

“The reaction to Marguerite taking over as CEO has

been very positive, both internally and externally, and

her initial impact is impressive. The NIBC transaction

demonstrated our talent and our ability to execute a

transaction of this kind swiftly and to the satisfaction of

all parties involved. Another example is how the bank

has already started to deliver on its strategic priorities.

The planned reduction of approximately 20% of the

workforce by 2028 is well underway, which helps

contain costs, and the progress made on optimising

risk-weighted assets is promising. All these things add

to the renewed vigour that I discussed earlier. And to be

clear, I’m not referring to Marguerite alone. The entire

leadership team is generating this new energy and has

been able to feed it into the organisation.”

What should the Supervisory Board focus on in

2026?

“We need to establish a clear reporting system to keep

track of how the strategy implementation is

progressing. One of the vital things to watch is

employee engagement, which is always at risk when

you announce such a substantial workforce reduction.

We must ensure that we maintain a pleasant work

environment and preserve people’s willingness to put

their best foot forward. The leadership team needs to

keep explaining why it’s doing what it’s doing. Because

change is not easy, and we are only at the start of the

process.

The Supervisory Board will also continue to closely

monitor the bank’s relationship with regulators and its

efforts to contain risk-weighted assets. In 2025, the

bank started using significant risk transfers to shift some

credit risks to institutional investors and is increasingly

benefitting from investments in data management.

We are making meaningful progress, but we’re not

there yet.

Other areas of attention in 2026 are the ongoing

integration of HAL, the finalisation of the NIBC deal and

the promotion of BUUT and BUX, which should help us

attract new clients and boost fee income. All in all, we

have a lot on our plate, but it’s a positive picture.”

“Looking ahead, I couldn’t

be more confident about

the future.”

In closing, how do you look back on your eight-

year tenure as Supervisory Board Chair, and how

do you feel about the future of the bank?

“I’ve enjoyed it, though it has been quite a ride.

The bank has gone through tumultuous times, from

the leadership changes prior to my starting to the anti-

money laundering settlement and the pandemic, which

required all of us to adapt to a new way of working.

All credit to our people, who remained committed to

the bank amid continuous change and disruption.

Looking ahead, I couldn’t be more confident about the

future. We have an extremely capable leadership team,

dedicated staff, a strong brand that people love and an

increasingly outward-looking and entrepreneurial

culture, culminating in a satisfactory 2025. We’re

definitely on the right path. In that respect, it’s safe to

say that my tenure is ending on an upbeat note.”


ABN AMRO	Annual Report 2025	157


≡	Leadership & governance	Supervisory Board	Report of the Supervisory Board

Report of the Supervisory Board

Introduction

The Supervisory Board supervises the policy of the

Executive Board and the general course of events at

ABN AMRO and the businesses connected with it, and

assists the Executive Board by providing advice.

Regular Supervisory Board meetings take place

following the meetings of the Remuneration

Committee, Selection & Nomination Committee, Risk &

Capital Committee, Supervisory Sustainability

Committee and Audit Committee. The Chairs of the

committees report to the Supervisory Board on their

deliberations and findings after each of their meetings,

and the Supervisory Board takes the outcomes and

recommendations into account. Furthermore, the

committees provide advice on matters requiring the

approval of the Supervisory Board. The insights and

recommendations provided by the committees form an

integral part of the Supervisory Board’s oversight. By

incorporating the committees’ deliberations into its

broader discussions, the Supervisory Board ensures that

key topics are addressed with the necessary depth and

expertise.

The Company Secretary (or deputy Company Secretary)

attends all meetings and is the secretary to the

Supervisory Board and its committees. All meetings of

the Supervisory Board start with a conflict of interest

check to determine whether any of the Supervisory

Board members has a conflict of interest concerning an

agenda item. The quarterly meetings of the Supervisory

Board also start with a check-in for the Supervisory

Board members only. In the quarterly meetings, after

the check-in, the CEO provides an update to the

Supervisory Board through the lens of the CEO’s

priorities. Following the CEO’s update, the other

Executive Board members join the quarterly meetings of

the Supervisory Board.

Members of the Supervisory Board

During the Annual General Meeting on 23 April 2025,

Mariken Tannemaat was re-appointed for a period of

four years by the General Meeting. On 11 September

2025, Arjen Dorland stepped down as Vice-Chair and

member of the Supervisory Board, as Chair of the

Remuneration Committee and as member of the

Selection & Nomination Committee and Audit

Committee. Michiel Lap was appointed as Vice-Chair of

the Supervisory Board and member of the Selection &

Nomination Committee with effect from 11 September

2025. During the Extraordinary Meeting of Shareholders

on 11 September 2025, Daniel Hartert was appointed

as a member of the Supervisory Board. He was also

appointed as a member of the Remuneration

Committee, Risk & Capital Committee and Supervisory

Sustainability Committee with effect from the same

date.

Meanwhile, important steps were taken in connection

with the expiring term of the Chair of the Supervisory

Board. On 29 January 2026, the Supervisory Board

announced that it would appoint Michiel Lap as Chair of

the Supervisory Board with effect from the close of the

Annual General Meeting on 22 April 2026.

To ensure an adequate transition and the continuity of

the activities of the Supervisory Board members, the

Selection & Nomination Committee conducted a

recruitment and selection process for a new Supervisory

Board member with banking experience and prepared

a position profile for this position. Towards the end of

November, the Selection & Nomination Committee

concluded its assessment of the preferred candidate.

After receiving positive advice from the Selection &

Nomination Committee, the Supervisory Board

supported the proposal to nominate Jean-Pierre

Mustier as a member of the Supervisory Board for

a term of four years at the Annual General Meeting in

2026, subject to the approval of the ECB.

Details of the Supervisory Board’s composition in 2025

can be found in the Composition and diversity

subsection in the Supervisory Board section.

The personal details of the members of the Supervisory

Board are considered to be incorporated by reference in

this Report of the Supervisory Board.

Meetings held in 2025 and attendance

During 2025, the Supervisory Board held five regular

meetings (of which four were quarterly meetings)

according to the pre-set schedule and twelve additional

meetings. The regular meetings were held physically,

whereas most of the additional meetings were held by

electronic means. The quarterly meetings took six hours

on average. In March 2025, the Supervisory Board held

its regular meeting to discuss and approve the

Integrated Annual Report 2024.

The quarterly meetings were attended by the members

of the Executive Board. The Chief Commercial Officers

provided the Supervisory Board with quarterly business

updates and deep dives on their respective client units,

with a focus on the dilemmas and challenges facing

these units. Market developments, strategic change


ABN AMRO	Annual Report 2025	158


≡	Leadership & governance	Supervisory Board	Report of the Supervisory Board

initiatives, financials, performance and non-financial

risks were important items for the Supervisory Board

during the business updates. Depending on the topics

discussed in the additional meetings of the Supervisory

Board, the responsible Executive Board members also

attended these meetings. Other bank staff and the

internal and external auditor were also invited to give

presentations on specific topics.

The Supervisory Board held two offsite meetings during

the year: one in April and one in October. During the

April offsite meeting, the Supervisory Board focused on

succession management, Detecting Financial Crime and

geopolitical developments, among other things. During

the offsite meeting held in October, the Supervisory

Board discussed topics such as the updated strategy for

2025-2028 in preparation for Capital Markets Day, the

digital euro and stablecoins, GenAI, possibilities for

outsourcing and risk management.

The number of Supervisory Board meetings held in

2025, and the attendance rates of the members, are

shown in the following table.

Attendance rates at meetings of Supervisory Board and committees


Attendance	Tom de Swaan	Arjen Dorland	Michiel Lap	Laetitia Griffith	Daniel Hartert	Sarah Russell	Mariken Tannemaat	Femke de Vries
Supervisory Board	100%	91%	94%	94%	100%	100%	88%	94%
Supervisory Board	17/17	10/11	16/17	16/17	6/6	17/17	15/17	16/17
Audit Committee	75%		100%			100%	100%
Audit Committee	6/8		8/8			8/8	8/8
Remuneration Committee	100%	100%		100%	50%		86%	100%
Remuneration Committee	7/7	5/5		7/7	1/2		6/7	7/7
Risk & Capital Committee		100%	100%		100%	100%	100%	100%
Risk & Capital Committee		9/9	13/13		4/4	13/13	8/8	13/13
Selection and Nomination Committee	100%	100%	60%	100%		100%
Selection and Nomination Committee	13/13	9/9	3/5	13/13		13/13
Supervisory Sustainability Committee			100%	80%	100%		100%	100%
Supervisory Sustainability Committee			4/4	4/5	1/1		5/5	5/5

Focus areas and discussion items of the

Supervisory Board in 2025

At the beginning of 2025, the Supervisory Board

prepared for the appointment of Marguerite Bérard as

Chief Executive Officer and member of the Executive

Board during the Annual General Meeting on 23 April

2025. During the last quarter of 2025, the Supervisory

Board paid attention to the departure of Ton van

Nimwegen and the reallocation of the duties and

responsibilities of the Chief Operations Officer to the

domains of remaining Executive Board members.

Throughout the year, during both formal and informal

meetings, the Supervisory Board devoted significant

time and attention to the bank’s long‑term strategic

direction. In these discussions, the updated strategic

plan for 2026 to 2028, as presented on 25 November

2025, took centre stage. The Supervisory Board not only

reviewed the strategic priorities but also assessed their

implications for the bank’s financial ambitions, capital

position and overall strategic resilience. These

conversations formed a recurring and integral part of

the Supervisory Board’s broader oversight

responsibilities, ensuring that strategic decisions

remained well‑aligned with market developments,

regulatory expectations and the interests of all

stakeholders. In this context, the Supervisory Board

examined a wide range of cost‑saving and operational

simplification initiatives. These initiatives were evaluated

for their direct financial impact and for their potential to

streamline the organisation, strengthen operational

efficiency and support the bank’s long‑term

competitiveness.

Furthermore, the Supervisory Board discussed several

potential M&A opportunities as part of its ongoing

strategic oversight. This included an in‑depth

exploration of possible transactions, such as the

acquisition of NIBC Bank N.V., that could enhance the

bank’s strategic position, broaden its product offering or

accelerate its growth ambitions.

Each quarter, the Supervisory Board extensively

discussed the financial quarterly results, including the

views of the internal and external auditors. Based on the

CFO memo, the Supervisory Board discussed related

topics such as the capital and funding plan, the outlook

on the financial plan, the monthly performance


ABN AMRO	Annual Report 2025	159


≡	Leadership & governance	Supervisory Board	Report of the Supervisory Board

highlights, the investor perspective, analyst consensus

and the communication approach.

At least once a quarter, the Supervisory Board was

updated on ABN AMRO’s key financial and non-financial

risks and the design of the internal risk management

and control systems via the CRO memo. During these

updates, the Executive Board’s assessment of the

adequacy and effectiveness of the risk management

and control systems was monitored and discussed.

The Supervisory Board also discussed the bank’s

strategic risk appetite at several meetings. In addition,

quarterly updates were provided on the progress of the

large non-financial remediation projects through the

Integrated Portfolio Report. In particular, the Group-

wide Recovery Plan within DFC was closely monitored

by the Supervisory Board.

The Chief Innovation & Technology Officer updated

the Supervisory Board every quarter on the key

developments and priorities within Innovation &

Technology. This included updates on reducing

complexity and fragmentation within Innovation &

Technology, increasing cyber resilience, improving data

capabilities, GenAI acceleration and regulatory findings.

Governance and oversight of important subsidiaries

remained a matter for attention in 2025. The

Supervisory Board performed deep-dives on important

subsidiaries such as ABN AMRO Clearing Bank N.V.,

ABN AMRO Asset Based Finance N.V., ABN AMRO

Hypotheken Groep B.V. and International Card

Services B.V.

Other topics on the agenda included the independence

of the external auditor, the integrated speak-up report,

the Risk Management Statement, the relocation of ABN

AMRO’s headquarters, the Supervisory Review and

Evaluation Process (SREP), performance and succession

management, ancillary positions of Supervisory Board

members and members of the Executive Board, KPI-

setting and the annual self-assessment of the

Supervisory Board.

The annual assessment of the Executive Board, the

Supervisory Board and their committees for the 2024

financial year took place in the first half of 2025.

Specific actions and areas for improvement following

the assessment for the year 2024 included further

enhancing the meeting documents for reporting to the

Supervisory Board and Executive Board, strengthening

the tracking of follow-up actions arising from decision-

making, and optimising steering tools for the oversight

of major projects, which were addressed during 2025.

The annual assessments of the Supervisory Board and

Executive Board for the 2025 performance year will

take place under the guidance of an external expert and

will be concluded in the first quarter of 2026.

The Supervisory Board continued to engage actively

with its key stakeholders in 2025, in both virtual and

physical meetings. The two members appointed

pursuant to the enhanced recommendation right of the

Employee Council, Laetitia Griffith and Femke de Vries,

met regularly with the Employee Council throughout

the year so as to maintain an active dialogue and obtain

the Employee Council’s thoughts and input on various

matters, including diversity, work satisfaction, strategy

execution, hybrid working and reorganisations. The

Chair and other members of the Supervisory Board also

met with the Employee Council on several formal and

informal occasions during the year. The Supervisory

Board appreciates the constructive relationship it has

with the Employee Council and highly values the input,

engagement, suggestions and considerations provided

by the Employee Council in the interests of the bank.

Active engagement was also maintained throughout the

year with the Dutch central bank (DNB), the European

Central Bank, the AFM, STAK AAB and NLFI. The

Supervisory Board had the constant aim of ensuring the

bank is well positioned to create sustainable long-term

value for its shareholders and for society, while focusing

firmly on clients’ interests and balancing the interests of

all stakeholders.

A description of the duties, responsibilities and current

composition of the Supervisory Board, including its

committees and other positions held by members, is

provided in the Supervisory Board section of this

chapter. More information on remuneration is provided

in the Remuneration report section of this chapter.

These subjects are considered to be incorporated by

reference in this Report of the Supervisory Board.

Supervisory Board Committees

Audit Committee

Introduction

The Audit Committee is responsible for the direct

supervision of all matters relating to financial and

sustainability reporting and controlling. As part of this, it

is responsible for supervising and advising the complete

Supervisory Board in respect of, among other things, (i)

matters concerning accounting policies, (ii) internal

control, financial and sustainability reporting functions,

internal audit and external audit, (iii) risk assessment of

issues that can influence financial and sustainability

reporting, and (iv) relevant regulatory compliance.


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Members of the Audit Committee in 2025

On 1 January 2025, the Audit Committee consisted of

Sarah Russell (Chair), Michiel Lap, Tom de Swaan and

Mariken Tannemaat. There were no changes during

the year.

Meetings held in 2025 and attendance

The Audit Committee held eight plenary meetings in

2025, consisting of six regular meetings and two

additional meetings. All matters discussed in the

Audit Committee’s plenary meetings that were relevant

for the Supervisory Board were reported on at the

subsequent meeting of the full Supervisory Board.

All regular plenary meetings of the Audit Committee

were also attended by the CEO, the CFO and the CRO.

The Head of Group Audit, the external auditor, the Head

of Accounting & Reporting, the Head of Controlling and

either the Company Secretary or the deputy Company

Secretary were also present at these regular meetings.

In addition, when deemed relevant and useful,

individual staff members and responsible management

were invited to present their case, respond to questions

and participate in discussions during the meetings.

In 2025, the members of the Audit Committee regularly

held separate meetings with several Executive Board

members, the Head of Group Audit, the Head of

Accounting & Reporting and the Head of Controlling.

The Chair of the Audit Committee also met bilaterally

with the external auditor on several occasions, focusing

on subjects such as the progress of the external audit,

the independence of the external auditor, litigation

matters and other subjects relevant to the Committee’s

responsibilities. The Chair also met with the European

Central Bank and the Dutch central bank in her capacity

as Chair of the Audit Committee on two occasions

during the year. Furthermore, the Committee’s

members held meetings with managers of various

departments in order to remain well informed on topics

that are subject to the Committee’s supervision. At the

end of the first regular meeting of the year, the Audit

Committee held a closed session with the Head of

Group Audit, among other things to reflect on

collaboration with the Executive Board and external

auditor. Directly after the meeting on 5 March 2025, the

Audit Committee had an informal bilateral conversation

with the external auditor to seek confirmation that all

relevant matters emerging from the audit had been

brought to the Committee’s attention. In addition, EY

shared its insights on the progress of large change

programmes and IT topics. At the end of the November

meeting, a closed session between the Committee and

the CFO was organised to exchange thoughts on

various aspects of the CFO’s role and the handling of

challenges associated with the position.

Focus areas and discussion items in 2025

The Audit Committee’s discussions in the meetings

covered topics including the quarterly reports, the 2024

Integrated Annual Report of ABN AMRO and key audit

matters reported by internal audit and the external

auditor. With regard to internal and external audits, the

Audit Committee discussed all control observations of

the internal and external auditors, including those

related to progress on high-priority projects and closure

of medium- and high-risk audit findings, based on the

quarterly Group Audit reports and the EY management

letter. Please refer to the Management Control

Statement in the Risk, funding & capital chapter and the

Audit Opinion of EY (see the Other Information chapter)

for further details. Moreover, the audit rotation was

scheduled for discussion on several occasions so that

the onboarding of PricewaterhouseCoopers and the

handover arrangements with Ernst and Young could

be considered.

The Audit Committee extensively discussed the bank’s

financial performance, with a focus on management

overlays and the IFRS 9 in-model adjustments.

In addition, the Audit Committee considered the

challenges around the cost objective for 2025 and

subsequent years, as well as the NII developments.

In 2025, the Audit Committee also took note of financial

reports issued to supervisory authorities, such as the

COREP and FINREP reports, Group Audit’s role,

performance and reports, reports from the external

auditor and EY’s engagement letters, independence and

fees, and discussed the integrated speak-up report

(formally known as the whistleblowing report). The

Audit Committee was also informed of all relevant

letters received from the European Central Bank and

the Dutch central bank.

During 2025, the Audit Committee remained focused

on governance relating to financial reporting controls

within the bank (especially those involving the second

line) aimed at improving the independent oversight of

financial reporting risk. Moreover, the Audit Committee

continued to concentrate on data governance and the

data and reporting programmes. The updates provided

to the Audit Committee are further integrated in a single

data management and reporting update, in which the

second line provides a risk opinion as well.

In March 2025, the Audit Committee reviewed and

discussed the Integrated Annual Report 2024, including

the Impact Report, the external auditor’s report on the

2024 consolidated financial statements and the

Management Control Statement. EY reflected on the

extended sustainability disclosures in the Integrated

Annual Report 2024, specifically the consistency

between the EU taxonomy, the CSRD and the bank’s


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strategy, and their alignment. In May 2025, the Audit

Committee reviewed the control environment and

status of inspection and audit points in relation to

Corporate Banking.

During the August meeting, the Audit Committee

discussed the methodology and outcome of the

updated ESRS Double Materiality Assessment (ESRS

DMA). The purpose of the ESRS DMA was to determine

the updated scope of sustainability topics to be

reported on in the bank’s upcoming annual reports.

The Audit Committee and the Supervisory Sustainability

Committee advised the Supervisory Board to approve

the updated methodology and the outcome of the ESRS

DMA. In addition, the Audit Committee focused on the

simplification initiatives around sustainability reporting

including the Omnibus regulations.

During the August and November meetings, the Audit

Committee reviewed the framework and

implementation of the Risk Management Statement

(Verklaring Omtrent Risicobeheersing), including the

Management Control Statement, strategic risk

assessments and the required alignment with the

Executive Board and the Risk & Capital Committee. For

further information on the Risk Management Statement,

please refer to the Management Control Statement in

the Risk, funding & capital chapter and the Audit

Opinion of EY (see the Other Information chapter).

In October 2025, the Audit Committee and the Risk &

Capital Committee were jointly updated by the CEOs

and CROs of the bank’s main subsidiaries, including

ABN AMRO Hypotheken Groep B.V., International Card

Services B.V., Asset Based Finance B.V. and ABN AMRO

Clearing Bank N.V., on various matters, in particular their

risk and audit actions, projected risk profile and risk

culture. Throughout the year, the Audit Committee also

asked relevant departments to provide updates on

internal regulatory projects with overdue high-risk

audit issues.

Risk & Capital Committee

Introduction

The Risk & Capital Committee is responsible for

supervising and advising the Supervisory Board in

relation to topics such as (i) risk management and

control, (ii) compliance, (iii) capital allocation and

liquidity requirements, (iv) the bank's risk appetite, (v)

regulatory compliance, such as codes of conduct and

internal procedures, (vi) risk awareness within the bank,

(vii) the integration of sustainability, climate-related,

and environmental risks into the risk management

framework, and (viii) sound remuneration policies and

practices inlight of risk, capital, liquidity and expected

earnings.

Members of the Risk & Capital Committee in 2025

On 1 January 2025, the Risk & Capital Committee

consisted of Michiel Lap, Sarah Russell, Femke de Vries

and Arjen Dorland. Arjen Dorland stepped down as a

member of the Risk & Capital Committee with effect

from 11 September 2025. Simultaneously, Daniel

Hartert was appointed as a member of the Risk &

Capital Committee.

Meetings held in 2025 and attendance

All regular plenary meetings of the Risk & Capital

Committee were attended by the CEO, the CFO and the

CRO. The Head of Group Audit, the external auditor and

the Company Secretary or deputy Company Secretary

also attended the full plenary meetings. The interim

Head of Compliance was present as well, except at the

regular plenary meeting in August. In addition, when

deemed relevant and useful, individual staff members

and responsible management were invited to present

their case, participate in discussions and respond to

questions.

The Risk & Capital Committee held thirteen plenary

meetings in 2025, consisting of four regular meetings

and nine additional meetings. All matters discussed in

the Risk & Capital Committee’s plenary meetings that

were relevant for the Supervisory Board were reported

on orally at the subsequent meeting of the full

Supervisory Board.

Focus areas and discussion items in 2025

Recurring items on the Risk & Capital Committee’s

agenda in 2025 were the CRO memo, including change

risks, credit risks, operational risks, compliance risks,

IT and security risks, and sustainability and climate risks,

the updates from Compliance and Credit Risk, an

update on the Definition of Default programme, the

Capital & Funding Plan, reporting on Detecting Financial

Crime’s activities, a privacy risk update, legal updates,

updates on information security by the Head of

Information Security (CISO) and a status overview of

regulatory findings. In addition, the CRO provided

updates at the regular Risk & Capital Committee

meetings on relevant developments in her area of

control.

One-off reports presented to the Risk & Capital

Committee related to integrated portfolio reporting,

digital resilience, SREP, client issues and regulatory-

related topics of the subsidiaries ABN AMRO Clearing

Bank N.V. and ABN AMRO Hypotheken Groep B.V.

The regular and ad hoc reports were used by the Risk &

Capital Committee to maintain oversight and advise the

Supervisory Board on the functioning and efficiency of


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the bank’s operations versus its risk appetite, including

the functioning of its internal risk management function.

As noted, the Risk & Capital Committee assessed the

Capital & Funding Plan on a quarterly basis and was

informed about the bank’s current capital and funding

positions. The Risk & Capital Committee discussed the

bank’s management of its capital and liquidity ratios,

including the issuance plans for capital and funding and

options for RWA steering. In all instances, the Risk &

Capital Committee advised the Supervisory Board to

approve the proposed Capital & Funding Plan. The Risk

& Capital Committee held an extra meeting to discuss

the Capital Adequacy Statement and the Liquidity

Adequacy Statement.

The Risk & Capital Committee discussed the updated

Strategic Risk Appetite Statement extensively on several

occasions and zoomed in on the new risk management

strategy. Following the quarterly Compliance and Legal

Reports, the Risk & Capital Committee discussed

individual legal files, the impact of national and

international laws and regulations and the performance

of the Compliance function. The Risk & Capital

Committee was frequently updated on the activities of

the Detecting Financial Crime unit, specifically the

delivery of the group-wide recovery plan, and zoomed

in on the progress and deliverables of the ongoing

remediation programmes.

In August, the Risk & Capital Committee was updated

on the progress of the implementation of the Risk

Management Statement (Verklaring Omtrent

Risicobeheersing), including main deliverables,

milestones and limitations. For further information on

the Risk Management Statement, please refer to the

Management Control Statement in the Risk, funding &

capital chapter and the Audit Opinion of EY (see the

Other Information chapter).

Extra meetings were held during 2025 to perform a

deep dive on topics such as ILAAP, ICAAP, DFC and the

group-wide recovery plan, risk assessment and

remuneration incentives (in a joint meeting with the

Remuneration Committee). Together with the Audit

Committee, the Risk & Capital Committee held sessions

focused on risk-related matters of the subsidiaries Asset

Based Finance B.V., ABN AMRO Clearing Bank N.V., ABN

AMRO Hypotheken Groep B.V. and International Card

Services B.V.

More information on the risk, capital, liquidity and

funding-related topics discussed by the Risk & Capital

Committee is provided in the Risk, funding & capital

chapter.

Remuneration Committee

Introduction

The Remuneration Committee is responsible for

supervising and advising the Supervisory Board on

subjects such as: (i) remuneration policies and their

execution with regard to members of the Executive

Board, the Supervisory Board, members of the Extended

Leadership Team, heads of internal control functions,

Identified Staff and non-Identified Staff, and (ii)

reporting on the execution of the bank’s remuneration

policies in the form of a remuneration report.

Members of the Remuneration Committee in 2025

On 1 January 2025, the Remuneration Committee

consisted of Arjen Dorland (Chair), Tom de Swaan,

Laetitia Griffith, Mariken Tannemaat and Femke de

Vries. With effect from 11 September 2025, Arjen

Dorland stepped down as a member of the Supervisory

Board and as Chair of the Remuneration Committee.

With the Chair position vacant, the Remuneration

Committee decided on its own interim chairing

arrangements. Daniel Hartert was appointed as a

member of the Remuneration Committee on and with

effect from 11 September 2025.

Meetings held and attendance in 2025

In 2025, the Remuneration Committee held five regular

meetings and two additional meetings. The Company

Secretary (or deputy Company Secretary) attended the

meetings. Four decisions were made in writing outside

of meetings.

Focus areas and discussion items in 2025

In February, the Remuneration Committee reviewed the

Remuneration Report for 2024 and evaluated the

performance of the Executive Board members, dual

reporting lines and CLA+ employees by weighing up

financial and non-financial performance. The

Remuneration Committee advised on the related scores

and proposed variable remuneration and salary

increases where applicable. In addition, the

Remuneration Committee discussed the proposed KPI

frameworks for 2025 and the proposed award of

discretionary variable remuneration (DVR) to CLA staff

for 2024, including the malus and gatekeeper

assessment for all Identified Staff that was carried out

by the control functions.

The Remuneration Committee was informed of the

collective increases for 2025, based on the collective

labour agreement (CLA) for banks, for the fees of the

Supervisory Board and the remuneration of the

Executive Board and CLA+ employees in scope of the

bonus prohibition, and of the Executive Board’s decision

to adjust the salary scales for CLA+ employees with


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effect from 1 January 2025, based on the performed

benchmark. In the context of being able to attract and

retain staff with the right skills and talent, the

Remuneration Committee also received an update on

the bank’s employer branding and talent acquisition

set-up and discussed the impact of the bank’s hiring

freeze.

A joint meeting with the Risk & Capital Committee was

held in May on the annual risk assessment of

remuneration incentives. At this meeting the main risks

related to remuneration policies and practices linked to

the various areas of the strategic risk appetite. In the

second meeting in May, the Remuneration Committee

received an overview of the retention, sign-on and

severance payments awarded in 2024 and the

developments regarding remuneration legislation,

which affect the bank’s remuneration policies and

processes. From a broader people perspective, the

Remuneration Committee was informed of the

implications for the bank stemming from increasing

absenteeism in the Netherlands, and of the deep dive

conducted into the upskilling and reskilling of

critical skills.

In September, the Remuneration Committee closely

monitored the preparation and impact of the EU Pay

Transparency Directive and reviewed the implications of

forthcoming labour‑market legislation on the

classification of external staff. It also performed the

half‑year performance and talent review and was

briefed on the potential extension of the Social Plan.

Furthermore, the members of the Remuneration

Committee discussed the administrative fine imposed

by the Dutch central bank for violation of the bonus

prohibition.

In November, the Remuneration Committee reviewed

the outcomes of the HR reward audit and the employee

engagement survey. This survey included a follow-up

regarding absenteeism and the personal wellbeing of

employees. The Remuneration Committee discussed

the proposed DVR pool for CLA staff for 2025, the

Identified Staff Policy and the proposed KPI Framework

2026 for Identified Staff and Executive Board members.

Attention was also given to the follow‑up of the

administrative fine for violation of the bonus prohibition.

During the year, the Remuneration Committee issued a

favourable recommendation to the Supervisory Board

on several retention arrangements for the bank’s

subsidiaries, in accordance with applicable laws and the

Global Reward Policy. The Remuneration Committee

also issued positive advice regarding the departure

arrangements for the bank’s Chief Executive Officer and

the Chief Operating Officer, which were consistent with

the Remuneration Policy of the Executive Board.

Further information on remuneration is provided in the

Remuneration Report section. These subjects are

considered to be incorporated by reference in this

Report of the Supervisory Board.

Selection & Nomination Committee

Introduction

The Selection & Nomination Committee is responsible

for supervising and advising the Supervisory Board on,

among other things, (i) selection for and appointments

and reappointments to the Supervisory Board and the

Executive Board, (ii) the succession plans of the

Supervisory Board and the Executive Board, (iii) the

knowledge, skills, experience, performance, size,

composition and profile of these boards, and (iv) the

performance of the members of these boards.

Members of the Selection & Nomination

Committee in 2025

On 1 January 2025, the Selection & Nomination

Committee consisted of Tom de Swaan (Chair),

Arjen Dorland, Laetitia Griffith and Sarah Russell.

Michiel Lap was appointed as a member of the

Selection & Nomination Committee on 8 September

2025. With effect from 11 September 2025,

Arjen Dorland stepped down both as a member of

the Supervisory Board and as a member of the

Selection & Nomination Committee.

Meetings held in 2025 and attendance

In 2025, the Selection & Nomination Committee held

five regular meetings and eight additional meetings.

The Company Secretary (or deputy Company Secretary)

attended the meetings. One decision was made in

writing without a meeting being held.

Focus areas and discussion items in 2025

Throughout 2025, the Selection & Nomination

Committee devoted significant attention to

safeguarding the quality, continuity and effectiveness

of ABN AMRO’s corporate governance across the

Executive Board and Supervisory Board and its

committees. The Selection & Nomination Committee’s

work covered supervisory and executive succession

planning, key appointments, leadership development

and evaluation processes, with a particular focus on

ensuring that the Supervisory Board and Executive

Board maintain the skills and capabilities required to

support the bank’s strategy, culture and regulatory

obligations.


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One of the main topics was the succession of Robert

Swaak, Chief Executive Officer and member of the

Executive Board. On 1 August 2024 it was announced

that Robert Swaak would not complete his term of

office at the bank and that it had been agreed he would

step down in the first half of 2025. After a thorough

recruitment and selection procedure and consultation

with the relevant stakeholders, the Selection &

Nomination Committee advised the Supervisory Board

on the intended nomination of Marguerite Bérard as

Chief Executive Officer and member of the Executive

Board. During the bank’s Annual General Meeting of

23 April 2025, the Supervisory Board, advised by the

Selection & Nomination Committee, announced the

intended appointment of Marguerite Bérard as Chief

Executive Officer and member of the Executive Board

with effect from that time as Robert Swaak’s successor.

The Selection & Nomination Committee took note of the

vacancy due to the expiry of Mariken Tannemaat’s term

at the bank’s Annual General Meeting and proposed her

reappointment to the Supervisory Board based on

performance while confirming that gender diversity

targets would continue to be met. Mariken Tannemaat

was reappointed for a period of four years during the

Annual General Meeting.

The Selection & Nomination Committee made progress

on the recruitment process for a Supervisory Board

member with extensive digital and technological

expertise to succeed Arjen Dorland. The Selection &

Nomination Committee advised the Supervisory Board

to update its collective profile, strengthen requirements

regarding ICT expertise, risk identification and ESG

oversight, and refine the position profile for the vacancy.

Following a successful recruitment procedure, the

Selection & Nomination Committee advised the

Supervisory Board on the nomination of Daniel Hartert

as Arjen Dorland’s successor in the position of member

of the Supervisory Board with effect from the

Extraordinary General Meeting of 11 September 2025.

The Selection & Nomination Committee also

recommended the appointment of Michiel Lap as Vice

Chair of the Supervisory Board as Arjen Dorland’s

successor. In addition, the Selection & Nomination

Committee supported the proposed committee

composition changes.

Alongside this, the Selection & Nomination Committee

reviewed various ancillary positions of Supervisory

Board and Executive Board members and granted

approval where time commitment, independence and

regulatory considerations were satisfactorily addressed.

The Selection & Nomination Committee also examined

the Executive Board’s succession plan.

Furthermore, the Selection & Nomination Committee

reviewed the results of the 2024 annual self-evaluations

of both the Supervisory Board and Executive Board.

The Selection & Nomination Committee agreed on

several enhancements to increase the effectiveness

and responsiveness of the governance framework.

For example, the Selection & Nomination Committee

identified actions to enhance the meeting documents

for reporting to the Supervisory Board and Executive

Board, strengthen the tracking of follow-up actions

arising from decision-making, and optimising steering

tools for oversight of major projects.

In 2025, the Selection & Nomination Committee gave

attention to matters that included the allocation of the

responsibilities of the departing Executive Board

member, Chief Operations Officer Ton van Nimwegen,

whose tasks and responsibilities were redistributed

among remaining Executive Board members with effect

from 1 January 2026, as well as the related suitability

assessments and coordination with internal

stakeholders, such as the works council, and external

stakeholders, such as the regulator.

Meanwhile, important steps were taken in anticipation

of the expiring term of the Chair of the Supervisory

Board. The Selection & Nomination Committee

positively advised the Supervisory Board to have

Supervisory Board member Michiel Lap assume the role

of Chair of the Supervisory Board of ABN AMRO.

Preparations for the expiring term of the Chair of the

Supervisory Board included consultations with the

Ministry of Finance and NLFI, and prioritised maintaining

a well-structured sequence of candidate discussions

while ensuring compliance with regulatory

requirements.

To ensure an adequate transition and the continuity of

the activities of the Supervisory Board members, the

Selection & Nomination Committee conducted the

recruitment and selection process for a new Supervisory

Board member with banking experience and prepared

the position profile for this position. Towards the end of

November, the Selection & Nomination Committee

concluded its assessment of the preferred candidate.

After receiving positive advice from the Selection &

Nomination Committee, the Supervisory Board

supported the proposal to nominate Jean-Pierre

Mustier as a member of the Supervisory Board for a

period of four years with effect from the close of the

Annual General Meeting on 22 April 2026 and to

prepare for regulatory approval.

The Selection & Nomination Committee also reviewed

insights from the Talent Visibility programme, focusing

on the robustness of internal Executive Board


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succession pipelines and identifying development

needs in key areas, including risk management. The

Selection & Nomination Committee evaluated the

redesigned Management Development Programme,

recognising its contribution to leadership effectiveness

and succession readiness across the organisation.

Positive advice was given on the proposed appointment

of the new Head of Compliance & SIM. Moreover, the

Selection & Nomination Committee concluded that no

additional suitability reassessments were required

following the quarterly antecedent reviews.

The Selection & Nomination Committee positively

advised the Supervisory Board on the reappointments of

the three Executive Board members with the title Chief

Commercial Officer with effect from the Annual General

Meeting in 2026. The role expansions of Executive

Board members as from 1 January 2026, following the

allocation of responsibilities of the departing Executive

Board member, Chief Operations Officer Ton van

Nimwegen, were also discussed and positive advice was

issued on ensuring alignment with competency

expectations and workload balance.

The Selection & Nomination Committee also positively

advised the Supervisory Board on the reappointment of

Sarah Russell as member of the Supervisory Board for a

period of four years with effect from the close of the

Annual General Meeting in 2026.

Finally, the Selection & Nomination Committee

considered the appointment of an external expert to

facilitate the annual board assessment for 2025 and

adopted the methodology and planning for that

assessment.

Supervisory Sustainability Committee

Introduction

The Supervisory Sustainability Committee advises the

Supervisory Board on matters within the area of

sustainability. In doing so, it is responsible for assisting

the Supervisory Board with, and making

recommendations on, for example, (i) sustainability

aspects of the strategy and policies, (ii) the double

materiality assessment, (iii) climate strategy and the

related climate action plan, (iv) oversight, support and

challenging of actions taken by the Executive Board in

relation to long-term value creation, (v) corporate

culture and values, (vi) sustainability KPIs, (vii) due

diligence obligations for the bank’s own obligations and

in relation to value chains, (viii) strategy on relations

with stakeholders on environmental, social and

governance matters, (ix) sustainability-related

developments, and (x) positioning with respect to

national and international best practices in the field of

environmental, social and governance matters.

Members of the Supervisory Sustainability

Committee in 2025

On 1 January 2025, the Supervisory Sustainability

Committee consisted of Femke de Vries (Chair), Laetitia

Griffith, Mariken Tannemaat and Michiel Lap. Michiel

Lap stepped down as a member of the Supervisory

Sustainability Committee with effect from

11 September 2025. Simultaneously, Daniel Hartert

was appointed as a member of the Supervisory

Sustainability Committee.

Meetings held in 2025 and attendance

The Supervisory Sustainability Committee held five

plenary meetings in 2025, consisting of four regular

meetings and one additional meeting. Tom de Swaan, in

his capacity as Chair of the Supervisory Board, attended

all five meetings of the Supervisory Sustainability

Committee in 2025 to keep abreast of the most

important developments relating to the Committee’s

tasks. The CEO, the CFO, the CRO, the Head of

Compliance, and the Company Secretary were also

present at the meetings. Depending on the topics

discussed in the meetings of the Supervisory

Sustainability Committee, the responsible Executive

Board members, individual staff members and

management involved also attended these meetings.

Focus areas and discussion items in 2025

Recurring items on the Supervisory Sustainability

Committee agenda in 2025 included, among other

things, ABN AMRO’s climate strategy, commercial

sustainability opportunities and initiatives within the

client units and the implementation of sustainability in

processes in the client units, ESG commitments, the

ESG Report, sustainability risk, ESG risk management

governance and legal developments regarding EU

ESG regulation.

Climate strategy items and targets were discussed in

the Supervisory Sustainability Committee meeting held

in February 2025, following which climate strategy

became an integral part of the ESG Report and a

recurring topic on the agenda. The ESG Report provides

central oversight of sustainability topics and supports

the monitoring of progress and implementation.

Corporate Banking, Personal & Business Banking and

Wealth Management provided updates on their

respective client units’ achievements in the area of

sustainability and presented targets and results. The

bank’s climate strategy and updates to the climate

action plan (especially commercial sustainability

initiatives to be embedded in the client units and

sustainability KPIs) will remain a recurring item on the


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agenda in connection with the implementation of the

bank-wide strategy presented in November 2025.

Sustainability risk aspects of the ERM Report were

discussed, with particular attention being paid by the

Supervisory Sustainability Committee to sustainability

targets, ESG data collection, the bank’s defence industry

standard and EBA guidelines on ESG Risk Management.

Other topics discussed in the dialogues with the CRO

included the bank’s new sustainability risk appetite and

sustainability governance framework. The Supervisory

Sustainability Committee was informed about changes

to ESG risk management governance, including

enhancements of the sustainability target operating

model (TOM) and the bank’s sustainability governance

framework, so that it could take a more integrated

approach to the bank’s sustainability strategy and

sustainability matters. At the request of the Supervisory

Sustainability Committee, alignment of the revised

sustainability governance framework with EBA

guidelines was discussed. The Supervisory Sustainability

Committee discussed, and advised positively, on the

CSRD Double Materiality Assessment Outcome 2025.

Other recurring items included progress on the

Sustainable Finance Regulations (SFR) programme and

legal developments regarding the EU ESG legislation

and EU Omnibus Package, which were monitored and

discussed on an ongoing basis.

Performance evaluation

The annual suitability self-assessment of the Executive

Board, the Supervisory Board and their committees

regarding the 2024 financial year was conducted in the

first half of 2025. The performance of the Executive

Board and its members and committees was assessed,

based on results gathered from questionnaires

completed by the members of the Executive Board and

discussions in Executive Board meetings, which were

evaluated by the Supervisory Board. The assessment of

the Supervisory Board and its individual members and

committees was also based on results gathered from

questionnaires completed by the members of the

Supervisory Board and on discussions in Supervisory

Board meetings. These assessments and evaluations

were then used to identify areas for improvement.

Action items from previous years included enhancing

the education programme with in-depth knowledge

sessions, increasing the focus on strategically important

matters and strengthening expertise related to new and

upcoming regulations and technological developments,

all of which were addressed during 2024 and 2025.

Action items from the assessment finalised in the first

half of 2025 included:

• Improving the quality of Executive Board documents

• Streamlining risk reporting

• Updating agenda setting

• Strengthening expertise related to IT in the

Supervisory Board

These action items were followed up during 2025. The

suitability self-assessments of the Supervisory Board

and Executive Board for the 2025 performance year

were started in the fourth quarter of 2025 and will be

concluded in the first half of 2026 under the supervision

of an independent external expert.

Induction programme and lifelong learning

programme

Induction programme

Following their appointment, the new member of the

Supervisory Board and the new member of the

Executive Board both completed an extensive induction

programme in 2025 to ensure they (i) are well-prepared

for the fit and proper interviews by the competent

authority and (ii) have sufficient knowledge of the

organisation to carry out their duties. In view of the

differences in knowledge, background and experience

of newly appointed members of these boards, each

induction programme has a tailor-made curriculum.

Lifelong learning programme

A lifelong learning programme is in place for members

of the Supervisory Board and the Executive Board. This

is designed to keep their expertise up-to-date and to

broaden and deepen their knowledge where necessary.

The objective is that members of the Supervisory Board

and Executive Board participate in the same training

sessions to foster knowledge-sharing. The curriculum is

developed and updated continually to ensure the

programme is of high quality, covers developments

related to regulatory requirements and takes account of

current developments in the global financial industry.

Topics covered in 2025 at sessions attended by the

Supervisory Board and the Executive Board included:

• Sustainability: integrated transition plan

• Moral dilemmas and the impact of biases

• Digitalisation: GenAI

• Business models: geopolitical and technological

trends that can impact ABN AMRO’s businesses

• Shadow banking


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≡	Leadership & governance	Supervisory Board	Report of the Supervisory Board

Members of the Supervisory Board and members of the

Executive Board have a standing invitation to participate

in the permanent education programme, as do

members of the senior management. The following

topics were covered by this programme in 2025:

1. Sustainability: climate strategy

2. Cybersecurity, fraud and DORA implementation

3. Performance management – objective setting

4. Developments in Basel IV and BCBS-239

5. Managing change and strategic portfolio

management

6. Macro-economic trends and outside-in investor

perspective

7. Innovation in products (crypto, digital euro)

8. Risk appetite setting and risk appetite framework

9. From insight to impact on the workplace by using the

behavioural risk dashboard as a leader

10. Strategic leadership in the age of data & AI:

11. unlocking business value together

All sessions of both programmes were offered online.

In addition, the members of the Supervisory Board

participated in the following learning deep dives on

location in 2025:

• Geopolitics / global affairs

• Where next for European banks: tariffs, financing

growth and private credit

• Digital currency

• Verklaring Omtrent Risicobeheersing (statement on

risk management)

The members of the Executive Board participated in the

following learning deep dives in 2025:

• Ambition-level sustainability

• Future generations board session

• Risk management: modelling strategy for long-term

viability

• Double materiality assessment (DMA) and Corporate

Sustainability Reporting Directive (CSRD)

• Deep dive on pricing and risk-adjusted return

• ACE - modular, channel-agnostic “One Bank” digital

interaction and IT platform

• Verklaring Omtrent Risicobeheersing (statement on

risk management)

• BCBS 239

• Digital currency

All members of the Supervisory Board and of the

Executive Board take part in the lifelong learning

programme and the deep dives, and meet the training

requirements. The effectiveness of the lifelong learning

programme is one of the matters included in the

management body’s annual suitability self-assessment.


ABN AMRO	Annual Report 2025	168


≡	Leadership & governance	General meeting and shareholder structure

General Meeting and

shareholder structure

General meeting

The Annual General Meeting is held each year by

30 June at the latest. The agenda for the Annual

General Meeting contains subjects specified in

ABN AMRO’s Articles of Association and under Dutch

law. Extraordinary General Meetings are convened if

deemed necessary, for instance to resolve important

decisions, such as major acquisitions and divestments or

appointments of Executive Board or Supervisory Board

members that cannot be deferred until the next Annual

General Meeting.

Shareholders or holders of depositary receipts who

alone or jointly represent at least 3% of the issued share

capital of ABN AMRO are allowed to add items to the

agenda of the General Meeting, provided they submit a

request for this (including reasons) to ABN AMRO at

least 60 days prior to the General Meeting. The

Supervisory Board and the Executive Board are both

entitled to convene a General Meeting. Shareholders or

holders of depositary receipts issued with the

cooperation of ABN AMRO may also convene a General

Meeting, provided they represent at least 10% of the

issued share capital. NLFI may also request the

Executive Board or Supervisory Board to convene a

General Meeting, as stated in the Relationship

Agreement.

General Meetings in 2025

ABN AMRO held two General Meetings in 2025: the

Annual General Meeting on 23 April and one

Extraordinary General Meeting on 11 September. The

Annual General Meeting was held in a hybrid manner:

shareholders and depositary receipt holders were able

to participate in person at ABN AMRO’s head office in

Amsterdam or virtually through their own device. The

Extraordinary General Meeting was held in person.

Annual General Meeting

The agenda of the Annual General Meeting on

23 April 2025 included:

• the adoption of the 2024 annual financial statements;

• the remuneration report;

• the reservation and dividend policy;

• the dividend proposal;

• the discharge of each member of the Executive Board

and Supervisory Board;

• the report on the functioning and appointment of the

external auditor;

• the appointment of Ernst and Young Accountants LLP

as the auditor to assure ABN AMRO’s sustainability

reporting for the financial year 2025;

• the appointment of PricewaterhouseCoopers N.V. as

the auditor to assure ABN AMRO’s sustainability

reporting for the financial years 2026, 2027 and 2028

(the appointment of PricewaterhouseCoopers N.V. to

audit the financial statements for the years 2026,

2027 and 2028 took place at the previous year’s

Annual General Meeting);

• the collective profile of the Supervisory Board;

• the reappointment of Mariken Tannemaat as a

member of the Supervisory Board;

• the intended appointment of Marguerite Bérard as

CEO and member of the Executive Board;

• the authorisation for the Executive Board to:

– issue shares and/or grant rights to subscribe for

shares, limit or exclude pre-emptive rights, and

acquire shares or depositary receipts for shares in

ABN AMRO’s own capital, for a period of 18 months

as from the date of the General Meeting, subject to

the approval of the Supervisory Board and provided

the total number of shares or depositary receipts

held by ABN AMRO is limited to 10% of the issued

share capital of ABN AMRO, and

– the cancellation of shares or depositary receipts for

shares in the issued share capital of ABN AMRO

held by ABN AMRO, and the related reduction of

the authorised capital (excluding ordinary shares B).

Extraordinary General Meeting

The agenda of the Extraordinary General Meeting on

11 September 2025 included the appointment of

Daniel Hartert as member of the Supervisory Board.

Shareholder structure

As at 31 December 2025, all shares in the capital of

ABN AMRO were held by two foundations: STAK AAB

(Stichting Administratiekantoor Continuïteit ABN AMRO

Bank) and NLFI (stichting administratiekantoor beheer

financiële instellingen).

On 20 May 2025, NLFI announced that it had reduced

its stake in ABN AMRO to below one-third. This sell-

down was part of NLFI’s trading plan to reduce its stake


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≡	Leadership & governance	General meeting and shareholder structure

in ABN AMRO from 40.5% to approximately 30.5%,

which level NLFI eventually reached on 25 July 2025.

On 9 September 2025, NLFI announced its intention to

initiate its fourth trading plan, with the aim of further

reducing its stake in ABN AMRO from 30.5% to

approximately 20%. The announcement of this trading

plan can be found on the website of NLFI. The execution

of the trading plan was ongoing as at

31 December 2025; as at that date, NLFI held a stake of

approximately 27.5%. The shareholdings of NLFI and

STAK AAB will be updated on our website once the

trading plan has been completed.

STAK AAB

History and objectives

STAK AAB is a trust office independent of ABN AMRO

that was set up by ABN AMRO with the approval of the

Dutch Minister of Finance and NLFI at the time of the

initial public offering of ABN AMRO in 2015. NLFI is

planning to gradually reduce its stake in ABN AMRO

over the coming years, with its ultimate aim being to

dispose of all of its ABN AMRO shares. In the event of a

sale, the shares to be sold will be transferred to STAK

AAB by NLFI. STAK AAB holds these shares for the

purpose of administration (ten titel van beheer), and in

exchange issues depositary receipts that are traded on

the Euronext Amsterdam stock exchange. Only STAK

AAB’s depositary receipts have been issued with the

cooperation of ABN AMRO.

The issuing of depositary receipts is primarily used as a

protective measure (see Anti-takeover measures

below). In addition, STAK AAB aims to promote the

exchange of information between ABN AMRO and the

holders of depositary receipts.

Meetings of depositary receipt holders

By virtue of its trust conditions, STAK AAB must ensure

that, no later than two weeks before a General Meeting

of ABN AMRO is held, a meeting of depositary receipt

holders is held at which the agenda items of that

General Meeting are discussed. In 2025, STAK AAB held

meetings of depositary receipt holders before the

Annual General Meeting of ABN AMRO on 8 April 2025

and before the Extraordinary General Meeting on

27 August 2025.

Bilateral meetings with ABN AMRO

ABN AMRO and STAK AAB held two periodic meetings

in 2025. The items discussed included, among other

things, the current state of affairs regarding ABN AMRO

and STAK AAB, the quarterly results, the investor

presentation and shareholder register of ABN AMRO,

the decreasing stake of NLFI in ABN AMRO and the

issuance of new depositary receipts.

Further information on STAK AAB

STAK AAB reports on its activities at least once a year in

its own annual report. The STAK AAB website provides

more information on the activities of STAK AAB, its

objectives, as well as its annual report, articles of

association, trust conditions and any information

relating to meetings of depositary receipt holders.

NLFI

The Dutch State holds an interest in ABN AMRO through

NLFI. NLFI was set up to avoid potential conflicting

responsibilities that the Dutch Minister of Finance might

otherwise face and to avoid undesired political

influence being exerted.

Objective of NLFI / Approval right of Dutch

Minister of Finance

NLFI is responsible for managing the shares and

depositary receipts in ABN AMRO and for exercising all

rights associated with these shares under Dutch law,

including voting rights. NLFI acts as a stand-alone

shareholder that is independent of the Dutch State,

including the Dutch Ministry of Finance. However,

important decisions taken by NLFI require prior

approval by the Dutch Minister of Finance, who can also

give binding voting instructions to NLFI with respect to

such decisions. NLFI is not permitted to dispose of or

encumber the ordinary shares in the capital of ABN

AMRO without the prior authorisation of the Dutch

Minister of Finance.

Relationship Agreement

NLFI and ABN AMRO entered into a Relationship

Agreement governing their relationship after the initial

public offering of ABN AMRO in 2015. The full text of

the Relationship Agreement is available on our website.

The Relationship Agreement will terminate if and when

NLFI (directly or indirectly) holds less than 10% of ABN

AMRO’s issued share capital. A limited number of

clauses will not terminate under any circumstances.

On 20 May 2025, NLFI announced that it had reduced

its stake in ABN AMRO to below one-third. As a result, a

number of rights of NLFI in the Relationship Agreement

no longer apply. Among other things, NLFI no longer

has prior approval rights for (i) any issuance of (or

granting of rights to acquire) shares, or (ii) for

investments or divestments by ABN AMRO or any of its

subsidiaries with a value exceeding 10% of

ABN AMRO's equity. The Relationship Agreement

otherwise remained in full force and effect. NLFI still

has a consultation right for the appointment or

reappointment of members of the Executive Board and

the Chair of the Supervisory Board, and for the

appointment of the external auditor. Furthermore, NLFI


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≡	Leadership & governance	General meeting and shareholder structure

has certain information rights as long as it holds at least

15% of the shares in ABN AMRO.

Anti-takeover measures

The Netherlands has traditionally embraced the use of

defence measures to ensure long-term value creation

for stakeholders. In large part, these measures involve

the use of a Dutch foundation (stichting) that is granted

special rights intended to prevent an unsolicited

takeover or other hostile activity. This also applies to

ABN AMRO. ABN AMRO has implemented a structure

whereby the Dutch foundation (stichting) STAK AAB is

the holder of shares in ABN AMRO’s issued share capital

and has issued depositary receipts representing such

shares with the cooperation of ABN AMRO. The purpose

of having a structure under which depositary receipts

are created and STAK AAB is the legal owner of the

underlying shares is to create a defence measure and

ensure long-term value creation for stakeholders.

STAK AAB will do everything in its power to deter any

action that could affect the independence, continuity or

identity of ABN AMRO. In a non-hostile situation, STAK

AAB will act primarily in the interests of depositary

receipt holders. In a hostile situation, STAK AAB will act

primarily in the interests of ABN AMRO and its business

enterprises. Under all circumstances, STAK AAB will also

take into account the legitimate interests of all other

stakeholders: clients, debt investors, shareholders,

depositary receipt holders, employees, and the society

in which ABN AMRO operates.

In a non-hostile situation, STAK AAB will grant a power

of attorney to the depositary receipt holders to exercise

the voting rights attached to the underlying shares.

STAK AAB will not exercise voting rights on the shares,

unless holders of depositary receipts have requested it

to do so. This may be different under hostile

circumstances as described in Article 118a, Book 2, of

the Dutch Civil Code. In this case, STAK AAB may limit,

refuse or revoke powers of attorney for up to two years

and STAK AAB itself will exercise the voting rights. In

doing so, it should, pursuant to the trust conditions and

the articles of association of STAK AAB, focus primarily

on ABN AMRO’s interests, taking into account the

legitimate interests of the stakeholders mentioned

above.

Employee Council

The majority of ABN AMRO’s employees are

represented by works councils. In European countries,

such as Belgium, France, Germany and the Netherlands,

one or more works councils are in place.

In the Netherlands, specifically appointed delegates

from the different works councils are centralised in the

overarching Employee Council (Raad van

Medewerkers). The Employee Council in the

Netherlands deals primarily with topics that affect all

parts of the organisation in the Netherlands and meets

regularly with members of the Executive Board,

including an annual joint meeting of the Executive

Board, the Supervisory Board and the Employee

Council.

In the Netherlands, the overarching Employee Council

and ABN AMRO have an agreement under which the

Employee Council has been granted certain additional

rights (the Works Council Covenant). Under the Works

Council Covenant, the Employee Council has the right

of inquiry (enquêterecht) within the meaning of Article

346, Book 2, of the Dutch Civil Code in the event of a

hostile situation. The Works Council Covenant defines

the following situations as hostile: (i) a public offer has

been announced or is made in respect of shares in the

capital of ABN AMRO (or in respect of depositary

receipts representing such shares) or there is a justified

expectation that this will take place, without agreement

first having been reached between the bidder and

ABN AMRO, (ii) the exercise of the voting rights by

a depositary receipt holder or shareholder would

effectively be in conflict with the interests of ABN AMRO

and its business, or (iii) any other situation in which the

independence, continuity or identity of ABN AMRO and

the enterprises associated with ABN AMRO could be

harmed. The Employee Council and ABN AMRO can

also agree that other situations qualify as hostile.

Furthermore, if NLFI requests the consent or

cooperation of or a position statement from ABN AMRO

in the event of a subsequent placement or a private sale

of shares or depositary receipts, ABN AMRO will also

request advice from the Employee Council within the

meaning of Articles 25 and 26 of the Works Councils

Act (Wet op de ondernemingsraden).

In addition to the works councils in individual European

countries, there is a European works council, known as

the European Staff Council (ESC). The ESC represents

staff from Corporate Banking and Wealth Management

in Belgium, France, Germany, Greece, Luxembourg, the

Netherlands, Norway, Romania and the United

Kingdom. The ESC is a forum for information,

consultation and dialogue on questions of an economic,

financial or social nature, that due to their strategic

importance or European character may be of interest to

all establishments of ABN AMRO and its subsidiaries.


ABN AMRO	Annual Report 2025	171


≡	Leadership & governance	Remuneration report

Remuneration report

Remuneration principles and policies applicable to the whole workforce

Our purpose

Through our purpose – Banking for better, for

generations to come – we aim to create value for

society as a provider of financial services to our clients

and as an employer. We therefore aim to create

conditions in which all our employees can use their

talents and develop or acquire the right skills to

contribute to our goals.

In striving to achieve a future-proof workforce, we focus

on an excellent employee experience and inspiring

leadership, along with efficient organisational

structures, processes and IT systems that help our

employees work more effectively. Please refer to the

Performance on our strategy section for further context.

This report describes the remuneration principles,

policies and remuneration elements for ABN AMRO as

a whole, both within and outside the Netherlands.

Policies and principles based on legislation

Our policies and principles are based on applicable

European and local remuneration legislation and

regulations, including Articles 92-94 of CRD V as

transposed into Dutch legislation, the Regulatory

Technical Standards (RTS) on Identified Staff as

included in a Commission Delegated Regulation, the

Dutch Financial Undertakings Remuneration Policy Act

(Wbfo), the Regulation on Sound Remuneration Policies

(Regeling beheerst beloningsbeleid), and the EBA

Guidelines on Sound Remuneration Policies.

Remuneration principles



Reward philosophy

	Our reward framework enables ABN AMRO to attract, motivate, develop and retain the right talent in a sustainable manner so that we can achieve our business strategy.	Fair & transparent • Clear remuneration policies and processes • Principle of equal pay for equal work or work of equal value • Balanced total remuneration package in line with the relevant market Align employee’s and ABN AMRO’s interests • Clarity in how individual performance and remuneration are connected • Balanced risk-taking in line with our moderate risk appetite • Encouragement of personal development and values-led behaviour as integral part of performance
	Compliant & responsible • Compliant with the boundaries of all applicable remuneration legislation and guidelines • Respectful of our societal role and impact, our client’s interests and other stakeholders

A future-proof workforce requires a remuneration

framework that enables ABN AMRO to meet its

responsibilities towards clients, society, employees,

investors and other stakeholders, both now and in the

years ahead.

To support this, our remuneration policy and principles

are set out in the Global Reward Policy, which provides

a framework for effectively managing reward and

performance in relation to and in support of the

purpose, business strategy, risk strategy, objectives,

core values and long-term interests of the bank. The

Global Reward Policy applies to all employees within

ABN AMRO and at all group companies, subsidiaries,

branches, representative offices and legal entities inside

and outside the Netherlands.

The Executive Board and Supervisory Board approve

the Global Reward Policy and are responsible for its

maintenance and implementation. The policy is

reviewed annually, and this review takes into

consideration the bank’s strategy and desired culture

as well as factors such as risk awareness, targets,

corporate values and any updates due to laws and

regulations.

Composition of remuneration packages

ABN AMRO aims to award a remuneration package that

is aligned with the relevant local market and complies

with the applicable remuneration restrictions. Outside

the Netherlands, the package consists of an annual base

salary (with ranges that differ for each country), annual

variable remuneration and fringe benefits. Within the

Netherlands, the remuneration packages, as stipulated

in ABN AMRO’s CLA for CLA employees and the


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≡	Leadership & governance	Remuneration report

Compensation & Benefits Regulations for CLA+

employees, generally consist of an annual base salary,

fringe benefits and pension contribution. In addition, a

recognition premium governed by ABN AMRO’s CLA

applies specifically to CLA employees. Variable

remuneration is awarded for specific roles or in specific

situations. Remuneration levels are generally positioned

around the median of the relevant labour market, based

on benchmarking, while keeping labour costs balanced.

Employment conditions

ABN AMRO’s employment conditions form an essential

part of the total remuneration package and contribute

to social sustainability, supporting the wellbeing and

vitality of employees both inside and outside the

workplace. Examples include the following (this list is

non-exhaustive and may differ from one country to

the next):

• the possibility of hybrid working and working from

offices closer to home, thus contributing to reducing

CO2 emissions and helping to improve work-life

balance

• free public transport to encourage sustainable daily

commuting

• bicycle scheme, a tax-friendly contribution for buying

an electric or other bicycle to encourage sustainable

commuting, with a higher reimbursement per

kilometre applying for travel by bicycle than for travel

by car

• Banking for Better (B4B) days, giving employees the

opportunity to take up to one week of B4B days to

make a contribution to society. In 2025, we updated

our employment conditions further by supporting

employees serving as reservist. They are explicitly

allowed to use Banking for Better days, regardless of

any compensation they may receive for making that

contribution

• cross‑sector mobility guidance to help employees

move into sectors with labour shortages, such as

education and healthcare

• personal development budget to support employees’

employability both now and in the future.

Performance management

A performance management process is in place that is

aimed at pursuing ABN AMRO’s purpose and strategy

by managing employee performance. Our performance

management process helps us to align our objectives

with the bank’s strategy, purpose and core values.

Where applicable, it also serves as the basis for

awarding variable remuneration. ABN AMRO’s

performance management process is called Together &

Better and it applies to all employees globally. In

addition to being a tool for steering performance,

Together & Better encourages employees to take

control of their performance, development and careers

in a mature employment relationship. Our performance

management also aims, where possible and relevant, to

make a clear link between performance and reward.

KPI-setting

At the beginning of the year, employees take the

initiative to set objectives that are aligned with ABN

AMRO’s bank-wide strategic KPIs. It is the joint

responsibility of the manager and the employee to

agree on the objectives. Within Together & Better,

objectives are set that relate to the themes of Results

(‘What is the deliverable of your work?’), Behaviour

(‘How do you perform your work?’) and Development

(‘What talents do you want to develop?’). Employees

have at least one objective that is aligned with risk and

compliance (‘Banking licence’). Individual objectives

must be directly linked to our purpose, strategy,

business objectives and core values (‘values@work’).

The KPIs set are both financial and non-financial, as well

as qualitative and quantitative.

Performance indicators for Identified Staff

The performance management process is slightly

different for Identified Staff (at CLA and CLA+ level)

because specific legal requirements for this group must

be met. A specific KPI framework applies to Identified

Staff (CLA and CLA+); this is linked to ABN AMRO’s

bank-wide strategic KPIs and has been approved by the

Executive Board and Supervisory Board. As required by

the Dutch Financial Supervision Act, at least 50% of the

targets are non-financial. For Identified Staff, including

the Executive Board, the KPIs are set at organisation

level, client unit/function level and an individual level.

For 2025, the organisation level non-financial KPIs

consisted of Sustainability Acceleration Assets, the

Climate Plan, Growth and the relational Net Promoter

Score (rNPS). The organisation level financial KPIs were

the Cost/Income ratio, Growth and Absolute Cost Base.

The non-financial KPIs for the client units and functions

included the results of the Employee Engagement

Survey, Growth (i.e. growth of primary clients, for

Personal & Business Banking), Climate Plan and rNPS,

and the financial KPIs included the Absolute Cost Base,

Growth (operating income for Corporate Banking, and

new assets for Wealth Management) and Client Unit

ROE. At an individual level, objectives were set for

results, behaviour and development. After each

performance year, Identified Staff members receive a

final performance score, which conveys the desired

compliance and risk culture and is taken into account at

client unit/function level and an individual level.


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≡	Leadership & governance	Remuneration report


	Weighting for Executive Board ⁴	Weighting for CLA+ Identified Staff	Weighting for CLA Identified Staff
Organisation level KPIs	40-65%	10-35%	8-24%
Client unit and function level KPIs	0-25%	25-50%	16-32%
Individual KPI	35%	40%	60%
Total	100%	100%	100%
‐ of which financial ^{1, 2}	30-40%	20-40%	12-19%
‐ of which non-financial ^{2, 3}	60-70%	60-80%	81-88%
1. Financial KPIs for Executive Board include a selection from Cost/income ratio, Absolute Cost Base, Return on equity (ROE), Net growth in strategic segments and Financial performance. For CLA+ and CLA Identified staff, the financial KPIs include a selection of Cost/income ratio, Growth, Absolute Cost Base and Client Unit ROE.
2. The mix and weighting of KPIs are tailored to the specific role of the Executive Board member or Identified Staff member.
3. Non-financial KPIs for Executive Board include a selection from Sustainability (Sustainability Acceleration Assets and Climate Plan), Employee Engagement, Risk, Compliance & Regulatory / Licence to Operate, Growth, rNPS, ESG: Sustainability or People, Customer Experience and Behaviour. For CLA+ and CLA Identified Staff, the non-financial KPIs include a selection from Sustainability Acceleration Assets, Climate Plan, Growth, rNPS, EES, Result, Behaviour and Development.
4. The CEO has KPIs on an individual and organisation level only.

Performance Management and

Sustainability

Sustainability is part of ABN AMRO’s performance

management processes. As described above,

sustainability is directly included in the KPI frameworks

of Identified Staff, including the Executive Board.

For CLA employees, sustainability is included in the

calculation of the pool for discretionary variable

remuneration.

Gender pay gap and equal pay

The gender pay gap is the difference in average gross

salaries between men and women. ABN AMRO

currently calculates the unadjusted gender pay gap, as

well as the gender pay gap corrected per job level

(whereby each job level is linked to a salary scale) for

base salary, for its employees in the Netherlands. For

ABN AMRO CLA employees working in the Netherlands,

the unadjusted gender pay gap in 2025 amounted to

14.1% in favour of men (compared with 14.9% in

2024). The unadjusted gender pay gap is mainly

attributable to more men being in higher job level

positions than women, and more women in lower job

level positions. ABN AMRO’s unadjusted gender pay

gap was slightly higher than the unadjusted gender pay

gap in the Netherlands in 2025, which was 10.5%

(source: FNV). When the unadjusted gender pay gap is

corrected for job level, the result is the adjusted gender

pay gap. The adjusted gender pay gap in 2025 was

0.44% in favour of men (compared with 0.66% in

2024).

We will continue to focus on increasing gender diversity

in higher job levels, enabling a reduction in the

unadjusted gender pay gap. Our ambition is

demonstrated by our DE&I targets, which are set in our

DE&I policies for our entire workforce. With regard to

the gender pay gap, reference is also made to the ‘Our

employees at a glance’ section in the Sustainability

Statements, which provides the international, bank-

wide gender pay gap disclosure in line with the ESRS

requirements.

Equal pay

ABN AMRO strives to ensure equal pay regardless of

factors such as gender, race, religion, cultural

background, sexual orientation, belief system or

political affiliation. Our generic job profile methodology,

which maps out all Dutch CLA jobs, leads to a job grade

that is determined in line with the Hay methodology.

The Hay methodology is also used for the CLA+ levels

and is recognised as a gender-neutral, objective and

verifiable job-grading methodology. Each job level at

CLA and CLA+ level is then linked to a salary scale. In

addition, our remuneration policy contains guidelines

for various moments of remuneration, i.e. salary-setting

for new hires or annual salary increases. We periodically

review the development of equal pay in our

remuneration policies and practices, comparing salaries

of men and women. This internal study shows a

consistent practice of equal pay, as also confirmed by a

gender pay gap (adjusted for job level) of less than 1%.

In the coming years, ABN AMRO will report on the

gender pay gap and equal pay in greater detail, in line

with the requirements of the EU Pay Transparency

Directive.

EU Pay Transparency Directive

The EU Pay Transparency Directive, which entered into

force in 2023, aims to promote equal pay between men

and women by introducing concrete measures to

increase pay transparency. EU Member States are

required to transpose this Directive into their national

legislation no later than 7 June 2026. ABN AMRO is

preparing to comply with the requirements stemming

from this Directive, both in the Netherlands and in other

EU countries where the bank operates.

Although the Dutch government published a draft bill

to implement the Directive on 26 March 2025, it

decided to postpone actual implementation until

1 January 2027. At this stage, the Netherlands is the

only EU Member State that is formally not expected to

meet the EU‑wide transposition deadline. ABN AMRO is

nevertheless already preparing for compliance with the

Directive in the Dutch context.


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Developments and business events in 2025

Collective labour agreements

In the Netherlands, ABN AMRO has two CLAs in place

which are applicable to almost all internal employees.

The Employment Conditions CLA is applicable until

1 July 2026, and the Social Plan until 1 July 2026. On

14 October 2025, it was announced that the Social Plan

would be extended from 1 July 2026 to 1 July 2029,

without any changes to its content. With this extension of

the robust Social Plan, the bank and the unions reaffirmed

the importance of providing employees with clarity and

certainty regarding any individual consequences that may

arise from reorganisations.

France, Germany and Belgium have their own CLAs.

In France, the applicable CLA was signed in

December 2024, resulting in salary increases that were

applicable from 1 January 2025 for employees with at

least one year of service. The salary increases ranged

from 1% to 2.5%, depending on the employee’s annual

base salary (the lower the salary, the higher the salary

increase). In addition, there were increases to the

monthly homeworking allowance and the employer’s

contribution to the employee savings plan, and there

was a one-off agreement to freeze the cost increase of

mandatory health insurance for 2025. Discussions for a

new CLA were entered into towards the end of 2025.

In Germany, the trade unions agreed on a CLA for the

banking industry that will apply from June 2024 until

the end of September 2026 (28 months). Wages were

increased by 5.5% from August 2024, followed by a 3%

increase in August 2025. A further increase of 2% will

take effect in July 2026. The CLA for the German

banking industry also applies to around 45% of HAL

employees. Employees working within Corporate

Banking and Clearing are not covered by the German

banking industry CLA and have discretionary salary

increase arrangements.

In Belgium, the annually agreed ‘CLA 90’ outlines the

conditions and framework for annual collective variable

remuneration, which is linked to predefined collective

objectives. These are in line with the objectives of the

Energy & Collaboration Plan and consist of targets for

financials and collaboration. The mandatory salary

increases throughout 2025 amounted to a total of

2.08%.

Hiring freeze

On 7 April 2025, ABN AMRO implemented a hiring

freeze, applicable to the entire bank and effective until

further notice, to manage costs responsibly. While we

recognise the significance of this decision, we also view

the hiring freeze as an opportunity to strengthen our

internal capabilities, optimise existing talent and foster a

more collaborative working environment, all in

alignment with our strategy. The hiring freeze did not

affect ABN AMRO’s remuneration policies or principles.

Violation of bonus prohibition

In 2025, DNB imposed an administrative fine on

ABN AMRO for violating the bonus prohibition in the

period 2016 to 2024. Although ABN AMRO interpreted

and applied the applicable legislation in good faith, we

acknowledge that our viewpoint was incorrect. We

regret this, are aware of the possible societal impact

and have accepted and paid the fine of EUR 15 million

imposed by DNB.

New strategy

In November 2025, the bank announced a new strategy

in which People & Performance is defined as a key

enabler. This includes building a high-performance

culture, investing in a digitally fluent workforce and

rightsizing the workforce. ABN AMRO announced it

would rightsize the organisation, resulting in a net total

reduction of the global workforce by 5,200 FTEs by

2028 compared with year‑end 2024. Around half of the

reductions are expected to take place through attrition.

In 2025, a reduction of approximately 1,500 FTEs was

realised. Employees will be treated transparently and

responsibly, in line with our standards. In the

Netherlands, for example, the bank and trade unions

agreed to extend the Social Plan for employees by

three years.

Legislation

Various European sustainability-related regulations,

guidelines and other publications, including

requirements relating to awarding variable

remuneration and reporting on remuneration topics,

have come into force in recent years or are scheduled to

come into force in 2026 and beyond. Examples include

the EU Pay Transparency Directive, Taxonomy

Regulation, Sustainable Finance Disclosure Regulation

(SFDR), Corporate Sustainability Reporting Directive

(CSRD), Capital Requirements Directive VI (CRD VI),

Capital Requirements Regulation III (CRR III), European

Banking Authority (EBA) guidelines and reports,

European Central Bank (ECB) guidance and reports and

other European Commission’s proposals and delegated

acts. The regulations with the most notable impact on

our remuneration policies and reporting include the

CSRD and the related European Sustainability Reporting

Standards (ESRS), which ABN AMRO has implemented

in order to provide more transparency on its

sustainability performance, and which include specific

provisions on incentive schemes and remuneration


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reports. The above list of legislation and regulations is

non-exhaustive.

Although CRD VI introduces several prudential and

governance‑related changes for banks, it does not

introduce fundamental changes to the existing

remuneration framework and basic remuneration rules.

It expands its scope and expectations in line with

broader prudential and sustainability objectives.

Variable remuneration

Variable remuneration restrictions

Various reward components that can be awarded

qualify as variable remuneration. The award of variable

remuneration is strictly regulated. Globally, our variable

remuneration is capped at 100% of fixed remuneration.

In the Netherlands, however, the Dutch legislator has

chosen to impose a stricter cap of 20%, unless an

exception applies under the remuneration regulations.

In January 2026, a legislative proposal was submitted

to the Dutch House of Representatives to amend the

existing Dutch framework for variable remuneration.

The proposal aims to narrow the scope of the current

20% variable remuneration cap. Under the current

regime, the Dutch scope covers all financial institutions,

the rules apply to all employees and the cap is set at

20%, whereas the EU framework generally permits a

cap of up to 100% for Identified Staff. The proposed

amendment is aimed at aligning Dutch practice more

closely with European standards by limiting the

application of the variable remuneration cap to

employees designated as Identified Staff. ABN AMRO

will continue to monitor developments in this legislative

process closely.

Variable remuneration in 2025

The table below shows the total variable remuneration

awarded to all staff globally in 2025, broken down by

the different types of variable remuneration listed in

the table.


(in millions)	2025	2024
Performance-related variable remuneration (including ID Staff)¹	78	62
CLA Netherlands recognition premium²	43	38
Total performance-related variable remuneration	121	100
Retention payments³	6	2
Sign-on and buy-out	1	1
Total	128	103
1. The performance-related variable remuneration mainly increased due to the acquisition of HAL.
2. In 2025, the bonus was granted over a full calendar year, whereas in 2024 an eligibility condition related to employment start date applied, resulting in a smaller group of participating employees. The underlying base amount also increased due to the CLA salary adjustments.
3. Retention payments increased due to the retention payments awarded within HAL.

Variable remuneration of Identified Staff

Based on remuneration legislation, ABN AMRO has to

qualify employees as Identified Staff based on their role

and/or income. ABN AMRO has three levels of Identified

Staff: Executive Board, CLA+ Identified Staff and CLA

Identified Staff (Other Identified Staff). When variable

remuneration is awarded to Identified Staff, it must

comply with the terms and conditions of ABN AMRO’s

Variable Compensation Plan (current version applicable

since 29 December 2020), which implements all

applicable remuneration restrictions on variable

remuneration for Identified Staff. Under this plan, the

variable remuneration is split into an upfront award of

60% and a deferred award of 40%. Deferred variable

remuneration in the current Variable Compensation

Plan vests in equal instalments in the four years after

the first payment. Both the upfront award and the

deferred award consist of a 50% cash award and a 50%

non-cash award. The instrument underlying the non-

cash award consists of performance certificates, the

value of which depends on the share price of ABN

AMRO and therefore fluctuates in line with the market.

The value of the performance certificates is paid out in

cash. A one-year retention period applies to the non-

cash award.

Malus assessment 2025

ABN AMRO has several risk-mitigating measures in place

that apply to variable remuneration. As part of the end-

of-year process, ex-ante and ex-post risk assessments

are conducted. A malus (downward adjustment of

variable remuneration that has not yet been paid out)

and/or clawback (clawing back variable remuneration

that has already been paid out) may be applied, in full or

in part, insofar as the following criteria are met:

• failure to meet the appropriate standards of

competence and correct behaviour (e.g. compliance

with the principles of the Banker’s Oath, internal

procedures and policies, internal codes of conduct

and relevant laws and regulations)


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• a significant downturn in the financial performance of

the institution or client unit/function (based on

specific indicators)

• responsibility for conduct that has resulted in

a considerable deterioration of the institution’s

financial position

• payment was based on incorrect information about

the fulfilment of the criteria and/or conditions for

payment

• a significant failure of risk management in the

institution or client unit/function where the Identified

Staff member works

• significant changes in the institution’s economic or

regulatory capital base

The Executive Board and Supervisory Board decide on

the application of a malus based on the advice of Risk,

Compliance and Audit, with input from other

ABN AMRO departments (such as Legal, HR and

Finance).

The malus assessment for 2025 relates to the vesting of:

• the first tranche of deferred variable compensation

for the 2024 performance period

• the second tranche of deferred variable

compensation for the 2023 performance period

• the third tranche of deferred variable compensation

for the 2022 performance period

• the fourth tranche of deferred variable remuneration

for the 2021 performance period

The Supervisory Board established, after an assessment

against the malus criteria set out above, that no malus

was applied for the 2025 performance year.

Remuneration details of Identified Staff

The following tables contain remuneration details of the

award to Identified Staff. The first table is the

segregated overview of the number of Identified Staff

and their aggregated remuneration (in EUR thousands)

at each client unit/function. In 2025, ABN AMRO

reviewed the selection of Identified Staff in line with the

applicable criteria and this process, in combination with

the acquisition of HAL, led to a number of changes in

the Identified Staff population.


		2025		2024
	Number of FTEs (Identified Staff)²	Aggregated remuneration (in thousands)	Number of FTEs (Identified Staff)²	Aggregated remuneration (in thousands)
Personal & Business Banking	42	10,466	53	12,077
Wealth Management	97	24,392	41	12,186
Corporate Banking	81	35,873	95	34,626
Group Functions¹	155	47,188	191	53,920
Total	375	117,919	380	112,809
1. Executive Board and Supervisory Board members are included under Group Functions.
2. The number of FTEs includes all employees that were Identified Staff during the year (including leavers).

The following two tables contain an overview of the

number of employees whose total annual remuneration

attributed to the financial year (including, for example,

severance payments) exceeds EUR 1 million.

The first table specifies the number of employees per

client unit/function. The second table specifies the

number of employees per organisational level.


	Remuneration in millions in 2025³
(in FTE)	1-1.5	1.5-2	2-2.5	2.5-3	3-3.5	3.5-4	4-4.5	>4.5
Personal & Business Banking
Wealth Management¹	2
Corporate Banking
Group Functions²	2
1. The remuneration of one CLA+ member within Wealth Management exceeded the threshold of EUR 1 million, owing to salary and severance payments. This concerns an employee with a foreign contract. Furthermore the remuneration of one HAL ExBo member exceeded the EUR 1 million threshold (1 July 2025 – 31 December 2025).
2. Executive Board and Supervisory Board members are included under Group Functions.
3. The remuneration in this table reflects the amounts attributed to the financial year, in accordance with the EBA requirement. Please note that the remuneration disclosures in the tables Remuneration of Executive Board and Supervisory Board represent the remuneration allocated to the financial year in accordance with EU IFRS.


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	Remuneration in millions in 2025²
(in FTE)	1-1.5	1.5-2	2-2.5	2.5-3	3-3.5	3.5-4	4-4.5	>4.5
Executive Board	2
CLA+¹	2
Other Identified Staff
1. The remuneration of one CLA+ member within Wealth Management exceeded the threshold of EUR 1 million, owing to salary and severance payments. This concerns an employee with a foreign contract. Furthermore the remuneration of one HAL ExBo member exceeded the EUR 1 million threshold (1 July 2025 – 31 December 2025).
2. The remuneration in this table reflects the amounts attributed to the financial year, in accordance with the EBA requirement. Please note that the remuneration disclosures in the tables Remuneration of Executive Board and Supervisory Board represent the remuneration allocated to the financial year in accordance with EU IFRS.

The next table provides an overview of the total

remuneration, broken down by type of remuneration

(i.e. fixed or variable). For variable remuneration, the

amounts are broken down further specified into the

relevant cash and non-cash components in line with the

Variable Compensation Plan.


2025	Number of FTEs (Identified Staff)		Aggregated remuneration (in thousands)
	SB, ExBo and CLA+	Other Identified Staff
Fixed remuneration	191	184	102,164
Variable remuneration ^{1, 2}	96	147	15,755
- of which in cash			10,797
- of which in non-cash instruments			4,958
- of which unconditional (up-front payment)			11,536
- of which conditional (deferred payment)			4,219
Retention payments			632
Sign-on payments	2	1	195
Severance payments³	2	6	2,513
1. Retention payments and sign-on payments are also included in the total variable remuneration over 2025.
2. Due to their specific nature, certain variable compensation elements are paid out in cash and are not or only partially subject to deferral.
3. The highest severance pay amounted to EUR 646,000.

For Identified Staff, 50% of the variable remuneration is

awarded in the form of a non-cash instrument. Starting

from performance year 2020, the non-cash instrument

has changed from depositary receipts to performance

certificates. The table below reflects the number of all

non-cash awards that were in place on

31 December 2025 for performance years 2019 to

2024 inclusive. According to the Variable Compensation

Plan, the value of a non-cash award is equivalent to the

value of one share of ABN AMRO.



(in thousands of DRs and PCs)		2025		2024
Outstanding as at 1 January		627		649
Granted during the year		264		314
Forfeited during the year	11		14
Paid out during the year cash	321		316
Paid out during the year DRs and PCs	3		6
Total paid out/forfeited		-335		-336
Outstanding as at 31 December		556		627

Executive Board

Executive Board Remuneration Policy

The Executive Board Remuneration Policy is published

on our website. It was adopted by the Annual General

Meeting on 24 April 2024 and took effect on

1 January 2024. The remuneration of the Executive

Board is in line with this policy.

The 2024 Executive Board Remuneration Policy has an

updated KPI framework that facilitates ABN AMRO’s

Executive Board composition and further enhances the

link with the current strategy and sustainability

objectives. In addition, weight bandwidths in the KPI

framework have been amended, for example to allow

for a higher weighting of sustainable long-term

strategy-related KPIs. The aim of the Executive Board

Remuneration Policy is therefore to contribute to

sustainable long-term value creation.

The maximum percentage of 20% for variable

remuneration has, in principle, been maintained in the

2024 Executive Board Remuneration Policy. Currently,

the bonus prohibition does not allow the awarding of

any variable remuneration. If and when variable

remuneration can be awarded, we will assess which

amount of variable remuneration is justified, taking into

account all restrictions with regard to remuneration.


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The policy provides for a collective indexation of

salaries for the Executive Board members in line with

the CLA for the Dutch banking sector (CLA Banken).

Following the establishment of this policy in 2024,

feedback received from internal and external

stakeholders has been duly noted. These stakeholders

included our Employee Council, various clients, the

general public (via an IPSOS questionnaire), a

representative number of shareholders and depositary

receipt holders, NLFI, Eumedion, VEB and proxy adviser

ISS, following constructive engagements. This approach

enabled ABN AMRO to take into account the views of a

broad range of stakeholder groups in a consultative

capacity. The Chair of the Remuneration Committee

was therefore able to obtain valuable feedback to

address areas of concern. This is in line with our

continued commitment to good governance.

Executive Board Remuneration Policy -

scenario analysis

Scenario analyses of the possible outcomes of the

variable remuneration components and their effect on

the remuneration of the Executive Board are conducted

in accordance with the Dutch Corporate Governance

Code. In line with the Dutch Banking Code (Code

Banken), the total target remuneration of the Executive

Board members is set below the median of comparable

positions within and outside the financial sector, taking

into account the relevant international context.

The Supervisory Board notes that the total remuneration

of the Executive Board is lagging behind the market.

However, no adjustments can be made due to the

bonus prohibition. As a result, the scenario analysis did

not change this outcome. In light of this, further

scenario analyses are considered less relevant.

The ongoing applicability of the fixed salary freeze, with

the exception of collective indexation under the CLA for

the Dutch banking sector (CLA Banken) and lack of

variable remuneration due to the bonus prohibition may

hamper the retention and future attraction of expert

leaders. When the 2024 Executive Board Remuneration

Policy was established, benchmarking was performed

against the relevant peer groups within and outside the

financial sector. The peer group is published on the ABN

AMRO website. The benchmarking exercise confirmed

that there is a growing discrepancy between the current

remuneration levels of the Executive Board and the

relevant benchmarking populations. This remains a

matter of concern for the Supervisory Board, as this may

compromise our ability to retain current Executive

Board members and attract new expert leaders, which

could in the longer term affect the board stability and

the execution of ABN AMRO’s strategy.

Contractual elements

All members of the Executive Board have a services

agreement (overeenkomst van opdracht) with

ABN AMRO for an unlimited period of time, which

constitutes the contractual relationship between ABN

AMRO and the Executive Board member. Appointment

terms are set in line with the rotation principles and are

a maximum of four years. All Executive Board members

are paid directly by ABN AMRO. The Executive Board

member may terminate the agreement subject to a

notice period of three months, whereas ABN AMRO

must observe a notice period of six months. In the event

of death or when the Executive Board member reaches

the Dutch state pension age (state retirement age), the

services agreement automatically ends by operation

of law.

Fixed remuneration

As long as the Dutch State holds an interest in

ABN AMRO, the Executive Board members (and a

specific group of senior staff) are not entitled to any

increases in their fixed salary other than the increases

provided for in the CLA for the Dutch banking sector.

The fixed remuneration of the Executive Board was

raised by 4% from 1 January 2025 and another 1%

from 1 July 2025, in line with the CLA for the Dutch

banking sector.

In 2025, the fixed annual remuneration was:

• from 1 January 2025 to 30 June 2025: Member of the

Executive Board: EUR 732,342 (EUR 862,672 for the

CEO);

• from 1 July 2025 to 31 December 2025: Member of

the Executive Board: EUR 739,665 (EUR 871,299 for

the CEO).

Further details of the remuneration of the individual

members of the Executive Board are provided in

Note 36 and Note 38 to the Consolidated Annual

Financial Statements.

Variable remuneration

Due to the aforementioned bonus prohibition, the

Executive Board members (and a specific group of

senior staff) are not entitled to variable remuneration.

As the bonus prohibition continued to apply in the 2025

performance year, the Executive Board did not receive

any variable remuneration. The Executive Board

members therefore only received their fixed

remuneration.


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Benefits

The Executive Board can participate in ABN AMRO’s

pension schemes applicable to all employees in the

Netherlands. For pensionable salary up to the

applicable threshold, which for 2025 amounted to

EUR 137,800, a collective defined contribution (CDC)

pension scheme applies. The total pension contribution

is 30%, of which 24.5% is an employer contribution and

5.5% is an employee contribution. The intended

pension accrual is 1.875%, based on a state retirement

age of 68 years. In 2025, the pension accrual was

1.875%. For pensionable salary in excess of

EUR 137,800, Executive Board members (just like

employees of ABN AMRO) receive a net pension

allowance that can be used to accrue a net pension in a

group defined contribution (DC) plan. The net pension

allowance amounted to 23.75% in 2025. In addition to

pension benefits, Executive Board members are eligible

for benefits such as a company car or a chauffeur.

Severance

The remuneration policy for Executive Board members

provides for a severance payment of up to a maximum

of one year’s gross salary if their contract is terminated

at ABN AMRO’s initiative. The current Executive Board

members all have the same contractual right to a

severance payment equal to three months’ gross fixed

salary. Robert Swaak stepped down as Chief Executive

Officer with effect from the Annual General Meeting in

2025. In addition, it was announced in 2025 that Ton

van Nimwegen would step down as Chief Operations

Officer with effect from 1 January 2026. For both

Robert Swaak and Ton van Nimwegen, the applicable

notice period and severance payment were taken into

account, as stipulated in the Executive Board

Remuneration Policy and with due observance of

applicable legislation.

Remuneration for the individual Executive Board members


								2025
	Base salary	Variable remuneration³	Other short-term benefits ⁴	Total short term benefits	Severance payments	Total pension-related contributions ⁵		Total
(in thousands)						Post-employment pension (a)	Short-term allowances (b)
M.M.A.S. Bérard, chair¹	599		96	695		20	120	835
R.A.J. Swaak, chair²	722		130	852	218	24	144	1,239
D.S. Dorner, vice-chair	736		10	746		29	142	917
C. Bittner	736		48	784		29	142	955
S. Fioravanti¹	736		107	843		29	142	1,014
C.L. van der Hooft - Cheong	736		36	772		29	142	944
A. van Nimwegen	736		69	805		29	142	977
F.G. Vaandrager	736		45	781		29	142	952
A.M. Vreugdenhil	736		24	760		29	142	931
Total	6,473		565	7,038	218	247	1,258	8,764
								2024
R.A.J. Swaak, chair²	829			829		38	208	1,075
D.S. Dorner, vice-chair	704		44	748		38	170	956
C. Bittner	704		48	752		38	170	960
T.J.A.M. Cuppen²	411		238	649		22	99	770
S. Fioravanti¹	176		26	202		10	42	254
C.L. van der Hooft - Cheong	704		38	742		38	170	950
A. van Nimwegen	704		65	769		38	170	977
C. Oosterloo ^{1, 2}	307		9	316		17	74	407
F.G. Vaandrager	704		58	762		38	170	970
A.M. Vreugdenhil	704		24	728		38	170	936
Total	5,947		550	6,497		315	1,443	8,255
1. The following members were appointed as Executive Board members in 2025 and 2024: M.M.A.S. Bérard (23 April 2025), C. Oosterloo (ad interim from 24 April 2024 until 1 October 2024) and S. Fioravanti (1 October 2024).
2. The following members stepped down as Executive Board members of ABN AMRO: R.A.J. Swaak (stepped down on 23 April 2025 and left with effect from 1 November 2025), T.J.A.M. Cuppen (stepped down on 24 April 2024 and left with effect from 1 August 2024) and C. Oosterloo (ad interim period ended with effect from 1 October 2024). For T.J.A.M. Cuppen, all remuneration components for the period until her services agreement ended on 1 August 2024 are included above.
3. Owing to the Bonus Prohibition Act, the Executive Board members are not entitled to receive variable compensation. This prohibition has applied since the 2011 performance.
4. Other short-term benefits consist of flight tickets, a housing allowance, compensation for lease car expenses, mortgage interest rate benefit and international schooling costs for Executive Board members' children when applicable. If applicable, the amount of the payment for remaining leave entitlement at the end of the services agreement is also included in Other short-term benefits.
5. The Executive Board members participate in ABN AMRO Bank's pension plans for employees in the Netherlands. This participation is not mandatory for M.M.A.S. Bérard and S. Fioravanti considering their specific international tax resident status. Total pension-related contributions refer to (a) the employer contribution to the pension fund for the CDC pension scheme for pensionable income up to EUR 137,800 (2024: EUR 137,800) and (b) the arrangement in accordance with the ABN AMRO Collective Labour Agreement ('ABN AMRO CAO'). In 2025 the employer contribution decreased from 30% to 23.75%.


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Loans from ABN AMRO to Executive Board

members

Executive Board members may obtain banking and

insurance services from ABN AMRO and its subsidiaries

on the basis of regular applicable terms. Executive

Board members do not receive privileged financial

services. The loans included in the overview below are

mortgage loans.


			2025			2024
(in thousands)	Outstanding as at 31 December	(Addition)/ redemptions	Interest rate	Outstanding as at 31 December	(Addition)/ redemptions	Interest rate
D.S. Dorner	742	171	3.1%	913	-471	3.5%
C.L. van der Hooft - Cheong	904	27	1.2%	931	497	1.2%
C. Oosterloo¹				150		2.1%
F.G. Vaandrager	369	128	3.8%	497	-497	4.2%
1. The following member was appointed in 2024: C. Oosterloo (ad interim from 24 April 2024 until 1 October 2024).

Development of annual remuneration of

Executive Board members

The following table shows the annual development in

the remuneration of Executive Board members. The

table shows how changes in annual remuneration relate

to the previous years, to ABN AMRO’s performance and

to developments in the average employee

remuneration. The average employee remuneration for

the financial year is determined by dividing the total

wage costs in the financial year (as included in the

consolidated financial statements) by the average

number of FTEs during the financial year. For a like-for-

like comparison, the average employee remuneration is

shown excluding social security charges.

The column ‘Absolute’ shows the difference in the

indicator over two periods in time, while the column

‘Relative’ shows the increase or decrease as

a percentage. Since 2021, other short-term benefits

have been included in the disclosure of total Executive

Board remuneration. The comparative figures are

adjusted accordingly.


		2020 - 2021		2021 - 2022		2022 - 2023		2023 - 2024		2024 - 2025		Reporting year
(in thousands)	Position	Absolute	Relative	Absolute	Relative	Absolute	Relative	Absolute	Relative	Absolute	Relative	2025
ExBo
M.M.A.S. Bérard, chair¹	CEO									835	n.a.	835
R.A.J. Swaak, chair²	CEO	291	n/a	7	1%	35	4%	41	4%	164	n.a.	1,239
D.S. Dorner, vice-chair³	CCO	90	n/a	789	n/a	33	4%	44	5%	-39	-4%	917
C. Bittner ⁴	CI&TO					924	n.a.	36	4%	-5	-1%	955
S. Fioravanti ⁵	CRO							254	n.a.	760	n.a.	1,014
C.L. van der Hooft - Cheong ⁶	CCO	89	n/a	786	n/a	28	3%	47	5%	-6	-1%	944
A. van Nimwegen ⁷	COO					73	n.a.	904	n.a.		0%	977
F.G. Vaandrager ⁸	CFO					600	n.a.	370	n.a.	-18	-2%	952
A.M. Vreugdenhil ⁹	CCO			724	n/a	176	n.a.	36	4%	-5	-1%	931

Company performance
Profit		1,279	n/a	634	51%	829	44%	-294	-11%	-150	-6%	2,252
Cost/income ratio		10.0%	15%	-7.2%	-9%	-8.5%	-12%	1.0%	2%	2.7%	4%	64.4%
Return on average equity		6.7%	n/a	2.8%	48%	3.6%	41%	-2.2%	-18%	-1.3%	-13%	8.7%

Average employee remuneration		4	4%	4	4%		0%	5	5%	3	2%	115
1. M.M.A.S. Bérard joined the Executive Board on 23 April 2025.
2. R.A.J. Swaak joined the Executive Board on 22 April 2020 and stepped down on 23 April 2025. His services agreement ended with effect from 1 November 2025.
3. D.S. Dorner joined the Executive Board on 24 November 2021.
4. C. Bittner joined the Executive Board on 1 January 2023.
5. S. Fioravanti joined the Executive Board on 1 October 2024.
6. C.L. van der Hooft-Cheong joined the Executive Board on 24 November 2021.
7. A. van Nimwegen joined the Executive Board on 1 December 2023.
8. F.G. Vaandrager joined the Executive Board on an interim basis on 1 May 2023 and on a permanent basis on 16 November 2023.
9. A.M. Vreugdenhil joined the Executive Board on 1 March 2022.


ABN AMRO	Annual Report 2025	181


≡	Leadership & governance	Remuneration report

The five-year development of the annualised base

salary of the CEO and other Executive Board positions is

shown in the next graph. Due to the bonus prohibition,

the fixed remuneration of the Executive Board was

increased by the collective increases at 1 January 2025

and 1 July 2025, in line with the CLA for the Dutch

banking sector.

Five-year annualised average base salary –

Executive Board (in thousands)

CEO pay ratio

The CEO pay ratio is the comparison between the total

annual remuneration of the CEO and the average salary

of all ABN AMRO employees. In line with our overall

remuneration philosophy, we strive for a moderate pay

ratio. The salary of our CEO does not fluctuate as it has

been set in line with the Executive Board Remuneration

Policy and does not contain any variable elements. The

ratio between the average employee remuneration for

the financial year and the CEO’s total annual

remuneration has been calculated in accordance with

the Corporate Governance Code 2025. The calculation

does not include temporary agency workers and

external contractors. The ratio in 2025 was 8.22. The

ratio reflects the CEO’s total remuneration, including

pension costs and social security charges, divided by

the average employee remuneration including pension

costs and social security charges during 2025. The

average annual remuneration of the employees is

determined by dividing the total wage costs in the

financial year (as included in the consolidated financial

statements) by the average number of FTEs during the

financial year.

The pay ratio at ABN AMRO is significantly lower than

that of other companies included in the AEX and AMX

indices. This difference primarily reflects the bank’s

structurally different remuneration environment. ABN

AMRO operates under strict remuneration restrictions.

These rules create a fundamentally different

remuneration structure compared with non-financial

companies, which often have broader latitude to award

higher executive compensation. Given this context, ABN

AMRO’s lower pay ratio is regarded as an accurate and

appropriate representation of ABN AMRO’s current

position, also considering the applicable remuneration

restrictions.

The ABN AMRO ratios published in 2021, 2022, 2023

and 2024 were 8.78, 8.5, 8.96 and 8.75, respectively.

Information on the pay gap in line with the ESRS

requirements is included in the ‘Our employees at a

glance’ section in the Sustainability Statements.

CEO pay ratio

2025 Performance of the Executive Board

ESRS

Although no variable remuneration is awarded, a KPI

framework is used to assess the performance of the

Executive Board. The annual KPI framework for the

Executive Board is approved by the Supervisory Board.

The performance criteria for Executive Board members

are based on financial and non-financial measures at

organisation level, client unit/function level and

individual level, as set out in the Executive Board

Remuneration Policy. The performance criteria and

targets reflect and contribute to key elements of ABN

AMRO’s strategy and sustainable long-term value

creation, including Sustainability and Licence to Operate.

Annual targets are set for all KPIs. The KPI-setting is in

line with the legal requirement to have at least 50% non-

financial KPIs.

The Supervisory Board, acting in coordination with the

relevant ABN AMRO departments, continuously

monitors and evaluates the Executive Board members’

performance against the established KPIs and targets.


ABN AMRO	Annual Report 2025	182


≡	Leadership & governance	Remuneration report

KPI-setting and performance

ESRS

In 2025, all financial KPIs were focused on long-term

profitable growth, a healthy balance of capital and the

need to control our costs in order to be sustainable. The

scores are given within a 1-5 bandwidth, with a score of

1 being the lowest score, a score of 3 being defined as

‘meets requirements’ and a score of 5 being the highest

score.

Organisational level

Financial KPIs (return-based and cost-based) were, on

average, achieved at organisation level. In addition to

reporting on financial indicators, the organisation

reported on three non‑financial KPI categories related

to Sustainability, People, and Risk, Compliance &

Regulatory. Progress on sustainability was measured

using KPIs linked to ABN AMRO’s Climate Plan and

Sustainability Acceleration Assets. These assets reflect

the share of sustainability‑focused and EU

Taxonomy‑aligned financing and investments relative to

the bank’s total assets. The Climate Plan KPI tracks the

annual progress of targeted economic sectors against

their planned climate‑transition pathways. Both KPIs

performed in line with expectations.

The organisation‑wide employee engagement score

was 79%. Although this represents a decline compared

with the previous year, due in part to organisational

changes, it still reflects strong commitment and

resilience among employees.

The KPI for Risk, Compliance & Regulatory was

exceeded, indicating further improvement in internal

control and compliance awareness.

Client units and functions

Financial KPIs were cost-based and growth-based. Cost

objectives were met on average. Growth in certain

strategic segments fell short of targets, owing to the

influence of market conditions and competitive

dynamics. Employee engagement at client unit and

function level followed the organisation‑wide pattern

and showed a moderate decline compared with the

previous year. The Primary Clients Growth KPI showed a

notable increase in the share of primary clients;

however, the result of the KPI was just below target. The

rNPS KPI, linked to customer experience, exceeded

expectations.

Individual Level

Executive Board members were assessed on objectives

related to financial performance, ESG (sustainability,

people), customer experience, and risk & regulatory

performance. The average individual score across the

Executive Board was equivalent to “meets

expectations”. The overall assessment of the

Supervisory Board is that, on average, all members of

the Executive Board had good overall performance

ratings in 2025.


	Type	KPI	Score 1-5²
2025

Organisation
	Financial	Return based: RoE (0-20%)	4
		Cost based: Cost/income ratio (5%)	3
		Cost based: Absolute cost base (5-10%)	2
	Non-financial	Sustainability: Sustainability Acceleration Assets (5%)	3
		Sustainability: Climate plan (5%)	3
		People: Employee engagement (0-10%)	2
		Risk, Compliance & Regulatory / Licence to Operate (10-25%)	4
Client unit and function
	Financial	Cost based: Absolute cost base (0-10%)	3
		Growth based: Net growth in strategic segments (CB & WM; 0-5%)	2
	Non-financial	Customer experience: Primary clients Growth (P&BB; 0-5%)	2
		Customer experience: rNPS (0-10%)	5
		People: Employee engagement (0-10%)	2
Individual¹
	Financial	Financial performance (5-10%)	3
	Non-financial	ESG: Sustainability or People (5%)	3
		Risk, Compliance & Regulatory / Licence to Operate (5-10%)	3
		Customer experience (5-7.5%)	3
		Behaviour (5-7.5%)	3
1. The scores are the average of the absolute individual scores of all ExBo members.
2. The organisation and client unit scores are the average scores per KPI. The weight/applicability of each KPI differs per ExBo member.


ABN AMRO	Annual Report 2025	183


≡	Leadership & governance	Remuneration report

Supervisory Board

Supervisory Board Remuneration Policy

The 2024 Supervisory Board Remuneration Policy is

published on our website and was adopted by the

Annual General Meeting on 24 April 2024 and took

effect on 1 January 2024.

The 2024 Supervisory Board Remuneration Policy

continues the approach of the 2020 Supervisory Board

Remuneration Policy for fixed and variable

remuneration, in line with the applicable Remuneration

Restrictions. The principles of the Supervisory Board

Remuneration Policy are based on the remuneration

principles in our Global Reward Policy that applies to all

employees within ABN AMRO as a whole. Our Global

Reward Policy is designed to support the bank’s

strategy, objectives, values and long-term interest as

explained above in the chapter on Remuneration

principles and Policies. In that regard, the Supervisory

Board Remuneration Policy aims to contribute to the

long-term performance of ABN AMRO and to

sustainable long-term value creation. The Supervisory

Board Remuneration Policy takes into account the

special position that Supervisory Board members have

in a two-tier board system.

The remuneration of the Supervisory Board is set in line

with the Supervisory Board Remuneration Policy by

determining the applicable amounts within the

bandwidths of the Supervisory Board Remuneration

Policy. Consequently, a 4% indexation of the annual

fees was applied with effect from 1 January 2025 as

well as a 1% indexation with effect from July 2025, in

accordance with the CLA for the banking sector.

Fixed remuneration

The annual fees from 1 January 2025 until

30 June 2025 were as follows:

• Member of the Supervisory Board: EUR 63,899

(EUR 83,068 for the Chair)

• Member of a Committee: EUR 15,975 (EUR 19,170

for the Chair)

The annual fees from 1 July 2025 until

31 December 2025 were as follows:

• Member of the Supervisory Board: EUR 64,538

(EUR 83,899 for the Chair)

• Member of a Committee: EUR 16,134 (EUR 19,361

for the Chair)

ABN AMRO pays its Supervisory Board members

directly and does not grant any variable remuneration

or equity to Supervisory Board members. Supervisory

Board members are appointed by the General Meeting

upon nomination by the Supervisory Board. The initial

appointment period is four years unless a shorter period

is set at the time of appointment. Supervisory Board

members can be reappointed.

Further details of the remuneration of the individual

members of the Supervisory Board are provided in

Note 36 and Note 38 to the Consolidated Annual

Financial Statements.

Remuneration for the individual Supervisory Board members


(in thousands)	2025	2024
T. de Swaan, chair	135	125
M.P. Lap, vice-chair	113	107
A.C. Dorland, vice-chair²	81	111
L.J. Griffith	113	108
D.U. Hartert¹	34
S.A.C. Russell	116	106
M.L. Tannemaat	112	108
F. de Vries	116	106
W.J.M. Devriendt²		9
Total	820	780
1. In 2025 and 2024 the following member was appointed as a member of the Supervisory Board: D.U. Hartert (11 September 2025).
2. In 2025 and 2024 the following members stepped down as a member of the Supervisory Board: W.J.M. Devriendt (5 February 2024) and A.C. Dorland (11 September 2025).


ABN AMRO	Annual Report 2025	184


≡	Leadership & governance	Remuneration report

Five-year annualised average base salary –

Supervisory Board (in thousands)

Loans from ABN AMRO to Supervisory Board

members

Supervisory Board members may obtain banking and

insurance services from ABN AMRO and its subsidiaries

on the basis of regular applicable terms. Supervisory

Board members do not receive privileged financial

services. The loans included in the overview below are

mortgage loans.


			2025			2024
(in thousands)	Outstanding as at 31 December	(Addition)/ Redemptions	Interest rate	Outstanding as at 31 December	(Addition)/ Redemptions	Interest rate
T. de Swaan	1,881	-307	1.2%	1,574	6	1.0%
S.A.C. Russell	600	370	3.8%	970	-600	3.1%
M.L. Tannemaat	682	16	1.6%	698	9	1.6%
F. de Vries	1,306	-501	2.9%	805	14	2.6%

Stakeholder views

Annual General Meeting

During the Annual General Meeting of 23 April 2025,

the 2024 remuneration report was put to an advisory

vote, with 99.73% of the votes cast being in favour of

a positive advice. ABN AMRO was pleased to note the

positive advisory vote on the 2024 remuneration report

and aims to continue meeting shareholders’

expectations in this regard.

Employee participation in 2025

In addition to the Employee Council, employee

participation consists of a Commercial Council for the

three client units, an Enabler Council for the other parts

of the Dutch banking business, and several works

councils and subcommittees for subsidiaries and other

countries.

At ABN AMRO, members of work councils are

appointed for a term of three years. The current

members have been appointed until 1 July 2026.

Owing to retirements and job changes, mid-term

elections have been held for the Commercial Council

and the ICS subcommittee.

In 2025, the Dutch works councils received a total of

57 requests for advice, 12 requests for consent, 45

information memoranda and 1 notification. One of the

requests for advice concerned the acquisition of NIBC.

Employees from Corporate Banking and Wealth

Management in the Netherlands, Belgium, France,

Germany, Greece, Luxembourg, Norway and the United

Kingdom are also represented in the European Staff

Council (ESC). The ESC is a forum for information

sharing, consultation and dialogue on matters of an

economic, financial or social nature that, due to their

strategic importance or European character, are of

interest to all European establishments of ABN AMRO or

its subsidiaries.


ABN AMRO	Annual Report 2025	185


≡	Leadership & governance	Other governance information	Codes and regulations

Other governance

information

Codes and regulations

ABN AMRO is required to comply with a wide variety of

governance codes and regulations, including the Dutch

Corporate Governance Code, the Banking Code and

CRD V. This section explains how ABN AMRO complies

with these codes and regulations. More comprehensive

overviews of ABN AMRO’s compliance with such codes

and regulations can be found in the Governance Codes

and regulations section of our website.

Dutch Corporate Governance Code

We believe that when corporate governance meets high

international standards, it significantly boosts the

confidence of a company’s stakeholders. Since

depositary receipts for shares in ABN AMRO are listed

on Euronext Amsterdam, ABN AMRO adheres to the

Dutch Corporate Governance Code.

General compliance and explanations

ABN AMRO complies with all principles and best

practices of the Dutch Corporate Governance Code,

except for the deviations and nuances described below.

In the Dutch Corporate Governance section of its

website, ABN AMRO also publishes a detailed ‘comply

or explain’ list with regard to adherence to the Dutch

Corporate Governance Code.

Best practice provision 1.3.6

(Absence of an internal audit department)

This best practice provision does not apply since there is

a separate department for the internal audit function

within ABN AMRO.

Best practice provision 2.1.3 (Executive Committee)

This best practice provision is not applicable to

ABN AMRO because ABN AMRO has not had an

Executive Committee since 24 November 2021.

Best practice provision 2.1.5

(Policy on diversity, equity & inclusion)

ABN AMRO has a diversity, equity & inclusion policy. Its

suitability policy also includes a diversity policy for the

composition of ABN AMRO’s Supervisory Board and

Executive Board. ABN AMRO has targets regarding

gender diversity of the Executive Board, Supervisory

Board and senior management. The other aspects (age,

nationality, education/professional background and

geographical reference) are all taken into account on a

qualitative basis to ensure diversity and inclusion in the

composition of the Executive Board, Supervisory Board

and senior management.

Best practice provision 2.1.9

(Independence of the Chair of the Supervisory Board)

ABN AMRO applies this best practice provision, which

states that the Chair of the Supervisory Board should

not be a former member of the management board of

the company. Although Tom de Swaan was a member

of the management board of the former ABN AMRO,

the current ABN AMRO is the result of various legal and

operational separations and combinations, a merger

and a legal demerger that took place after the

acquisition of the former ABN AMRO Holding N.V. (the

former ABN AMRO Group) by a consortium of banks in

October 2007. The consortium consisted of the Royal

Bank of Scotland Group, Fortis and Banco Santander

S.A. (the Consortium). In October 2008, when the Fortis

group experienced financial difficulties, the Dutch State

acquired certain operations of the Fortis group, as well

as Fortis’ interest in the vehicle that had acquired the

former ABN AMRO Group. ABN AMRO Group N.V. (ABN

AMRO Group) was newly incorporated on 18 December

2009 to hold the operations, assets and liabilities of

parts of the former ABN AMRO Group and the part of

the Fortis group acquired by the Dutch State. The new

and current ABN AMRO was demerged from the former

ABN AMRO Bank N.V. on 6 February 2010 as a newly

incorporated entity. The former ABN AMRO Bank N.V.

was subsequently renamed Royal Bank of Scotland N.V.

On 1 July 2010, the new ABN AMRO Bank and Fortis

Bank (Nederland) N.V. merged pursuant to a legal

merger, in which the current ABN AMRO was the

surviving entity and Fortis Bank (Nederland) N.V. was the

disappearing entity. ABN AMRO Group was merged into

ABN AMRO on 29 June 2019. The former ABN AMRO

Group and ABN AMRO are different entities from the

former ABN AMRO Holding N.V. and former ABN AMRO

Bank N.V.


ABN AMRO	Annual Report 2025	186


≡	Leadership & governance	Other governance information	Codes and regulations

Best practice provision 3.1.3

(Remuneration - Executive Committee)

This best practice provision is not applicable to ABN

AMRO because ABN AMRO has not had an Executive

Committee since 24 November 2021.

Principle 3.2. and best practice provisions 3.2.1 –

3.2.2 (Management Board remuneration)

ABN AMRO complies with this principle. The Bonus

Prohibition Act (Wet aansprakelijkheidsbeperking DNB

en AFM en bonusverbod staatsgesteunde

ondernemingen), which became effective in 2011, does

not allow such compensation for board members of

financial institutions that fall within the scope of this Act

during a period of state support in the form of a

shareholding owned by the Dutch State. The members

of the Executive Board are therefore not entitled to

receive variable remuneration during the period of

government ownership.

Best practice provision 4.1.3 (Agenda)

ABN AMRO applies this principle, which states, among

other things, that (a) each substantial change in the

corporate governance structure of ABN AMRO and in

compliance with the Dutch Corporate Governance

Code and (b) material changes in the Articles of

Association should be presented to the General Meeting

as a separate discussion item or voting item, as

applicable. The only exception to this best practice

provision is that the Executive Board and the

Supervisory Board may decide to place certain topics on

the agenda under one agenda item if these topics are

justifiably related. ABN AMRO considers this exception

to be a further substantiation of this best practice

provision thatmay be necessary if proposals to amend

the Articles of Association or the corporate governance

structure of ABN AMRO are interrelated in such a way

that separate votes on each of these proposals could

lead to in an imbalanced voting result and, in turn, an

imbalance in the corporate governance structure.

Best practice provision 4.2.2

(Contacts and dialogue with shareholders)

ABN AMRO recognises the importance of bilateral

communications with current and potential

shareholders and holders of depositary receipts. In

order to facilitate such bilateral communications, the

Executive Board of ABN AMRO has adopted, with the

approval of its Supervisory Board, a Policy on Bilateral

Contacts with Shareholders in accordance with best

practice provision 4.2.2 of the Dutch Corporate

Governance Code. This policy does not specifically

include the stipulation, as included in the best practice

provision, that the shareholder should disclose its entire

share position (long. short and through derivatives) at

the company’s request. In practice, ABN AMRO will

comply with this requirement from the best practice

provision in appropriate cases.

Best practice provision 4.3.1 (Voting as deemed fit)

This best practice provision is not applicable to ABN

AMRO as it is aimed at the shareholder.

Best practice provision 4.3.3 (Cancelling the binding

nature of a nomination or dismissal)

This provision is not applicable to ABN AMRO since ABN

AMRO applies the rules that are applicable to large

companies (structuurregime).

Best practice provision 4.3.4

(Voting right on financing preference shares)

This best practice is not applicable to ABN AMRO since

ABN AMRO has not issued financing preference shares.

Best practice provisions 4.3.5 – 4.3.8 (Responsibilities

of the shareholder)

These best practice provisions are not applicable to ABN

AMRO as they are the responsibility of the shareholder.

Principle 4.4

(Recognising the importance of company strategy)

This best practice provision is not applicable to ABN

AMRO as it is aimed at the shareholder

Principle 4.5 (Issuing depositary receipts for shares)

ABN AMRO does not apply this principle. In

contradiction to this principle and provision, the issuing

of depositary receipts by STAK AAB is primarily used as

a defence measure and not to prevent shareholder

absenteeism from enabling a minority of shareholders

to control the decision-making process at a General

Meeting. Regulatory considerations have been decisive

in choosing a structure with depositary receipts as a

protective measure. Declarations of No Objection are

required in the event of a direct or indirect acquisition of

a qualified holding in regulated entities in which ABN

AMRO holds an interest. Therefore, this structure

provides ABN AMRO with the greatest possible certainty

of adequate protection against a hostile takeover.

Although the issuing of depositary receipts has been set

up primarily as a defence measure and not to prevent

absenteeism, STAK AAB aims to promote the exchange

of information between ABN AMRO on the one hand

and holders of depositary receipts and shareholders on

the other by, for example, organising a meeting of

depositary receipt holders before every General

Meeting. More information on the purpose and

functioning of the depositary receipts and STAK AAB,

including information on situations in which STAK AAB

may decide to limit, refuse or revoke powers of attorney

(and not to observe voting instructions received) can be

found on the STAK AAB website.


ABN AMRO	Annual Report 2025	187


≡	Leadership & governance	Other governance information	Codes and regulations

Best practice provisions 4.5.1 – 4.5.5 and 4.5.7 – 4.5.8

Compliance with these best practices is the

responsibility of the board of STAK AAB. With respect to

best practice provisions 4.5.5 and 4.5.8, the following

applies. In a non-hostile situation, STAK AAB will act

primarily in the interests of holders of depositary

receipts. In a hostile situation, STAK AAB will act

primarily in the interests of ABN AMRO and its business

enterprises. Under all circumstances, STAK AAB will also

take into account the legitimate interests of all other

stakeholders: clients, savers, deposit holders,

shareholders, holders of depositary receipts, employees

and the society in which ABN AMRO operates.

Furthermore, in principle STAK AAB has the obligation

to grant a power of attorney to holders of depositary

receipt holders so they can exercise the voting rights

attached to the underlying shares and will not exercise

voting rights on the shares in ABN AMRO (unless

holders of depositary receipts have asked STAK AAB to

do so). The foregoing could be different in the hostile

situations described in Article 118a, Book 2, of the

Dutch Civil Code. STAK AAB may then decide (a) to

limit, exclude or revoke powers of attorney, and (b) not

to observe voting instructions received for a period of

up to two years. Furthermore, under the depositary

receipt terms, when exercising the voting rights in a

hostile situation STAK AAB must focus primarily on the

interests of ABN AMRO and its business enterprises, as

set out above.

Principle 5.1 and best practice provisions 5.1.1 –

5.1.5 (One-tier governance structure)

This principle and these best practice provisions are not

applicable since ABN AMRO has a two-tier board,

instead of a one-tier board to which these best practice

provisions relate.

How ABN AMRO complies with the best

practice provisions for sustainable long-term

value creation, culture and diversity

Sustainable long-term value creation

Strategy to achieve sustainable short- and long-term

value creation

Please refer to the Strategy & performance chapter in

this report for a detailed explanation of the Executive

Board’s view on sustainable long-term value creation

and the strategy for achieving it, as well as a description

of the contributions made to sustainable long-term

value creation during 2025.

Diversity

Supervisory Board profile

In line with best practice provision 2.1.1 of the Dutch

Corporate Governance Code, the Supervisory Board has

drawn up a profile of its scope and composition, taking

into account the nature and activities of ABN AMRO. The

current collective profile is set out in Annex 3 of the

Rules of Procedure of the Supervisory Board, which are

published on ABN AMRO’s website. For more

information we refer to the section on the composition

of the Supervisory Board in this report.

In line with best practice provision 2.1.5 of the Dutch

Corporate Governance Code, ABN AMRO has drawn up

a diversity policy for the composition of the Supervisory

Board and Executive Board. This is part of ABN AMRO’s

suitability policy.

Please refer to the Leadership and governance structure

section in this report for details of gender diversity

within ABN AMRO’s management bodies.

Diversity, equity & inclusion policy

ABN AMRO is committed to diversity and inclusion,

including promoting equal treatment of and equal

opportunities for employees, preventing harassment,

ensuring non-discrimination and ensuring compliance

with national and local labour and employment laws. A

summary of ABN AMRO’s diversity, equity & inclusion

policy is published on ABN AMRO’s website.

Diversity targets, initiatives and achievements

Please refer to the Strategy & performance chapter in

this report for detailed information on diversity targets,

initiatives and achievements.

Culture

We have completed our culture change programme,

which was set up to strengthen ABN AMRO’s

capabilities for sound risk-taking and execution power.

This ensures our collective investment in culture

continues, with the bank’s senior management and HR

at the forefront.

Tax Governance Code

General compliance and explanations

ABN AMRO complies with all the principles and

transparency requirements in the Dutch Tax

Governance Code of the Confederation of Netherlands

Industry and Employers (VNO-NCW), as described

below. Under the Governance section on its website,

ABN AMRO also publishes a detailed ‘comply or explain’

list of its adherence to the Dutch Tax Governance Code.

This Code establishes a clear and transparent system, in

which accountability and supervision of tax policies are

intrinsic elements.


ABN AMRO	Annual Report 2025	188


≡	Leadership & governance	Other governance information	Codes and regulations

Like the Corporate Governance Code, the Tax

Governance Code is based on the principle of ‘comply

or explain’: companies must account for any principles

in the Code with which they are not currently compliant.

As stated in the Dutch Tax Governance Code,

ABN AMRO has a clear tax strategy and clear tax

principles. ABN AMRO’s tax principles, which apply to

all entities in the corporate group, are published on

our website.

ABN AMRO has a tax governance structure in place in

which the board plays the principal role. It does not use

tax havens to avoid taxation; a presence in a tax haven is

permitted only if it has real economic significance.

We do not view tax as simply a cost, but also as a

means of contributing to society, to sustainable growth

and long-term prosperity. We are committed to

complying with the letter, intent and spirit of tax

legislation wherever we operate, and to paying the right

amount of tax at the right time.

ABN AMRO uses business structures with genuine

commercial purpose, maintains relations with tax

authorities built on trust and transparency, and

communicates regularly on its approach and the taxes

it pays.

In 2025, our tax contribution, including taxes paid

directly and those collected on behalf of tax authorities,

amounted to EUR 2.9 billion (2024: EUR 2.5 billion).

Total taxes paid and collected

(in millions)

Total tax

contribution

EUR 2,549

(2024)

Total tax

contribution

EUR 2,898

(2025)

Managing tax risk

Our Tax Control Framework is updated, whenever

necessary, to reflect changes in regulations and

stakeholder interests. Tax is also integrated into our

broad risk management process and included in risk

assessments for new products and business activities.

We monitor compliance with our tax policy and have

controls in place to ensure that tax returns are filed in

good time and that tax positions are promptly identified

and reported.

We engage with tax authorities to ensure we fully

understand our tax obligations and regularly exchange

information in line with Dutch and international

regulations.

The higher bank tax rate implemented in 2024 is still in

place. This has an impact on ABN AMRO’s total tax

contribution and effective tax rate.

Client tax integrity

Our standards in the area of client tax integrity are in

line with our core values, moderate risk appetite, wider

risk profile and the DNB’s expectations. Given changing

international tax rules, we organise training to ensure

staff remain aware of integrity risks. In the case of

clients, we steer clear of aggressive tax planning and

avoidance structures. Our intention is always to offer

products that comply with the letter, intent and spirit of

tax legislation and that are commercially sound rather

than tax-driven. This approach is included in the bank’s

tax policy, tax principles and product approval process

and monitored through our Tax Control Framework.

Dutch Banking Code

The Dutch Banking Code sets out principles that banks

with a corporate seat in the Netherlands (i.e. with a

Dutch banking licence) should observe in terms of

corporate governance, risk management, audit and

remuneration. The Dutch Banking Code applies to

ABN AMRO as the main entity within a group that holds

a Dutch banking licence. ABN AMRO is therefore

committed to complying with the Dutch Banking Code

and devotes a great deal of effort to ensuring that the

spirit of the code is reflected in the behaviour of the

employees and the culture of the bank. As such, we are

pleased to confirm that ABN AMRO complies with the

principles of the Dutch Banking Code. A principle-by-

principle overview of the manner in which ABN AMRO


ABN AMRO	Annual Report 2025	189


≡	Leadership & governance	Other governance information	Codes and regulations

Bank complied with the Dutch Banking Code in 2025 is

published on our website.

All members of the Supervisory Board and Executive

Board have taken the Banker’s Oath, as required by

Dutch law. The oath is a confirmation of ABN AMRO’s

existing policies, which are fully in line with the bank’s

cultural principles and core values. Along with the

introduction of a Social Charter and the Banking Code,

the Dutch banking industry has taken the initiative to

have all employees take the Banker’s Oath. Employees

take the oath to affirm their commitment to upholding

high standards of ethical behaviour. They are personally

responsible for complying with these rules of conduct

and may be held accountable for non-compliance.

Subsidiaries of ABN AMRO and the

Dutch Banking Code

ABN AMRO operates through several subsidiaries with

a banking license, including ABN AMRO Clearing Bank

N.V., ABN AMRO Hypotheken Groep B.V. and

International Card Services B.V. In November 2025 the

bank announced the planned acquisition of NIBC Bank

N.V., pending regulatory approval.

ABN AMRO applies the principles of the Dutch Banking

Code to all these Dutch subsidiaries on a consolidated

basis by developing group-wide policies and standards

that promote compliance with internal and external

rules and best-practice provisions. In view, however, of

the differences between the activities, organisation and

risk management of the subsidiaries, the application of

group-wide policy and standards may vary from one

subsidiary to another. An explanation of the manner in

which these subsidiaries complied with the Dutch

Banking Code during 2025 is published on our website.

CRD V

Article 96 of CRD V requires financial institutions to

explain on their website how they comply with the

requirements of Articles 88-95 of CRD V. These articles

set out governance, disclosure, remuneration,

nomination and management body requirements for

financial institutions. The obligation to publish such

an overview was implemented in Dutch law by

Article 134b of the Decree on prudential measures

FMSA (Besluit prudentiële regels Wft).

ABN AMRO has published an overview of how the bank

complies with Article 134b of the Prudential Measures

Decree FMSA and Article 96 of CRD V on our website.


ABN AMRO	Annual Report 2025	190


≡	Leadership & governance	Other governance information	Codes and regulations

Legal structure

Global structure

The complete list of subsidiaries and participating

interests as at 31 December 2025, as referred to in

Article 414, Book 2, of the Dutch Civil Code, has been

filed with the Trade Register.

Personal & Business Banking

ABN AMRO’s Personal & Business Banking client unit is

supported by the following subsidiaries (this list is not

exhaustive):

• ABN AMRO Hypotheken Groep B.V. is responsible for

ABN AMRO’s mortgage activities in the Netherlands

for residential real estate, providing mortgage

products through various channels and distributed

under various brands, including its core mortgage

labels ABN AMRO and Florius. On 12 November 2025

it was announced that ABN AMRO will discontinue the

Moneyou brand. Furthermore, ABN AMRO intends to

legally merge ABN AMRO Hypotheken Groep B.V. into

ABN AMRO Bank to further improve operational

efficiency.

• International Card Services B.V. (ICS) is the market

leader in credit card issuing in the Netherlands. ICS

issues credit cards for ABN AMRO, co-branders and its

own label.

• ALFAM Holding N.V. (Alfam) offers consumer credit

through the labels ABN AMRO and Defam. It actively

contributes to a healthy Dutch credit market and is

one of the largest finance companies in the

Netherlands in the field of consumer credit. On

25 November 2025 ABN AMRO announced that it

would sell Alfam to Rabobank. The acquisition is

subject to the approval of the relevant regulators and

the usual advisory processes of ABN AMRO’s

Employee Council and is expected to be completed in

the third quarter of 2026.

• New10 B.V. provides SMEs in the Netherlands with

loans in a highly automated way via a fully digital

product offering.

• On 12 November 2025 it was announced that ABN

AMRO had reached agreement on the acquisition of

NIBC Bank. The transaction is subject to regulatory

approvals and works councils’ consultation processes

within ABN AMRO and NIBC. Completion of the

transaction is expected in the second half of 2026.

Wealth Management

ABN AMRO Wealth Management is present in the

Netherlands, France, Belgium, and Germany.

• In the Netherlands, Wealth Management offers an

extensive range of Wealth Management services

under the brand name ABN AMRO MeesPierson.

• ABN AMRO Bank N.V. Paris Branch, operating under

the brand name Neuflize OBC, has nine branches in

major French cities in addition to its head office in

Paris, and provides an integrated approach to private

and commercial clients with a dedicated advisory and

products offering.

• ABN AMRO Investment Solutions S.A. provides asset

management solutions for ABN AMRO clients and

third parties (including distributors and institutions) in

Europe.

• ABN AMRO Bank N.V. Belgium Branch offers private

banking and private wealth management-related

services in 8 branches across Belgium.

• ABN AMRO Bank N.V. Frankfurt Branch offers private

banking and private wealth management-related

services through its 12 branches, covering all major

regions in Germany, under the Bethmann Bank label.

Its Entrepreneur & Enterprise concept offers

entrepreneurs and their businesses an integrated

approach to banking.

• On 1 July 2025 ABN AMRO announced the

completion of the acquisition of Hauck Aufhäuser

Lampe Privatbank AG, a leading German private bank.

The combined presence with ABN AMRO Bank in

Germany and Luxembourg comprises 2,000

employees across 18 locations in Germany and

Luxembourg.

• BUX B.V. provides digital financial services that make

trading and investing accessible to a broad client base

and a new generation of investors across Europe.

Corporate Banking

ABN AMRO’s Corporate Banking client unit is supported

by the following subsidiaries (this list is not exhaustive):

• ABN AMRO Clearing Bank N.V. (AAC) is a global

leader in derivatives and equity clearing. It is one of

the few players currently offering global market

access and clearing services on more than 85 of the

world’s leading exchanges and operates from several

locations across the globe. Services are provided in

Europe from the head office in Amsterdam, as well as

through its London Branch. AAC operates an IT hub in

Romania. Beyond Europe, services are provided

through wholly owned subsidiaries or branches in the

USA, Australia, Japan, Hong Kong, Singapore and

Brazil.


ABN AMRO	Annual Report 2025	191


≡	Leadership & governance	Other governance information	Codes and regulations

• ABN AMRO Asset Based Finance N.V. provides asset-

based solutions (working capital solutions, equipment

leases, equipment loans and vendor lease services) to

its clients in the Netherlands and Germany.

• The joint venture ABN AMRO – ODDO BHF B.V.

provides equity brokerage services and focuses on

the Benelux region. Both ABN AMRO and ODDO BHF

have an equal share in this strategic partnership.

• ABN AMRO Sustainable Impact Fund VC B.V. invests

in start-up companies and companies focused on the

energy, circular and/or social transition, as part of and

in line with ABN AMRO’s sustainability strategy.

Functions

ABN AMRO’s functions are supported by the following

subsidiaries (this list is not exhaustive):

• ABN AMRO Captive N.V. is a captive reinsurance

company.

• ABN AMRO Funding USA LLC is active in the US

market, issuing ABN AMRO’s US dollar commercial

paper funding for clients operating in the US and for

clients with US dollar loans.


ABN AMRO	Annual Report 2025	192


≡	Leadership & governance	Responsibility statement

Responsibility statement

Pursuant to Section 5:25c sub 2 part c of the Dutch

Financial Supervision Act, the members of the Executive

Board state that to the best of their knowledge:

• The Annual Financial Statements give a true and fair

view of the assets, liabilities, financial position and

profit or loss of ABN AMRO Bank N.V. and the

companies included in its consolidation.

• The Executive Board report gives a true and fair view

of the state of affairs on the balance sheet date and

the course of business during the 2025 financial year

of ABN AMRO Bank N.V. and the affiliated companies

included in its Annual Financial Statements.

• The Executive Board report describes the material

risks faced by ABN AMRO Bank N.V.

Amsterdam, 10 March 2026

Executive Board

M.M.A.S. Bérard, Chief Executive Officer and Chair

D.S. Dorner, Chief Commercial Officer - Corporate Banking and Vice-Chair

C. Bittner , Chief Innovation and Technology Officer

S. Fioravanti, Chief Risk Officer

C.L. van der Hooft - Cheong, Chief Commercial Officer - Wealth Management

F.G. Vaandrager, Chief Financial Officer

A.M. Vreugdenhil, Chief Commercial Officer - Personal & Business Banking


ABN AMRO	Annual Report 2025	193

Sustainability Statement s


Business conduct	267
EU Taxonomy	269
ESG Annex	287


ABN AMRO	Annual Report 2025	194


≡	Sustainability Statements	Basis of preparation

Basis of preparation

General basis of preparation

The Consolidated Sustainability Statements (‘the

Sustainability Statements’) of ABN AMRO Bank N.V. for

the year ended 31 December 2025 incorporate

information of ABN AMRO Bank N.V. and its controlled

entities in scope of the consolidation of the Annual

Financial Statements (as included in Note 1 to the

Annual Financial Statements). During the year 2025, the

bank acquired a new subsidiary, Hauck Aufhäuser

Lampe (HAL). HAL has been included in the

Sustainability Statements where feasible; however, its

client assets portfolio is not reflected due to challenges

in data quality and availability, as disclosed in the

relevant tables.

The Sustainability Statements have been prepared in

accordance with the Corporate Sustainability Reporting

Directive (CSRD) and the European Sustainability

Reporting Standards (ESRS, as adopted by the European

Commission in 2023). The Sustainability Statements

were prepared by the Executive Board and authorised

by the Supervisory Board and Executive Board on

11 March 2026.

The Sustainability Statements reflect the bank’s 2025

strategy and, where relevant, explain how the 2026–

2028 strategy will influence future sustainability

reporting. For more information on the new strategy,

please refer to Our strategy.

ABN AMRO expects that the revision of ESRS due to the

Omnibus proposals as presented in 2025 will also have

an effect on its sustainability reporting going forward,

but only once adopted by the European Commission.

Subsidiaries of ABN AMRO are exempted from company

or consolidated sustainability reporting pursuant to

Articles 19a(9) or 29a(8) of Directive 2013/34/EU and

their sustainability information is incorporated into these

statements. A list of the major subsidiaries and

participating interests of the bank can be found in Other

information.

Double materiality assessment

An important cornerstone of sustainability reporting is

the double materiality assessment (DMA). This

assessment determines the material sustainability

matters that the bank has to disclose. The double

materiality process, reporting criteria and the outcomes

of the DMA are described in the Strategy and business

model section.

Description of the value chain

ABN AMRO is required to identify and report on impacts,

risks and opportunities (IROs) that are caused or

contributed to by the bank or that are linked to its

operations, products or services. There are four parts to

the bank’s value chain: own operations, the upstream

value chain and the downstream value chain, where we

make a distinction between direct clients and the value

chain of our direct clients:

• Own operations impacts refer to direct impacts of

ABN AMRO.

• Upstream value chain impacts refer to indirect

impacts from suppliers of goods, services and capital.

The bank’s main conventional suppliers are

predominantly providers of human resources or IT

services.

• Direct client impacts refer to indirect internal impacts

generated at clients of ABN AMRO.

• Downstream value chain of our direct clients refers to

impacts that originate at suppliers of ABN AMRO’s

clients and customers of ABN AMRO’s clients. The

impacts of ABN AMRO are predominantly an indirect

effect of the activities of actors in the value chain.

Given the role of the bank as a financier of the real

economy, we are linked to the impacts, risks and

opportunities that emerge in the various value chains

of our business relationships in multiple sectors.

The bank relies on its clients and their use of sector-

specific information to accurately and completely

identify the key actors in their value chains.




			Supplier of client

Suppliers of goods and services	ABN AMRO	Corporate client	Client of client	End client

Providers of capital		Consumer client


Suppliers	Own operations	Direct clients	Value chain of clients

Upstream value chain	Own operations	Downstream value chain

For a standard banking institution, most of the impact is typically observed in the downstream segments of the value chain.


ABN AMRO	Annual Report 2025	195


≡	Sustainability Statements	Basis of preparation

Internal controls in sustainability reporting

ABN AMRO has embedded sustainability reporting

within its overall governance and risk management

framework, in line with the Dutch Corporate

Governance Code (Verklaring Omtrent Risicobeheersing)

and CSRD requirements. The process is supported by

robust internal controls and periodic oversight to ensure

transparent and reliable sustainability reporting.

Sustainability reporting risks are managed under the

bank’s data risk management framework. A structured

risk assessment methodology is applied, prioritising key

inherent risks based on their likelihood and impact

before controls are implemented.

The main identified key inherent risks include data

quality, process inefficiencies, regulatory compliance

and third-party dependencies. These are mitigated

through detective and preventive controls, formal sign-

offs, segregation of duties and targeted actions such as

staff training and process automation.

Internal controls are embedded in existing reporting

processes that are overseen by Risk Management, the

Group Disclosure Committee and Finance. Management

provides dedicated sign-offs for both qualitative and

quantitative sustainability information, ensuring

accountability and compliance with regulatory standards.

Disclosures in relation to specific

circumstances

Time horizons

We assess material IROs over the short, medium and

long term. The short term refers to the reporting period

of the Annual Financial Statements. For forward-looking

information on material IROs in the Sustainability

Statements, ABN AMRO defines:

• 1 year as short term

• between 1 and 5 years as medium term

• more than 5 years as long term

Where our time horizons deviate from these general

guiding principles, this is disclosed alongside the

specific material topic.

In preparing these Sustainability Statements,

management has exercised its judgement in applying

sustainability policies and making estimates and

assumptions concerning the future. Actual results may

differ from those estimates and assumptions.

Metrics and estimation uncertainty

In this report we use metrics, especially in the case of

our client portfolios, that are based on certain estimates,

averages or assumptions. The underlying data either

comes directly from clients or is sourced from external

data vendors. We use sector averages if we cannot

reasonably collect information, especially from our

value chain business relationships. For certain metrics,

such as our financed emissions, we combine several

data sources. Generally, the level of accuracy of these

metrics is lower than that of financial metrics, given the

quality of the inputs. The quality typically depends on

whether the data is directly reported by our clients or

based on proxies, the characteristics of that reported

data and whether it has been reviewed by an external

party, whether the data is forward-looking or historical

and whether established measurement frameworks are

available.

We have included this information for each metric with

regard to assumptions, approximations and judgments

either in the respective sections or in the Definitions

section of this report. As indicated in the Definitions

section, all quantitative metrics relating to information

on our value chain currently have a high measurement

uncertainty, as sustainability reporting is a developing

field for most actors in our value chain and we depend

on these actors for accurate information.

Comparability of sustainability information between

entities and over time may be affected by the lack of

historical sustainability information in accordance with

ESRS and by the absence of uniform practices for

evaluating and measuring this information. This allows

for the application of different, but acceptable,

measurement techniques, especially in the initial years.

Overview of disclosure requirements covered

in the Sustainability Statements

The table below shows the disclosure requirements

that are included in these Sustainability Statements.

This table should be read in conjunction with the

Incorporation by reference section, which shows the

disclosure requirements covered in other parts of the

Annual Report.

Some other elements have been included in these

Sustainability Statements, based on sustainability rating

agencies’ requirements, requests by stakeholders or

commitments of the bank. This information is included

in the ESG annex and marked with a box stating ‘Non-

material from DMA’. ABN AMRO also issues a Pillar 3

Report, which includes ESG information based on the

Capital Requirements Regulation. We do not issue any

other sustainability reports simultaneously with this

Annual Report.


ABN AMRO	Annual Report 2025	196


≡	Sustainability Statements	Basis of preparation

Overview table with disclosure requirements


Chapter	ESRS	Paragraphs included in Sustainability Statements	Transitional provisions applied
Basis of preparation	ESRS 2	5(a), 5(b)i, 5(b)ii, 5(b), 5(c), 9(a), 9(b), 10(c), 10(d), 12, 15, 16, 36(a), 36(b), 36(c), 36(d), 36(e), 40(d)i, 40(d)ii, 40(d)iii, 40(d)iv, 42(c), 54, 56	n/a
Strategy and business model	ESRS 2	17(a), 17, 26(c), 40(a), 40(e), 40(f), 40(g), 45(a)i, 45(a)ii, 45(a)iii, 45(a)iv, 45(a)v, 45(a), 45(b), 45(c)i, 45(c)ii, 45(c)iii, 45(c), 45(d), 48(a), 48(b), 48(c)i, 48(c)ii, 48(c)iii, 48(c)iv, 48(d), 48(e), 48(f), 48(g), 48(h), 53(a), 53(b)i, 53(b)ii, 53(b)iii, 53(b)iv, 53(b), 53(c)i, 53(c)ii, 53(c), 53(d), 53(e), 53(f), 53(g), 53(h), 58, 59	n/a
	ESRS E1	18, 19(a), 19(b), 19(c), 20(a), 20(b), 20(c), 21
	ESRS G1	6
Governance of sustainability matters	ESRS 2	22(a), 22(b), 22(c)i, 22(c)ii, 22(c)iii, 22(c), 22(d), 23(a), 23(b), 23, 26(a), 26(b), 26(c)	n/a
Governance of sustainability matters	ESRS G1	5(b)	n/a
Risk management of sustainability matters	ESRS 2	30, 32, 36(a), 36(b), 36(c), 45(a), 53(c)iii, 53(e), 65(a), 65(b), 65(c), 65(d), 65(e), 65(f)	n/a
Risk management of sustainability matters	ESRS E1	18, 24, 25(a), 25(b), 25(c)	n/a
Climate ¹	ESRS 2	65(a), 65(b), 65(c), 68(a), 68(b), 68(c), 68(e), 75, 77(a), 77(b), 80(a), 80(b), 80(c), 80(d), 80(e), 80(f), 80(g), 80(h), 80(i), 80(j), 81(b)i, 81(b)ii	n/a
Climate ¹	ESRS E1	14, 16(a), 16(b), 16(h), 16(i), 16(j), 28, 29(a), 32, 33, 34(a), 34(b), 34(c), 34(e), 34(f), 44(c), 51, 66(a), 66(c), 67(a), 67(c)	34(a), 66, 67, 68, 69
Biodiversity	ESRS 2	17(b), 17(c), 17(d), 17(e)	Topic is in scope of transitional provisions
Own workforce	ESRS 2	40(a)iii, 68(a), 68(b), 68(c), 68(d), 68(e), 80(a), 80(b), 80(c), 80(d), 80(e), 80(f), 80(g), 80(h), 80(i), 80(j)
Own workforce	ESRS S1	14(a), 14(c), 14, 15, 19, 20(a), 20(b), 20(c), 21, 24(a), 24(b), 24(c), 24(d), 27(a), 27(b), 27(c), 27(d), 27(e), 27, 28, 29, 32(a), 32(b), 32(c), 32(d), 32(e), 33, 37, 38(a), 38(b), 38(c), 38(d), 39, 41, 43, 46, 47(a), 47(b), 47(c), 50(a), 50(b)i, 50(b)ii, 50(b)iii, 50(b), 50(c), 50(d)i, 50(d)ii, 50(d), 50(e), 50(f), 60(a), 60(b), 63(a), 63(b), 66(a), 66(b), 74(a), 74(b), 74(c), 74(d), 74(e), 79, 83(a), 83(b), 93(a), 94, 97(a), 97(b), 97(c), 103(a), 103(b), 103(c), 103(d), 104(a), 104(b)	55, 56, 57, 60(c), 83(b), 93(b)
Consumers and end- users	ESRS 2	17(b), 17(c), 17(d)	Topic is in scope of transitional provisions
Business conduct	ESRS 2	65(a), 65(b), 65(c), 65(d), 65(e), 65(f), 68(a), 68(b), 68(c), 68(d), 68(e), 75, 77(a), 77(b), 81(b)i, 81(b)ii, 81(b)	n/a
Business conduct	ESRS G1	5(a)	n/a
EU Taxonomy	n/a	n/a	n/a
ESG Annex	n/a	n/a	n/a
1. ABN AMRO discloses climate-related risk metrics, which partially address E1-9 paragraph 66 and 67. This pertains to physical risk metrics and transition risk metrics (please refer to ABN AMRO's climate risk section).

Transitional provisions

ABN AMRO makes use of the phase-in provisions and

the transitional provision for value chain information.

We use the provisions for metrics and targets on

material matters that relate to our client portfolios, such

as climate change and biodiversity, as we were unable

to obtain all relevant and reliable information or

generally accepted standards on how to measure

impacts, and industry or scientific benchmarks were not

available. In addition to these provisions, the European

Commission has extended the phase-in requirements

applicable to biodiversity and consumers & end-users to

the bank as part of the targeted 'quick fix’ amendments

to the first set of ESRS, adopted in July 2025.

ABN AMRO makes use of these amendments to make

the disclosures regarding these topics more targeted

and relevant to the material IROs we face in these areas.

ABN AMRO continues to implement the transitional

requirements and aims to adopt concrete planning

once uncertainties raised by the Omnibus proposals and

transposition of the CSRD into Dutch legislation have

become more clear.

Incorporation by reference

Some disclosures are not included in the Sustainability

Statements but in other relevant sections of this Annual

Report, as they are closely linked to other reporting

requirements ABN AMRO is subject to. These sections

have been labelled with an ESRS label in the respective

chapters. The table below provides an overview of

where we disclose this information. With regard to risk

management, we have defined ESG risk as a driver of

traditional risk types. The Risk management of ESG

matters section describes how we define and manage

ESG risk. More details on the methodologies and

management used for the traditional risk types, such as

credit risk, market risk, operational risk and liquidity risk,

are provided in the Climate risk section.


ABN AMRO	Annual Report 2025	197


≡	Sustainability Statements	Basis of preparation


Description	ESRS section	ESRS Disclosure Requirement	Incorporated by reference in section
Strategy, business model and value chain	ESRS 2 SBM-1	40(a)i, 40(a)ii	Our bank - Our business model
Strategy, business model and value chain	ESRS 2 SBM-1	42(a), 42(b)	Strategy & performance - Who are our stakeholders?
Interests and views of stakeholders	ESRS 2 SBM-2	45(a)i-v	Strategy & performance - Who are our stakeholders?
The role of administrative, management and supervisory bodies	ESRS 2 GOV-1	21(a), 21(d), 21(e)	Leadership & governance - Executive board composition - Composition and diversity / Diversity Executive board
		21(c)	Leadership & governance - Executive board composition - Relevant experience
		21(b)	Leadership & governance - Supervisory board composition - Employee representation
		21(a), 21(c), 21(d), 21(e)	Leadership & governance - Supervisory board composition - Composition and diversity
Integration of sustainability-related performance in incentive schemes	ESRS 2 GOV-3	29(a), 29(e)	Leadership & governance - Remuneration report - 2025 Performance of the Executive Board
	ESRS 2 GOV-3	29(b), 29(c), 29(d)	Leadership & governance - Remuneration report - KPI setting and performance
	ESRS E1, GOV-3	13
Disclosures in relation to specific circumstances	ESRS 2 BP-2	10(a), 10(b), 11	Definitions
Metrics in relation to material sustainability matters	ESRS 2 MDR-M	75, 77
Tracking effectiveness of policies and actions through targets	ESRS 2 MDR-T	80(c)

Data points in Sustainability Statements derived from other EU regulation

Overview of data points included in Sustainability Statements derived from other EU regulation


Disclosure requirement and related datapoint	ESRS and paragraph number	Materiality for ABN AMRO	Reference
Board's gender diversity	ESRS 2 GOV-1, paragraph 21 (d)	Material	Not included in Sustainability Statements, incorporated by reference in Leadership & Governance
Percentage of board members who are independent	ESRS 2 GOV-1, paragraph 21 (e)	Material	Not included in Sustainability Statements, incorporated by reference in Leadership & Governance
Statement on due diligence	ESRS 2 GOV-4, paragraph 30	Material	ESG risk management framework
Involvement in activities related to fossil fuel activities	ESRS 2 SBM-1, paragraph 40 (d) i	Not applicable	Not included
Involvement in activities related to chemical production	ESRS 2 SBM-1, paragraph 40 (d) ii	Not applicable	Not included
Involvement in activities related to controversial weapons	ESRS 2 SBM-1, paragraph 40 (d) iii	Not applicable	Not included
Involvement in activities related to cultivation and production of tobacco	ESRS 2 SBM-1, paragraph 40 (d) iv	Not applicable	Not included
Transition plan to reach climate neutrality by 2050	ESRS E1-1, paragraph 14	Material	Our climate strategy
Undertakings excluded from Paris-aligned Benchmarks	ESRS E1-1, paragraph 16 (g)	Not applicable	Not included
GHG emission reduction targets	ESRS E1-4, paragraph 34	Material	Our climate strategy - Overview per sector
Energy consumption from fossil sources disaggregated by sources (only high climate impact sectors)	ESRS E1-5, paragraph 38	Not applicable	Not included
Energy consumption and mix	ESRS E1-5, paragraph 37 ¹	Not material	ESG annex - Energy consumption and mix
Energy intensity associated with activities in high climate impact sectors	ESRS E1-5, paragraphs 40 to 43	Not applicable	Not included
Gross Scope 1, 2, 3 and Total GHG emissions	ESRS E1-6, paragraph 44 ²	Material	GHG monitoring
Gross GHG emissions intensity	ESRS E1-6, paragraphs 53 to 55	Not material	Not included
GHG removals and carbon credits	ESRS E1-7, paragraph 56 ³	Not material	ESG annex - GHG emissions - own operations
Exposure of the benchmark portfolio to climate-related physical risks	ESRS E1-9, paragraph 66	Material	Climate change heatmap for corporate loans, Sensitivity to physical climate risk, Climate scenario analyses


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≡	Sustainability Statements	Basis of preparation


Disclosure requirement and related datapoint	ESRS and paragraph number	Materiality for ABN AMRO	Reference
Disaggregation of monetary amounts by acute and chronic physical risk Location of significant assets at material physical risk	ESRS E1-9, paragraph 66 (a) and (c)	Material	Sensitivity to physical risk, Climate scenario analyses
Breakdown of the carrying value of its real estate assets by energy-efficiency classes	ESRS E1-9, paragraph 67 (c)	Material	Breakdown of commercial real estate portfolio by energy label, Breakdown of residential mortgage portfolio by energy label
Degree of exposure of the portfolio to climate- related opportunities	ESRS E1-9, paragraph 69	Not material	Topic is in scope of transitional provisions
Amount of each pollutant listed in Annex II of the E-PRTR Regulation (European Pollutant Release and Transfer Register) emitted to air, water and soil	ESRS E2-4, paragraph 28	Not material	Not included
Water and marine resources	ESRS E3-1, paragraph 9	Not material	Not included
Dedicated policy	ESRS E3-1, paragraph 13	Not material	Not included
Sustainable oceans and seas	ESRS E3-1, paragraph 14	Not material	Not included
Total water recycled and reused	ESRS E3-4, paragraph 28 (c)	Not material	Not included
Total water consumption in m ³ per net revenue on own operations	ESRS E3-4, paragraph 29	Not material	Not included
Disclosure of activities negatively affecting biodiversity sensitive areas	ESRS 2 SBM-3 - E4 paragraph 16 (a) i	Not applicable	Topic is in scope of transitional provisions
Material negative impacts with regards to land degradation, desertification or soil sealing have been identified	ESRS 2 SBM-3 - E4 paragraph 16 (b)	Not applicable	Topic is in scope of transitional provisions
Own operations affect threatened species	ESRS 2 SBM-3 - E4 paragraph 16 (c)	Not applicable	Topic is in scope of transitional provisions
Sustainable land / agriculture practices or policies	ESRS E4-2, paragraph 24 (b)	Not applicable	Topic is in scope of transitional provisions
Sustainable oceans / seas practices or policies	ESRS E4-2, paragraph 24 (c)	Not applicable	Topic is in scope of transitional provisions
Policies to address deforestation	ESRS E4-2, paragraph 24 (d)	Not applicable	Topic is in scope of transitional provisions
Non-recycled waste	ESRS E5-5, paragraph 37 (d)	Not material	Not included
Hazardous waste and radioactive waste	ESRS E5-5, paragraph 39	Not material	Not included
Risk of incidents of forced labour	ESRS 2 SBM-3 - S1, paragraph 14 (f)	Not material	Not included
Risk of incidents of child labour	ESRS 2 SBM-3 - S1, paragraph 14 (g)	Not material	Not included
Human rights policy commitments	ESRS S1-1, paragraph 20	Material	Social - introduction
Due diligence policies on issues addressed by the fundamental International Labour Organization Conventions 1 to 8	ESRS S1-1, paragraph 21	Material	Policies related to own workforce
Processes and measures for preventing trafficking in human beings	ESRS S1-1, paragraph 22	Not material	Not included
Workplace accident prevention policy or management system	ESRS S1-1, paragraph 23	Not material	Not included
Grievance/complaints handling mechanisms	ESRS S1-3, paragraph 32 (c)	Material	Processes to remediate negative impacts and channels for own workforce to raise concerns
Number of fatalities and number and rate of work-related accidents	ESRS S1-14, paragraph 88 (b) and (c)	Not material	Not included
Number of days lost to injuries, accidents, fatalities or illness	ESRS S1-14, paragraph 88 (e)	Not material	Not included
Unadjusted gender pay gap	ESRS S1-16, paragraph 97 (a)	Material	Our employees at a glance - Pay gap and total remuneration
Excessive CEO pay ratio	ESRS S1-16, paragraph 97 (b)	Material	Our employees at a glance - Pay gap and total remuneration
Incidents of discrimination	ESRS S1-17, paragraph 103 (a)	Material	Our employees at a glance - Incidents, complaints and severe human rights impacts
Non-respect of UNGPs on Business and Human Rights and OECD	ESRS S1-17, paragraph 104 (a)	Material	Our employees at a glance - Incidents, complaints and severe human rights impacts
Significant risk of child labour or forced labour in the value chain	ESRS 2 SBM-3 – S2, paragraph 11 (b)	Not material	Not included
Human rights policy commitments	ESRS S2-1, paragraph 17	Not material	Not included
Policies related to value chain workers	ESRS S2-1, paragraph 18	Not material	Not included
Non-respect of UNGPs on Business and Human Rights principles and OECD guidelines	ESRS S2-1, paragraph 19	Not material	Not included
Due diligence policies on issues addressed by the fundamental International Labour Organization Conventions 1 to 8	ESRS S2-1, paragraph 19	Not material	Not included


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≡	Sustainability Statements	Basis of preparation


Disclosure requirement and related datapoint	ESRS and paragraph number	Materiality for ABN AMRO	Reference
Human rights issues and incidents connected to its upstream and downstream value chain	ESRS S2-4, paragraph 36	Not material	Not included
Human rights policy commitments	ESRS S3-1, paragraph 16	Not material	Not included
Non-respect of UNGPs on Business and Human Rights, ILO principles or and OECD guidelines	ESRS S3-1, paragraph 17	Not material	Not included
Human rights issues and incidents	ESRS S3-4, paragraph 36	Not material	Not included
Policies related to consumers and end-users	ESRS S4-1, paragraph 16	Not applicable	Topic is in scope of transitional provisions
Non-respect of UNGPs on Business and Human Rights and OECD guidelines	ESRS S4-1, paragraph 17	Not applicable	Topic is in scope of transitional provisions
Human rights issues and incidents	ESRS S4-4, paragraph 35	Not applicable	Topic is in scope of transitional provisions
United Nations Convention against Corruption	ESRS G1-1, paragraph 10 (b)	Not material	Not included
Protection of whistleblowers paragraph	ESRS G1-1, paragraph 10 (d)	Not material	Not included
Fines for violation of anti-corruption and anti- bribery laws	ESRS G1-4, paragraph 24 (a)	Not material	Not included
Standards of anti-corruption and anti-bribery	ESRS G1-4, paragraph 24 (b)	Not material	Not included
1. Although not material, certain E1-5, paragraph 37 data points will be disclosed to ensure coherence with previous reports and to provide the information to meet criteria for an ESG rating. Hence, this is included in the ESG Annex.
2. Only scope 3 category 15 emissions have been deemed material and are therefore included in the GHG monitoring section. Other emission scopes are included in the ESG Annex.
3. Although not material, the bank is disclosing certain information related to carbon credits in the ESG Annex to ensure consistency with previous reports and for external commitment purposes.


ABN AMRO	Annual Report 2025	200


≡	Sustainability Statements	Strategy and business model

Strategy and business model

This section explains the relationship between our strategy and our business

model, including an explanation of our focus.

Sustainability in relation to our strategy and

business model

This section of the Sustainability Statements explains

how ABN AMRO’s strategy and business model relate

to sustainability. It highlights how sustainability is

incorporated into the bank’s positioning. This section

clarifies what parts of ABN AMRO’s business model

drive our sustainability efforts, and indicates what assets

are not the primary focus of these Sustainability

Statements. The following figure shows what products

and balance sheet items relate to, or have impact on,

sustainability matters.

Linking our business model to sustainability matters

ABN AMRO

100%

Total assets

Off balance

63%

Loans and advances

12%

Financial

investments

25%

Other assets

62%

Residential

mortgages

33%

Corporate

loans

Consumer

loans

Other

Sustainability matters

Relates to or affects sustainability matters

Partly relates to or affects sustainability matters

Does not relate to sustainability matters

The main ESG-related impact in our value chain is the

downstream impact associated with the clients we

finance, primarily through our lending portfolios — such

as mortgages and corporate loans — which are central

to the Sustainability Statements. The relevance of

consumer loans depends on their use of proceeds,

when known, in line with the principles of the EU

Taxonomy Regulation. Examples include real estate

loans, building renovation loans and motor vehicle

loans. While our non-lending activities may have a

significant ESG impact, best practices for reporting on

them are still evolving. What influence ABN AMRO has

on client assets (investments managed or facilitated for

clients) varies depending on the service provided:

Discretionary Portfolio Management, Advisory or

Execution-only. In line with past years, we have

disclosed information about our client assets portfolio

with regard to climate change mitigation. Impacts also

occur through the products and services that we offer

and through the strategic choices that are made

regarding privacy, access to our products and services

and other matters. This is described in more detail in the

Social section.


ABN AMRO	Annual Report 2025	201


≡	Sustainability Statements	Strategy and business model

Sustainability as part of our strategy

In 2025, sustainability was one of the three pillars of our

strategy. We aim to be our clients’ first-choice partner

and provide distinctive expertise in supporting their

sustainability transition. Our efforts were focused on

three main areas: climate, nature and social impact.

We measured our progress through various metrics, for

example our Sustainability Acceleration Standard asset

volume (SAS).

The strategy update that we announced in November

2025 delivers a more focused approach to

sustainability. The 2025 DMA outcome served as input

for the strategy update. For a detailed description of

how sustainability is integrated into our overall strategy,

see the Strategy & performance chapter.

Under the new strategic plan, we have made

sustainability a key enabler of our business, with a focus

on decarbonisation. We aim to help clients achieve their

emission targets via new commercial initiatives, such as

benefits for home energy efficiency upgrades. We plan

to develop a Transition Finance Framework to classify

and enable financing for activities that credibly cut

emissions in line with climate pathways, alongside

already sustainable initiatives aligned with regulatory

definitions. As described in the Strategy & performance

chapter, any emissions pathway must be both credible

and achievable to support an orderly and sustainable

transition towards net-zero emissions.

Although we focus on decarbonisation, we aim to

address other sustainability issues that matter to our

clients or society. For example, improving energy

efficiency in homes in lower-income neighbourhoods

not only helps reduce emissions but can also create a

positive social impact. Nature-related issues, such as

cutting nitrogen emissions and boosting biodiversity,

are important for our agricultural and other clients. We

recognise the complex transitions clients are facing and

seek to help them navigate these when they need

financing.

We track our sustainable finance volumes via our

SAS KPI. The SAS is based on a comprehensive

framework developed to measure our Sustainability

(acceleration) assets in order to assess our performance

on a bank-wide and on a client-unit level. Although SAS

includes topics defined as material in our DMA

assessment, it was not developed to measure the

progress of our material topics and should not be

considered a metric under ESRS. Rather, we utilise SAS

to help drive financing to clients, supporting their

sustainability ambitions.

Our SAS volume is made up of Taxonomy-aligned loan

volumes and Acceleration-aligned loan volumes, the

latter containing a measurable sustainability

component. We also measure and report on our Green

Asset Ratio as per the EU Taxonomy. Increases in SAS

can contribute to emission reductions in our portfolio,

which in turn show up as progress towards our climate

targets. However, there is not always a link between

SAS and our climate strategy, as SAS includes inputs

that are not just climate-related, or the achievement of

emission reductions may occur later in the lifetime of

the financed asset.

DMA methodology

To determine what sustainability topics are material

and form the basis of the Sustainability Statements,

ABN AMRO applies the double materiality principle.

Double materiality includes the impact ABN AMRO has

on society and the environment (impact materiality) and

the financial impact of sustainability matters on

ABN AMRO (financial materiality).

General approach and setup

To assess the topics of environment, social and business

conduct, ABN AMRO established a project team,

drawing on expertise from various functions within the

bank. We assessed the impacts of our own operations

and upstream activities as well as those of our

downstream operations, where the majority of our

impacts are concentrated. We applied thresholds

consistent with those used in IFRS, ensuring that our

financial materiality thresholds remained unchanged

across materiality assessments.

Towards the end of the assessment process, our

conclusions were reviewed and approved by the

Executive Board and the Supervisory Board, after which

we compiled a finalised list of material subtopics.

See the Governance of sustainability matters section for

more details on sustainability governance.

¹ The requirement to conduct consultations with affected communities in determining material IROs was addressed by including proxies (NGOs) as part

of the stakeholder engagement process.

² To determine what topics are potentially material from an impact perspective (including climate, pollution, water and marine, biodiversity-related and

other impacts) for our downstream operations, we looked at external data that identified potential impacts based on sector averages and geographic

locations, mapped against our sector exposure. Where no mapping was possible with the external data provided, expert judgement was applied.

Given that our assessment is based on proxies and estimates, no specific screening of site locations was performed in our downstream value chain.

Given the nature of our own operations (offices) and main suppliers (mostly IT and consultancy), we did not perform specific site location screening in

those parts of the value chain either.


ABN AMRO	Annual Report 2025	202


≡	Sustainability Statements	Strategy and business model

Determining impact materiality

Our impact materiality assessment followed a

structured multi-step process:

1. Understand the organisational context

2. Identify and engage with stakeholders

3. Classify actual and potential impacts

4. Assess these impacts based on scale, scope,

irremediability and likelihood

5. Apply thresholds to determine material topics

The assessment began with building upon the

knowledge of the organisational context from prior

years to update the list of topics to be assessed,

including the sub-topics outlined in Appendix A of

ESRS 1. Where necessary, these sub-topics were

tailored to better reflect terminology more commonly

used within ABN AMRO and the broader financial

sector. We used the stakeholder engagement results 1

from 2024 and analysed recent stakeholder group

input, which reconfirmed the prior-year survey

outcomes. Below, an overview is presented of the

stakeholders included in the assessment, the used

sources for input and the main topics that were listed

as important.

The aim of the DMA is to identify and report on the

material impacts, risks and opportunities the bank faces.

Hence the Sustainability Statements do not cover every

impact, risk and opportunity of the bank that individual

stakeholders may deem important.

To classify (step 3) and assess (step 4) impact

materiality, ABN AMRO integrates available quantitative

data wherever possible. Given that most of our impacts

are linked to downstream financing of the real economy

– predominantly residential mortgages and corporate

loans – that was where we focused the assessment. This

includes average sector-specific impact data from

external parties 2 and the environmental and social risk

heatmaps, which help us detect potential impacts and

risks based on our portfolio composition. See the Risk

management of ESG matters - Risk identification and

materiality section for more information on the

heatmaps. This data considers a broad value chain

perspective, aiming to quantify both ABN AMRO’s direct

impacts and those connected to our clients’ value

chains. Due to the reliance on statistical industry

averages and data modelling, these estimates carry a

degree of uncertainty. However, they serve as an

important starting point for identifying potential

negative impacts. Synthesising all inputs, the analysis

applies expert judgment in evaluating factors such as

scale, scope, likelihood and irremediability, as outlined

by ESRS. Severity was determined by assessing the

scale, scope and irremediability on a scale from 1 to 5.

For negative impacts, actual impacts were assessed by

their severity, while potential impacts considered both

severity and likelihood. Positive impacts were evaluated

by their scale and scope, with potential impacts also

factoring in likelihood.


Stakeholder group	Clients	Employees	Investors	Society
Description of stakeholder group	Consumers, small and medium-sized enterprises, large companies and non- profit organisations	All employees world-wide with a fixed contract (including contractors & agency staff in the Netherlands)	Shareholders and bondholders	Suppliers and other business partners, local communities, government authorities, regulators and NGOs
Stakeholder input sources	Analyse call centre transcripts, analyse meeting summaries, analyse website search queries, analyse page visits of thematic pages (e.g. page on biodiversity)	Discuss with employee works councils (NL, GER, FR). Reuse outcomes of DMA survey 2024	Dialogue with investor relations to identify frequently discussed topics, Investor Letters (Eumedion, Black Rock)	NGOs: list of key topics from previous year made by NGO stakeholder owner. Suppliers: Receive input via dialogue with procurement. Local communities via AAB Foundation, leveraging their website. ECB: via website, priorities are checked. Future generations: via a dialogue with a Future Generations Board representative.
Main topics listed as important	Anti-money laundering, privacy of client data	Suitability of products and services, Privacy of client data, Child labour and forced labour, working conditions, anti-money laundering	Climate, social inclusion, suitability of products and services	Climate change mitigation, biodiversity, diversity & inclusion, social inclusion, affected communities


ABN AMRO	Annual Report 2025	203


≡	Sustainability Statements	Strategy and business model

Scoring: For actual impacts, the severity score determines

materiality. For potential impacts, severity and likelihood

together determine materiality. ESRS prescribes that for

potential negative human rights impact the severity of the

impact takes precedence over its likelihood. For adverse

human rights impact, severity is weighted 3:1 against

likelihood. For all other impacts, severity is weighted 1:1

against likelihood. When calculating the final score, topics

are deemed material if they score 3.5–5, and not material

if they score lower than 3.5.

Changes in methodology

Based on market developments, past experience and

growing internal expertise, in 2025 the impact

assessment methodology was updated. This included

a shift from applying a 3-step scale to a 5-step scale to

determine the score for impact materiality, and the

inclusion of top-down input from the Executive Board.

Based on the top-down input, we further specified the

material matters by demarcating the sectors and

determining impacts for the identified material matters

in our downstream value chain. This shifts the focus

towards the topics that the bank can influence.

Determining financial materiality of risks

We assessed financial materiality by combining two

factors: (1) likelihood of occurrence and (2) potential

magnitude of financial effects over the short, medium,

and long term. Our approach followed EBA guidelines

on managing ESG risks, and covered all ESRS topics.

Scope

The starting point was ABN AMRO’s balance sheet. Risks

across the entire value chain — suppliers, own

operations and clients — were considered if a clear link

to financial impact (i.e. transmission channel) could be

identified. Based on our environmental and social

heatmaps, asset classes with low risk sensitivity were

excluded from the scope.

Methodologies, assumptions and scoring

We assessed the ESG risk drivers for each type of risk —

credit, business, liquidity, market and non-financial

(including all its sub-risks).

The transition risks in our lending book (downstream)

were considered based on cost of risk mitigation for our

clients. Our analysis estimated the risk of both physical

damage and productivity loss on our clients’ financial

strength. For simplicity, we assumed identical ESG risks

within and outside the Netherlands.

The physical risks (downstream and own operations)

were assessed based on scientific data for the

Netherlands and the change to the collateral value

(real estate; see the Climate scenario analysis section).

The time horizon of the physical risk assessment was

until 2050, considering the contractual duration of the

residential real estate financing (30 years). For assessing

non-financial ESG risks (own operations and

downstream), we applied a scenario and stress testing

methodology that combined the climate scenarios

described below with expert judgement.

The financial materiality assessment results for climate

risk are disclosed under Effect of Climate Risk on

traditional risk types. For disclosures on client integrity

as a material financial risk, refer to the Business

Conduct section.

Changes in methodology

In 2025, we aligned the scoring methodologies of the

financial materiality assessment and risk taxonomy.

Accordingly, the potential magnitude of risks is

assessed against a four-point scale: Critical, High,

Medium and Low. See Risk management framework for

more about the bank’s risk taxonomy.

Scenarios

Our financial materiality assessment was performed

against the following ESG scenarios:

• Climate-related transition risks in the lending portfolio

were assessed against our internal base case, which

differs from the Paris Agreement in considering a

limited overshoot scenario that assumes the

Netherlands and the EU will adopt GHG reduction

plans to incentivise investment spending and

disincentivise fossil fuel consumption. Still, EU GHG

emissions are falling by less than the current EU

targets. This is due to various reasons, including the

lack of political commitment, higher financing cost,

capacity and credit constraints, scarcity of materials,

shortage of personnel and insufficient speed of

technological progress. Macroeconomic forecasts

related to this scenario ran until 2030, and were also

used for calculating loan impairment allowances in

our financial statements (see the Macroeconomic

scenarios in the Credit risk review section).

• Climate-related physical risks were assessed against a

high emission scenario (Representative Concentration

Pathway (RCP) 8.5 scenario), where no additional

efforts are made to constrain greenhouse gas

emissions. This results in a temperature increase of

4.3°C by 2100. This scenario is relevant for our

residential and commercial real estate portfolios.

• Finally, several operational risk scenarios were

performed, assessing financial risks from data centre

failure, greenwashing perception and shortcomings

relating to privacy of client data and duty of care

concerning residential mortgages.


ABN AMRO	Annual Report 2025	204


≡	Sustainability Statements	Strategy and business model

Determining financial materiality of

opportunities

To assess opportunities, we evaluated the sustainability

related business cases within the strategic planning

which exceed the same financial thresholds as the risk

assessment on our P&L and whether this is expected to

take place within 5 years. Only climate opportunities

were identified as exceeding the threshold.

Connections of impacts with risks and

opportunities

Our heatmaps assess sensitivity to physical and

transition risks. Negative impact is one of the inputs for

assessing sensitivity to market, technology and policy

risks. In addition, negative impact itself is used as a

driver of transition risks if it is associated with

reputational risk in a sector we have exposure to.

Impacts relating to workers in the value chain and end-

users and consumers are mostly linked to non-financial

risks in the DMA process and assessed from that

perspective. Impacts may also lead to the identification

of an opportunity, which is then taken up in the regular

commercial process.

Changes in material topics

In 2025, fewer topics were assessed to be material than

in 2024, due to changes in methodology and the

incorporation of top-down input from the Executive

Board as described in the section Changes in

methodology. Based on the 2025 assessment, the

following matters are no longer assessed material from

an impact perspective: Pollution (air and water),

Resource use & circular economy, Workers in the value

chain (working conditions and child labour and forced

labour) and Consumers and end-users (social inclusion).

The following matters are no longer assessed as

material from a risk perspective: Pollution and

Consumers and end-users (suitability of products &

services and privacy of client data). For a detailed

overview of material matters in 2024, consult our

Integrated Annual Report 2024, in the chapter

Sustainability Statements.

Determination of material information per

material matter

As a starting point for determining what information is

material to include in our disclosures, we first linked the

ESRS Disclosure Requirements (DRs) to the matters that

we identified as material in our DMA. In most cases, we

deemed a combination of the minimum disclosure

requirements of ESRS 2 and a sub-set of the

requirements in the topical ESRS as connected to our

material matters. For the material matter ‘Client

Integrity’ (which is entity-specific), we used the

minimum disclosure requirements of ESRS 2,

supplemented by information from our previous

disclosures and reporting frameworks. However, if we

determined that the specific information did not

significantly depict or explain the matter to meet users'

decision-making needs, we do not include it. Similarly, if

an ESRS metric was deemed not material at the data

point level and was unnecessary for fulfilling the

objectives of the DRs, we excluded it. Throughout this

process, we did not make use of any thresholds.


ABN AMRO	Annual Report 2025	205


≡	Sustainability Statements	Strategy and business model

Overview of material matters per ESRS

Material topics

Type

Linked to portfolio & industries

Topic

Subtopic

ABN AMRO

label

Definition

Type of

materiality

Value chain

identification

Personal

loans &

mortgages

Corporate

loans¹

Client assets¹

Climate

change

Climate

change

mitigation

Climate

change

mitigation

The process of limiting the increase

in the global average temperature

through minimising the negative and

maximising the positive impact

caused by the activities of our clients

Negative

impact

Downstream

Impact: GHG

emissions

Residential

mortgages

Agriculture,

mining &

quarrying (oil &

gas), electricity

(production),

transport

(shipping & road

transport),

commercial real

estate, and

others

Energy,

manufacturing,

transportation,

mining and

quarrying,

utilities

Climate

transition

risk

Risks that arise from the transition to

a low-carbon and climate-resilient

economy

Financial risk

Downstream &

own

operations

Agriculture,

mining &

quarrying (oil &

gas),

manufacturing,

electricity

production,

transport, and

others

Climate

physical risk

Risks resulting from climate change

that can be event-driven (acute) or

from longer-term shifts (chronic) in

climate patterns

Financial risk

Downstream &

own

operations

Residential

mortgages

Climate

change

mitigation

Climate

change

mitigation

The process of limiting the increase

in the global average temperature

through minimising the negative and

maximising the positive impact

caused by the activities of our clients

Financial

opportunity

Downstream

Sustainable

impact fund,

renewable

energy and

decarbonisation

technologies

Biodiversity

and

ecosystems

Direct impact

drivers of

biodiversity

loss

Biodiversity

Biodiversity loss caused by climate

change, land-use change, fresh

water-use change and sea-use

change, indirect exploitation and

invasive species, caused by the

activities of our clients

Negative

impact

Downstream

Impact:

Nitrogen

emissions

Agriculture

(dairy farming),

transportation &

storage (deep-

sea shipping)

Own

workforce

Equal

treatment

and

opportunities

Diversity,

equity &

inclusion

Equal treatment and equal

opportunity of workers, prevention

of harassment, ensuring non-

discrimination within ABN AMRO

Negative &

positive

impact

Own

operations

Not linked to a particular portfolio, sector or

product

Consumers

and end-

users

Personal

safety

Suitability of

products &

services

Development of suitable products

and services that adequately meet

the needs, characteristics and

situation of the bank’s intended

clients/target groups, as well as

adequately acting in the best

interest of clients to protect them

from foreseeable harm in line with

client centricity principles

Negative

impact

Own

operations

Not linked to a particular portfolio, sector or

product

Information-

impacts

Privacy of

client data

The protection of our clients' data

through ABN AMRO’s banking

systems and policies

Negative

impact

Own

operations &

upstream

Not linked to a particular portfolio, sector or

product

Business

conduct

Entity-

specific topic

Client

Integrity

Client Integrity encompasses the

practices that ABN AMRO

implements in its interactions with

clients. Within the bank, it includes

the following domains: Anti-Money

Laundering, Anti-Bribery and

Corruption, Combating the

Financing of Terrorism, Tax, Fraud

and Sanctions

Financial risk

Downstream

Not linked to a particular portfolio, sector or

product

1. The list of sectors depicted is non-exhaustive.


ABN AMRO	Annual Report 2025	206


≡	Sustainability Statements	Strategy and business model

Current and anticipated effects of material

matters

Effect on strategy and business model

We assessed the resilience of our business model to

material matters in 2025, considering:

• Material impacts, risks and opportunities as identified

by the 2025 DMA and the updated risk taxonomy (for

more information on risk taxonomy, see the Risk,

Funding & Capital chapter, under Risk management

framework)

• The bank’s 5-year forward-looking financial plan

• Current and anticipated financial effects of the

sustainability matters on our bank as at

31 December 2025

• Current capital position and projections for the next

5 years

• A 5-year forward-looking adverse scenario, in which

carbon emission prices increase suddenly due to a

large physical risk event or abrupt tightening of

climate policies. The time horizon of this scenario is

aligned with our interim 2030 climate strategy targets

• Results of the ICAAP stress testing analysis, and

• Results of a 25-year forward-looking climate

resilience scenario analysis, considering various long-

term scenarios and the potential effect on portfolio

size. The time horizon of this analysis is aligned with

our 2050 net-zero ambition

• The upstream value chain was not relevant for this

analysis and therefore is not in scope.

Insights from the above help us assess the bank’s

resilience in a transitioning economy and inform

our strategy.

Current and anticipated effects of impacts

Environmental effects

ABN AMRO recognises that its environmental impact is

primarily driven by the activities of its clients. These

impacts include climate change and biodiversity loss,

which can result in cascading effects. The majority of

environmental effects stem from the financing,

investment products and other services provided by

ABN AMRO, while the bank's own operational footprint

is relatively small. Given the diverse range of economic

activities we finance, providing a comprehensive

description of the effects, or potential effects, of

material matters on people and the environment

remains complex.

For instance, climate change can lead to short-term

economic challenges due to the increased frequency

and severity of extreme weather events. Over the long

term, these challenges may escalate as the impacts of

climate change persist, such as rising temperatures,

melting glaciers and ice sheets, and acidifying oceans.

Additionally, certain client activities may contribute to

biodiversity loss through various drivers, such as air

pollution, which is partially comprised of nitrogen

emissions.

Social effects

ABN AMRO recognises the positive and negative effects

of social impacts; for example, equal treatment and

opportunities for all can have positive effects such as

improved team dynamics, but also negative effects

such as mental health strains if treatment is perceived

as unequal. ABN AMRO has launched various initiatives

to enhance workplace inclusivity and contribute to

broader societal goals. We integrate social

considerations into our operations to create a more

inclusive and resilient bank. These efforts include

initiatives targeting diverse groups, such as women,

individuals from minority cultural or ethnic

backgrounds, people with disabilities, asylum seekers

with refugee status, different generations and the

LGBTIQ+ community. Activities focusing, for example,

on neurodiversity and our Reboot and B-Able

programmes reflect our objectives in these respects.

More details can be found in the Social section.

The effects of the announced reduction in staff in 2025,

as part of the strategic plan described in the Strategy

chapter, have been taken into account in the DMA

assessment.

Current and anticipated effects of risks and

opportunities

For material climate risks in our corporate lending

portfolio (downstream), we have taken EUR 5 million

provision overlays (2024: EUR 19 million), further details

of which can be found in our Credit risk review. We also

hold economic capital for climate risk in our corporate

lending portfolio (downstream) and for flooding,

greenwashing perception and privacy-related risks in

our own operations. See the Climate risk section for

more information on the physical and transitional

climate risks in our lending book.

As in 2024, the DMA in 2025 highlighted some climate-

related opportunities. The energy transition requires

substantial early-stage capital, with ABN AMRO

planning to allocate up to EUR 1 billion by 2030

through direct equity, fund investments and hybrid

debt. In addition, ABN AMRO aims to increase its

lending exposure to renewable energy and

decarbonisation technologies to EUR 10 billion by

2030. Further details can be found in the Climate-

related opportunities section.


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≡	Sustainability Statements	Governance of sustainability matters

Governance of sustainability

matters

This section sets out the governance of sustainability matters. The focus of

this section is on changes to the governance in 2025 and the roles of the

Executive Board and the Supervisory Board.

Changes in sustainability governance

ABN AMRO ensures that sustainability matters are

integrated into its governance and processes, aiming to

address sustainability matters effectively and to keep up

with regulatory expectations and legislation. During the

year 2025, ABN AMRO simplified its governance

structure in relation to sustainability matters as

explained below.

In recent years, the Group Sustainability Committee

(GSC), the role of the Chief Sustainability Officer (CSO)

and the Sustainability Centre of Excellence (SCE) were

introduced to accelerate sustainability governance and

processes within ABN AMRO. Over time, sustainability

matters have been further embedded across

committees that consider environmental, social and

governance impacts, risks and opportunities as part of

routine decision-making. In addition, sustainability is

more effectively integrated into the day-to-day

operations of (among others) the three client units,

Risk Management, Finance and our functions.

This approach aligns with ABN AMRO’s new strategy,

where sustainability is positioned as a strategic enabler

and the governance is more simplified.

More concretely, the following changes have been

made. Firstly, the GSC was decommissioned during the

year 2025. Following this decommissioning, the

Engagement Committee, formerly a subcommittee of

the GSC, was made a subcommittee of the GRC.

Secondly, effective from the beginning of 2026, a

simplified target operating model is in place with clear

mandates and responsibilities, a more focused mandate

of the CSO, the introduction of deputy CSO roles within

departments, the introduction of a Group Sustainability

department and the discontinuation of the SCE. The

Group Sustainability department will serve as a

connector between ABN AMRO’s core sustainability

objectives and its relevant departments. The CSO

remains the senior executive responsible for translating

and driving the sustainability strategy throughout the

organisation. The CSO reports directly to the CEO.

Sandra Phlippen has been appointed CSO effective

1 January 2026.

Our sustainability governance approach effective year-

end 2025 is described in more detail below. For details

about our previous approach, in particular in relation to

the GSC, see our 2024 Annual Report.

For information on the composition, compensation,

expertise and diversity of the Executive Board and the

Supervisory Board, please refer to the Leadership &

governance chapter.

The roles of the Executive Board and the

Supervisory Board

The Executive Board’s procedural rules guide its

functioning and internal organisation. Each Executive

Board committee also has its own procedural rules.

The same applies to the Supervisory Board and its

committees.

Executive Board and its committees

The Executive Board is responsible for the continuity of

ABN AMRO and its affiliated business undertaking as

well as for sustainable long-term value creation. The

Executive Board sets and implements ABN AMRO’s

strategy, to which long-term sustainability is central.

The Executive Board considers, among others, impacts,

risks and opportunities when setting out the

sustainability-related elements in its strategy and

targets. Sustainability is taken into account via KPIs as

described in our Remuneration Report, which helps

drive accountability. The Executive Board is also

responsible for compliance with sustainability

regulations applicable to ABN AMRO.

To carry out its duties, the Executive Board is assisted by

its committees, which offer diverse perspectives on

sustainability matters, depending on their specific

mandates. For instance, the Group Risk Committee


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≡	Sustainability Statements	Governance of sustainability matters

(GRC) is responsible for ESG risk management and for

reviewing and steering ABN AMRO’s risk profile within

the scope of ABN AMRO’s risk appetite. This committee

also evaluates the short-, medium- and long-term

effects of ESG risks on ABN AMRO to support the

Executive Board in making informed strategic and

business decisions. As a subcommittee of the GRC, the

Engagement Committee is responsible for overseeing

ABN AMRO’s engagement activities regarding clients,

sectors and (material) suppliers in relation to

ABN AMRO’s Environmental, Social and Governance

expectations. The responsibilities of the Group

Disclosure Committee (GDC) include advising and

supporting the Executive Board in maintaining the

accuracy, effectiveness and timeliness of disclosures

relating to sustainability matters, including performance

on social and environmental impacts, as mandated by

Dutch and European law. The committees of the

Executive Board are chaired by an Executive Board

member and involve senior leadership as members.

Having dedicated Executive Board committees

underscores the importance of sustainability at the

highest level.

Supervisory Board and its committees

The Supervisory Board supervises and advises the

Executive Board in the exercise of its powers and duties,

including in relation to sustainability. Each of

the Supervisory Board’s committees addresses

sustainability aspects within its area of expertise. For

instance, the Supervisory Sustainability Committee

supervises sustainability aspects of the strategy and

policies. These cover a broad range of topics, including

those covered in the European Sustainability Reporting

Standards (ESRS).

Sustainability governance in relation to risks,

impacts and opportunities

The Executive Board maintains oversight on impacts,

risks and opportunities in relation to sustainability

matters, with assistance from (among others) Group

Strategy and the GRC. In 2025, SCE was responsible for

conducting the DMA. Group Strategy conducted the

integration of the DMA results in ABN AMRO’s strategy.

The Executive Board has mandated the GRC to manage

ESG risks and negative impact. Generally, negative

impact and risk are managed through our ESG risk

management framework and in line with our enterprise

risk management cycle. This includes controls and

oversight by the GRC. Generally, positive impact and

opportunities are included in our strategy (particularly

business strategy) cycles, as overseen by the Executive

Board. In 2025, positive impact and opportunities were

managed by Group Strategy, SCE and the CSO.

Sustainability governance structure



Administrative, management and supervisory bodies	Supervisory Board Audit Committee, Remuneration Committee, Selection & Nomination Committee, Risk & Capital Committee, Supervisory Sustainability Committee

	Executive Board
	Executive Board

	Group Risk Committee Chair: CRO	Group Disclosure Committee - Chair: CFO
	Group Risk Committee Chair: CRO	Group Disclosure Committee - Chair: CFO


n	Supervisory oversight	Risk	Positive impact	Delegates

n	Overall responsibility	Opportunities	Negative impact


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≡	Sustainability Statements	Governance of sustainability matters

Information provided to and sustainability

matters addressed by the Executive Board

and the Supervisory Board

Sustainability matters are discussed on a regular basis

during meetings of the Executive Board and the

Supervisory Board. The Executive Board generally meets

on a weekly basis, and the Supervisory Board meets at

least six times a year. The Executive Board and the

Supervisory Board also receive information from

relevant governance bodies on sustainability matters,

including impacts, risks and opportunities. For instance,

the Executive Board and the Supervisory Board receive

regular updates on progress towards sustainability-

related targets that have been set within ABN AMRO

and on ESG risks and related developments. Material

sustainability topics on the agenda include, among

others, the DMA, ESG risks and sustainability reporting.

Members of the Executive Board and the Supervisory

Board must have sufficient knowledge and

understanding of sustainability. Particular emphasis is

placed on (among others) the knowledge, skills and

expertise required for effectively managing risks,

including AML/CTF, sustainability matters and diversity.

Each year, these Boards formally assess their

own performances, including their composition,

diversity and effectiveness. Similar assessments take

place when members are appointed or reappointed to

the Executive Board or the Supervisory Board. This

ensures that both Boards collectively possess the

necessary skills and expertise, including in relation to

sustainability. Given the nature of ABN AMRO’s

activities, regulators also evaluate topics such as

business conduct and climate and environmental risks

as part of their suitability assessments. This helps ensure

that both Boards are diverse and have the required

knowledge and experience. Following their

appointment, all new Executive Board and Supervisory

Board members participate in a comprehensive

induction programme. This includes sessions on

sustainability-related matters, covering material

impacts, risks and opportunities. As part of the Lifelong

Learning Programme, members of both Boards attend

additional training sessions to keep their sustainability

knowledge up-to-date. Furthermore, knowledge and

expertise with regard to sustainability matters is gained

via (among others) several deep-dive sessions.

³ Not exhaustive.


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≡	Sustainability Statements	Risk management of ESG matters

Risk management of

ESG matters

This section sets out our framework for managing environmental, social and

governance (ESG) risks in line with our overall risk management framework.

It also includes an overview of the policies we have in place for ESG matters.

Background and definitions of ESG risk

Managing ESG risk is a part of safeguarding our risk

profile. ESG risk is defined as the risk of any negative

financial and/or reputational effect on ABN AMRO

resulting from the negative materialisation of current or

future ESG factors on the bank’s portfolio and activities,

its clients, assets or third parties that are actors in the

value chain (referred to as ‘third parties’). ESG risk takes

effect in the form of ESG risk drivers and their

subsequent transmission channels, affecting the

traditional financial and non-financial risk types.

The reputational and financial value of these risks is

determined in line with our risk taxonomy (see Risk

management framework). In the context of risk

management, the term ‘ESG’ is used instead of

‘sustainability’ to ensure alignment with terminology

used by the banking supervisory authorities.

Overview of how ESG risk can impact the bank 3


ESG factors

Environmental
Climate change (E1)
Pollution (E2)
Water and marine resources (E3)
Biodiversity and ecosystems (E4)
Circular economy (E5)

Social
Own workforce (S1)
Workers in the value chain (S2)
Affected communities (S3)
Consumers and end-user (S4)

Governance
Business conduct (G1)

Includes: Inside-out and outside-in


ESG risk drivers

Environmental
Physical • Acute • Chronic

Transition • Policy changes • Technological changes • Behavioural changes

Social
Environmental risk
Changes in social policy
Changes in market sentiment

Governance
Inadequate management of Environmental and Social risks
Non-compliance with corporate governance frameworks/codes


Transmission channels

Microeconomic
Lower profitability
Lower real estate value

Macroeconomic
Increased cost of compliance
Increased legal costs
Lower household wealth
Lower asset performance


Risk types as per Risk Taxonomy

Enterprise risk
Credit risk
Market risk
Liquidity risk
Business risk
Non-financial risk

Value of the bank

Financial

Reputational

ESG factors are environmental, social or governance

matters that may have a positive or negative effect on

the financial performance or solvency of an entity,

sovereign or individual. Inside-out factors include the

negative impacts on people or the environment, as

defined in ESRS. ESG factors can have a financial or

reputational effect on ABN AMRO through its core

business activities.

From a prudential ESG risk management perspective,

the focus is placed on the negative financial and

reputational effect these factors might have on the

bank’s activities, clients, assets or third parties.

⁴ These steps are outlined on the following pages.


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≡	Sustainability Statements	Risk management of ESG matters

Transmission channels are the causal chains that explain

how risk drivers affect the traditional risk types of

ABN AMRO, directly or via its clients, assets or third

parties.

See the Definitions section at the end of the annual

report for the glossary of other sustainability terms.

ESG risk management framework

The seven steps in the ESG risk management framework 4

Business

strategy

Strategic

decision-

making

Risk

identification

and materiality

Risk governance

and ESG risk

policy

Risk

Reporting

Risk

assessment

and

measurement

Risk Control

& Monitoring

Risk

response


Examples of tools and processes:
1	ESG risk management and strategy, target-setting and climate strategy
2	Environmental and social risk heatmap, financial materiality assessment
3	Portfolio scenario analysis, CASY (Client Assessment on Sustainability), stress testing
4	Lending criteria, risk policies, engagement
5	Risk appetite on ESG risks
6	ESG risk reporting at client unit risk and executive committees
7	Insights on ESG risks to decision-making

ESG risk is managed in line with the bank’s enterprise

risk management cycle (ERM cycle). The risk

governance in place (see Governance of sustainability

matters), together with the ESG Risk Policy, which sets

requirements for managing ESG risk, is referred to as

the ESG Risk Management Framework. It ensures

oversight of risks relating to ESG matters and

operationalises how we manage them. The ESG Risk

Management Framework applies to new and existing

clients and suppliers throughout their lifecycle (i.e. from

acceptance, through ongoing due diligence to a

potential exit).

Due diligence in line with the UN Guiding

Principles on Business and Human Rights and

the OECD Guidelines for Multinational

Enterprises

In a similar manner to our enterprise risk management

cycle, the due diligence process, as defined in the UN

Guiding Principles on Business and Human Rights and

the OECD Guidelines for Multinational Enterprises,

outlines the steps to be applied to address actual and

potential negative impacts relating to relevant OECD

themes (for example, human rights and the

environment). The table below maps the core elements

of due diligence and shows where these are addressed

in our Annual Report.


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≡	Sustainability Statements	Risk management of ESG matters


Core elements of due diligence as in the OECD Guidelines			Incorporated in Annual Report section

a) Embedding due diligence in governance, strategy and business model			• Governance of ESG matters • ESG risk management framework • ESG risk policy • ESG Annex- Human rights related disclosures


b) Engaging with affected stakeholders in all key steps of the due diligence			• Strategy, value creation & performance • Client engagement • Dialogue and engagement with our own workforce • Dialogue and engagement related to privacy • Grievance mechanisms and remediation channels • ESG Annex - Human rights related disclosures


c) Identifying and assessing negative impacts			• Strategy and business model - Determining impact materiality • Strategy and business model - Social effects • Risk identification and materiality assessment • Risk assessment and measurement • ESG Annex - Human rights related disclosures


d) Taking actions to address negative impacts			• Risk response • Processes to remediate negative impacts and channels for own workforce • Our approach to action for privacy • ESG Annex - Human rights related disclosures


e) Tracking the effectiveness of these efforts and communicating			• Climate change • Risk control & monitoring and risk reporting • Targets related to own workforce

ESG Risk Policy

Depending on what part of the value chain is under

consideration and what role ABN AMRO plays in it, ESG

risk and its underlying factors will be managed via

different policies and standards. The figure below

provides an overview of ESG-related risk policies and

standards that apply.

The ESG Risk Policy, together with the underlying ESG

risk standards, generic principles and related

exclusions, defines requirements that apply across the

bank and provides the framework for managing ESG

risks within our defined risk appetite. The policy is

reviewed annually to incorporate new insights and best

practices, stakeholder perspectives and internal and

external developments, and to ensure alignment with

the latest regulatory guidance. The policy recognises

ESG as a risk driver across traditional risk types, as

described in our risk taxonomy.

In principle, we neither directly provide financial

products or services to activities on our Exclusion List,

nor engage in business with companies listed on our

Controversial Weapons List.

The ESG Risk Policy articulates how the bank puts the

Enterprise Risk Management cycle into practice in

relation to our new and existing clients and suppliers for

the duration of the lifecycle (i.e. from onboarding,

through to ongoing due diligence and engagement to

potential exit). More specifically, the ESG risk policy acts

as an umbrella document and includes:

• The definition of ESG risks and related ESG terms.

• Requirements that apply to the first line of defence

and the second line of defence across the ERM cycle.

• The framework for managing ESG risks as a risk driver

across traditional risk types.

• How oversight of ESG risks is undertaken.

• Delegated responsibilities and minimum ESG

elements to be considered as part of the bank’s

existing governance.

As part of the delegated authority granted to it by the

Executive Board, the Group Risk Committee is

responsible for approving the ESG Risk Policy. Once

approved, the ESG Risk Policy is communicated

internally across the first and second lines of defence,

which are responsible for its implementation.

⁵ This overview is not exhaustive, but focuses on key policies that can be linked to the role of ABN AMRO as a provider of goods and services across the

value chain.


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≡	Sustainability Statements	Risk management of ESG matters

Risk policies in place to manage ABN AMRO’s ESG matters 5

Risk Governance Charter

Risk Taxonomy

Role of ABN AMRO as a provider of goods and service across the value chain

Downstream value chain

Own operations

Upstream value chain

Lender Services Provider

Investment services

provider

Employees, assets etc

Suppliers

• Code of Conduct

• Global Standards for Client Due Diligence

ESG Risk Policy

ESG Risk Policy Framework

ESG Risk Standards

• Standard with Client Requirements

• Standard for Defence

• Standard for Project Finance

Exclusions

• Exclusion List

• Controversial Weapons list

Other ESG-related Risk Policies / Documents

Enterprise Risk

• Risk Appetite Policy

• ERM Policy

• Stress Testing and

Scenario Analysis

Policy

• Capital Adequacy

Policy

Credit Risk (CR)

• Credit Risk Oversight

& Monitoring

• Central Credit Risk

policy

• Client Investment

Risk Policy

• Whistleblowing

• Anti-bribery and

corruption

• Executive Board

remuneration

• HR Risk Policy

• Behavioural Risk

• Non-financial Risk

• Business Continuity

• Data Risk Policy

• Product Approval and

Review Policy

• Third Party &

outsourcing

Compliance Risk

• Compliance Charter

• Compliance Risk

Policy

• Duty of Care and

Client Centricity

ESG generic principles applicable to

corporate clients

Our Standards and Generic Principles form the

foundation of our Environmental, Social and

Governance (ESG) assessment of the bank's corporate

clients to which we provide corporate loans or other

financing to ensure appropriate monitoring and risk

response measures. They are operationalised into

specific requirements across our client units (Corporate

Banking, Wealth Management and Personal & Business

Banking) and consider the maturity of a client on its ESG

transition by taking into account the size and sector in

which the client is active.

They support the assessment of whether our clients

comply with the United Nations (UN) Guiding Principles

on Business and Human Rights (UNGPs) and the

Organisation for Economic Co-operation and

Development (OECD) Guidelines for Multinational

Enterprises (MNEs), as prescribed by Article 18 of the

EU Taxonomy Regulation.


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≡	Sustainability Statements	Risk management of ESG matters



Generic principles
ESG requirements that apply to corporate clients operating in higher-risk sectors
	Clients comply with applicable laws and regulations and are able to demonstrate transparency regarding their responsible business conduct.	Clients know the salient human rights risks of their own activities and business relationships and take measures to address these risks.
	Clients have a satisfactory ESG track record.	Clients have identified potentially affected groups and other relevant stakeholders and engage with them constructively and openly in assessing and mitigating human rights risks and addressing any grievances.
	Clients take measures to promote circularity and reduce the use of virgin material and waste (e.g. through design, recycling, life-time extension), if applicable.	Clients monitor their GHG emissions and take measures to reduce them in line with the Paris climate goals.
	Clients are aware of how their business model depends on ecosystem services (i.e. resources, pollination) and take measures to preserve these services.	Clients are aware of what the transition to a net-zero economy means for their business model and take appropriate measures to prepare for the transition.
	Clients are aware of their impact on biodiversity, water, air and soil and take appropriate measures to prevent biodiversity loss and pollution.	Clients are aware of the physical risks of a changing climate for their business model and take appropriate measures to mitigate these risks.

Business strategy and strategic decision-

making (steps 1 and 7)

The ESG Risk Policy starts with the setting of the

business strategy by the first line of defence. However,

the business strategy on ESG matters cannot be set in

isolation. It needs to align with the bank's risk appetite

and risk policies in the second line of defence.

As a result, the business strategy and strategic decision-

making are closely linked to risk control and oversight

through the Enterprise Risk Management (ERM) cycle

(described in the next sections):

• ESG risks shape strategic decision-making. For

example, the bank's climate strategy (as described in

the Climate change section) was developed partly in

response to climate-related transition risks. Likewise,

decisions to engage with specific clients or group of

clients to support their transition to a more ESG-mature

business model are based on client- or sector-level risk

assessments. Similarly, decisions to reduce, maintain or

expand certain portfolios are informed by our insights

into ESG risks. For example, our ambition to support the

transition of the European defence industry and our

related ESG risk management framework were

reviewed in 2025.

• Strategic objectives guide ESG risk management. For

example, our risk appetite limits take into account

several elements, such as our long- and medium-term

targets on carbon reduction. In addition, the ESG Risk

Policy, together with its related exclusions and ESG risk

standards, is reviewed regularly to ensure alignment

with our broader strategic objectives, including

assessing our clients’ compliance with these goals.

Risk identification and materiality (step 2)

We assess the non-financial ESG risks (own operations

and downstream) based on the scenario & stress testing

methodology (see the section Risk, funding & capital –

Risk management framework). For identifying risks in

our downstream value chain we rely to a large extent on

our Environmental and Social Risk heatmaps. These

heatmaps inform, for example, the materiality

assessment (see the Strategy and business model

section for more on impact and financial materiality

assessment), the internal stress testing and the risk

appetite (see Risk management framework). Alongside

our risk heatmaps, we scan our emerging risks on a

quarterly basis. Risks identified as the most significant

following the emerging risk scan and assessment with

our internal expert stakeholder group are fed into our

Risk Event Register (RER), which subsequently informs

our risk taxonomy and scenario booklet.

The Environmental and Social Risk heatmaps identify

separate sub-sectors’ inherent sensitivity to

sustainability events. These are sub-sectors in which we

operate through our corporate lending and residential

real estate portfolios (i.e. business environment). The

business environment is analysed under both a sectoral

lens (72 distinct sub-sectors) and a geographical lens

(regions and countries to which we have exposure,

either directly or through the sub-sectors’ value chains).

In 2025, we refined the granularity of our sub-sectors,

further enhancing the segmentation of our heatmaps.

As a consequence, the sub-sectors used to analyse our

business environment increased from 64 to 72 (such as

isolating cleaning activities and outsourcing agencies),

⁶ These values take into account the risk of a negative impact of each individual ESG topic relative to the other ESG matters shown in the table, enabling

cross-topic comparison. For topics E1 to E4, this takes into account sensitivity to transition and physical risks. For E5, S2 and S3, this takes into account

sensitivity of negative impact related to transition risks.

⁷ All relevant ESRS topics were considered during our risk identification process. While E2 and S2 show substantial inherent sensitivity and potential

negative impacts, these were not deemed material for ABN AMRO in in the subsequent Double Materiality Assessment, which included further

evaluation of our loan book and application of materiality thresholds. S1 and S4 are excluded, as they relate to sensitivity to negative impacts not of

our clients, but rather of our own operations.


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≡	Sustainability Statements	Risk management of ESG matters

to better reflect higher social risk sensitivity in our client

assessment tool.

The sensitivities are based on the sector sensitivities to

more than 40 potential underlying physical, transition

and negative impact events and focus on our corporate

lending activities in the downstream part of the value

chain. Examples of these events include flooding and

water stress for physical events, policy and market

effects for transition events, and greenhouse gas

emissions and water use intensity for negative impacts.

Further details on the underlying events relating to

material topics can be found in the Climate change

section.

The overview of Environmental and Social Risk

heatmaps for corporate loans shows an aggregated

score of the negative impact, transition risk and physical

risk scores in order to provide an overview of

sensitivities across sectors, broken down by topic.

A more detailed heatmap specific to climate is included

in the Climate risk section.

The results in the figure below indicate that 20% of our

portfolio comprises clients active in sub-sectors with

potentially high or moderately high sensitivity to

environmental topics, driven by either physical or

transition risks. This applies particularly in respect of

climate change and pollution, where 20% (14% and

6%) and 15% (1% and 14%) respectively, of our

corporate loans are in sub-sectors with a potentially

high or moderately high sensitivity to these risks.

With regard to social topics, we consider human rights

impact to be the main driver of social risks, representing

an inside-out negative impact. This applies mainly in

respect of workers in the value chain, with 15% (2%

and 13%) of our corporate loans being in sub-sectors

with a potentially high or moderately high sensitivity to

these risks.

Overview of Environmental and Social Risk heatmaps for corporate loans 6,7

Risk assessment and measurement (step 3)

ABN AMRO uses various tools to assess and measure

ESG risk at different levels:

• At a bank level: ESG risks are considered under our

materiality assessment and internal stress testing

scenarios. The effect of ESG risks on traditional risk

types is explained in the Climate risk section.

• At a portfolio level: We use scenario analysis

(including climate resilience analysis) to assess the

impact of specific ESG risks in our client portfolios

across the short, medium and long term. In 2025,

climate scenario analyses (see Climate risk section)

were performed for, among others, the residential

and commercial real estate portfolios. In addition, the

product approval and review process considers ESG


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≡	Sustainability Statements	Risk management of ESG matters

risks, alongside other risks, that may arise in our

product offering, such as residential mortgages.

• At a client level: ESG risks of clients are taken into

account and assessed as part of the new client take-

on and review (primarily for corporate clients, and

where applicable for natural persons) and corporate

credit approval request and review. ESG risks of

corporate clients are assessed based on the size,

sector and maturity of the corporate client’s transition

to a more ESG-friendly business model. This is carried

out via various tools:

– (i) the Client Assessment on Sustainability (CASY)

questionnaire applies to clients with a lending

relationship above EUR 1 million and addresses

clients’ compliance with the bank’s ESG risk

management framework;

– (ii) the Transition Readiness Assessment (TRA),

which focuses on sectors and clients in scope of our

climate strategy and measures clients’ maturity in

terms of transition readiness; and

– (iii) the Climate and Environmental Risk

Classification Tool (RCT), which focuses on

corporate clients with non-programme lending and

classifies clients based on their vulnerability to

climate and environmental risks. The CASY and RCT

output are included in the credit risk assessment,

second-line validation and credit risk decision.

• At a supplier level: ESG risks of our key suppliers are

taken into account and assessed when we enter into

new contracts and during the renewal of existing

contracts. Our 2025 salience assessment identified

relevant human rights risk drivers. ESG risks are

measured using our ESG risk assessment tooling

based on data provided by suppliers.

Risk response (step 4)

To ensure that ESG risks are managed in line with the

bank's risk appetite and strategic objectives, mitigating

actions are implemented at three levels: the bank,

portfolio and client levels.

ESG risk mitigation measures include:

• Sector and activity exclusions: certain sectors and

activities are excluded from our lending products and

all our banking services, as outlined in the bank's

Exclusion List (for example animal fur, cultivating

tobacco and manufacturing tobacco products).

• Enhanced requirements for corporate lending: strict

ESG-related requirements apply under the ESG Risk

Standard with Client Requirements.

• Integration into risk policies: ESG risk considerations

are embedded in the bank's credit risk and business

risk policies.

• Climate strategy: targeted strategies for high-

emission sectors, portfolio management and wider

sector approaches support the bank’s climate

objectives.

Client engagement

An important risk mitigating measure is to engage with

our corporate clients (downstream) and suppliers

(upstream) that do not comply with our standards and

have not made sufficient progress with their ESG risk

performance. Different levels of engagement apply,

depending on the outcome of the ESG risk assessment

at either the individual or the portfolio level. Oversight is

carried out via the Engagement Committee which

meets on a quarterly basis.

The overall approach to client engagement remained

unchanged during the reporting period. Engagement

with corporate clients can be divided into four general

categories, as follows:

• Normal intensity: an ongoing process tailored on the

outcome of the client's ESG risk assessment and

improvement areas. It is used as a mitigating action at

the client level and focuses primarily on supporting

the client’s transition to a more ESG-mature business

model on issues that are relevant to its sector and

size.

• Focus list: if a client’s transition to a more ESG-mature

business model is insufficient or if key ESG

developments occur in its profile, the client will be

considered for the focus list. In practice, this means

the client is monitored more frequently and progress

is presented at the Engagement Committee on a

quarterly basis.

• High intensity: if the client continues to demonstrate

insufficient progress on its transition to a more ESG-

mature business model, a formal, time-bound process

is established involving setting detailed objectives. It

could potentially lead to exiting the client

relationship. For an overview of ESG high-intensity

engagements and focus list clients, see the ESG

Annex.

• Thematic engagement: this category applies if we

identify that on average a sector or industry is at risk

of breaching the bank's ESG-related requirements.

Various teams within ABN AMRO can propose a

thematic engagement, and the decision to engage is

made by the Engagement Committee. Thematic

engagements are used for risk mitigation purposes, as

well as to achieve our strategic objectives for

accelerating the transition to a more ESG business

model. There was no thematic engagement in 2025.

• Further information on how we support our clients in

their transition to net-zero can be found in the

Climate Change - Engage with Clients section.

See the topical sections for more information on how

we manage our material ESG risks.


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≡	Sustainability Statements	Risk management of ESG matters

Risk control and monitoring, and risk

reporting (steps 5 and 6)

Monitoring activities help in evaluating whether risk

responses are functioning as intended to keep risk

exposures within the bank’s risk appetite.

• As described in the Risk Management Framework

section, the Strategic Risk Appetite Statement (SRAS)

is split into three key areas: sustainable business

model & value creation, financial soundness and

sound operating environment. A key element in the

sustainable business model & value creation is the

management of our portfolio towards Paris-aligned

decarbonisation targets contained in our policies and

climate strategy.

• The ESG risk appetite is defined through key risk

indicators (KRIs), which address ESG factors and risks.

To ensure ESG risks remain within the approved risk

appetite, we set limits and checkpoints and monitor

them quarterly at the bank-wide, entity and local

levels. This approach enables timely mitigating

actions.

The KRIs related to our material risks are disclosed in

the sections indicated in the table below. These

encompass both physical and transition climate risks.

• We monitor the sector performance and the exposure

coverage of the climate strategy, which supports

effective management of climate transition risks

across risk types.

• In addition, we track our exposure to carbon-related

assets and the ratio of vulnerable collaterals in high

physical risk areas.

• These indicators are reviewed on an ongoing basis as

more granular insights and data become available

over time.

Non-financial risks (including greenwashing perception,

client integrity and duty of care) are controlled by our

policies and continuous risk‑based monitoring in order

to prevent misleading claims, ensure appropriate client

behaviour checks, and safeguard fair client treatment.

For more information on our risk management, see the

Risk, funding & capital chapter.


ESG risk appetite - key risk indicators (KRIs)	Incorporated in section
Climate strategy sector performance	Environment - Climate change - Overview by sector
Coverage of the bank’s commitment to Net-Zero Banking Alliance decarbonisation targets	Environment - Climate change - Coverage of our climate strategy
Carbon-related exposure (% Gross Carrying Amount)	Environment - Climate change - GHG monitoring - Carbon-related assets
Vulnerable collateral in high physical risk area (%)	Environment - Climate change - Climate scenario analyses - Residential real estate


ABN AMRO	Annual Report 2025	218


≡	Sustainability Statements	Environment

Environment

Through our banking activities we have an impact on the environment.

We can play a role in the sustainability transition through our lending and

asset management activities. In our DMA, we have identified two material

environmental topics: climate change and biodiversity & ecosystems.

We focus our efforts on two main topics, which are

climate (in line with the publication of our Climate

Strategy in 2022), and biodiversity. Environmental

topics are highly interconnected.

Climate change, for instance, contributes to biodiversity

loss by disrupting ecosystems. At the same time,

biodiversity helps mitigate climate change, as healthy

ecosystems naturally absorb and store carbon.

Climate change

Climate change presents significant challenges to society and the economy.

As a financial institution, ABN AMRO supports the transition to a net-zero

future. We do this by financing sustainable activities and managing climate-

related risks.

In this chapter, we outline our climate strategy, progress

towards financed emissions targets, plans, and actions

taken to meet those targets. We also discuss identified

climate risks and opportunities, and how we respond

to them.

Material matters included in this section

Material topics

Type

Linked to portfolio & industries

Topic

Subtopic

ABN AMRO

label

Definition

Type of

materiality

Value chain

identification

Personal

loans &

mortgages

Corporate

loans¹

Client assets¹

Climate

change

Climate

change

mitigation

Climate

change

mitigation

The process of limiting the increase

in the global average temperature

through minimising the negative and

maximising the positive impact

caused by the activities of our clients

Negative

impact

Downstream

Impact: GHG

emissions

Residential

mortgages

Agriculture,

mining &

quarrying (oil &

gas), electricity

(production),

transport

(shipping & road

transport),

commercial real

estate, and

others

Energy,

manufacturing,

transportation,

mining and

quarrying,

utilities

Climate

transition

risk

Risks that arise from the transition to

a low-carbon and climate-resilient

economy

Financial risk

Downstream &

own

operations

Agriculture,

mining &

quarrying (oil &

gas),

manufacturing,

electricity

production,

transport, and

others

Climate

physical risk

Risks resulting from climate change

that can be event-driven (acute) or

from longer-term shifts (chronic) in

climate patterns

Financial risk

Downstream &

own

operations

Residential

mortgages

Climate

change

mitigation

Climate

change

mitigation

The process of limiting the increase

in the global average temperature

through minimising the negative and

maximising the positive impacts

caused by the activities of our clients

Financial

opportunity

Downstream

Sustainable

impact fund,

renewable

energy and

decarbonisation

technologies

1. 1. The list of sectors depicted is non-exhaustive.


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≡	Sustainability Statements	Environment	Climate change

Climate risk is integrated into ABN AMRO’s ESG Risk

Policy, which establishes requirements for managing

ESG risks, including environmental risks, across the

bank’s enterprise risk management cycle. Our climate

strategy supplements this policy by defining targets and

initiatives aimed at aligning our portfolio and operations

with a net-zero trajectory and reducing GHG emissions.

For further details, see the section on the ESG risk

management framework and ESG Risk Policy.

Our climate strategy

Our climate strategy outlines our commitment to

aligning our portfolios with a 1.5°C scenario and

supporting the transition to a net-zero economy by

2050. As part of our commitments under the Dutch

Financial Sector Climate Agreement and the guidance

of the Net-Zero Banking Knowledge Hub (previously

NZBA), we have prioritised sector-specific targets for

high-emitting industries. In November 2025, we

announced our intention to update our climate strategy

(for more details, see the Enablers of our strategy

section).

Following recent geopolitical developments and

a positive vote by its members to move away from

a membership-led alliance to a framework, NZBA ceased

operations effective 3 October 2025. Since launching our

climate strategy in 2022, NZBA has been a facilitator

for its execution, providing guidance on science-based

target setting, transition planning, best practices and joint

policy advocacy. Over the coming period, the NZBA

Steering Board and secretariat will define the details of

this new framework. In the meantime, the guidance will

remain available to use under the Net-Zero Banking

Knowledge Hub. We will continue to reference the

Guidance for Climate Target Setting for Banks and

supporting implementation resources as a reference for

the execution of our climate strategy.

Decarbonisation levers

Based on the priorities from our climate strategy, we

have identified three decarbonisation levers, which

ABN AMRO uses to implement specific actions aimed at

achieving climate targets for each sector. Our activities

are linked to these decarbonisation levers and can be

found below in the infographic.

The ESRS are sector-agnostic, which means they do not

account for the specific characteristics of the banking

industry. Moreover, the indirect influence of

ABN AMRO's decarbonisation levers makes it difficult to

directly measure their impact on GHG emission

reductions. An important lever for supporting

decarbonisation efforts is engaging with clients.

Finally, ABN AMRO’s climate strategy and actions taken

served as the foundation for identifying decarbonisation

levers. Climate scenarios were not considered in this

process.

Activities

Align our portfolio

with a net-zero

trajectory

Engage with

clients

Promote

sustainable

finance products

Integrate climate

into decision-

making

Learn and upskill

continuously

Collaborate in

key industry

initiatives

Align our portfolio with a net-zero trajectory

We have established emission reduction targets across

our lending portfolios and client assets, focusing on

responsible carbon intensity reduction.


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≡	Sustainability Statements	Environment	Climate change

Our approach to target-setting for the lending portfolio

is built on the four elements found in the infographic

below.



	Sector-based focus			Industry guidelines

	Target setting

	Performance Monitoring			Science Based Approach

To achieve our targets, we rely on assumptions

embedded in the underlying sector-specific

benchmarks, including the development of emerging

technologies and shifts in consumer demand.

These assumptions are monitored as described further

down in the section Integrate climate into decision-

making and inform our implementation strategy. For

example, within our road transport sector, in 2025 we

focused our actions on a portion of the truck portfolio

where we can have the most impact, as EU regulations

and incentives are expected to independently

accelerate sector decarbonisation.

Regarding our targets, the selected decarbonisation

pathways vary across sectors due to differences in

portfolio characteristics, emission-generating activities,

lending products and the chosen target type. For all

sectors apart from agriculture and commercial real

estate, we have chosen science-based benchmarks that

are aligned with the latest 1.5°C scenario reference

pathways. For agriculture, we have opted to align with

the scientific calculations in the 2022 Climate and

Energy Outlook of the Netherlands (Klimaat- en

Energieverkenning, KEV) compiled by the Netherlands

Environmental Assessment Agency (Planbureau voor de

leefomgeving, PBL), which uses the IPCC Fifth

Assessment Report (AR5) for Global Warming Potential

(GWP) values and considers the implemented and

proposed policies of the Dutch Coalition Agreement

and its ability to fulfil the EU FIT for 55 goals. See the

explanation on commercial real estate below. For client

assets in 2025, we have aligned our reduction pathway

with the 1.5°C scenario outlined in the

Intergovernmental Panel on Climate Change (IPCC)

Special Report, following current guidance and science-

based net-zero investment frameworks.

We recognise that some 2030 targets do not fully align

with the pathway chosen for the sector concerned. This

applies to residential mortgages, commercial real

estate, inland shipping, and road transport trucks and

vans, where the 2030 targets are above the reference

pathway. In 2025, for commercial real estate we

assessed and continue to uphold our target based on

the Carbon Risk Real Estate Monitor (CRREM) 1.5°C

scenario V1 pathway, despite the heightened ambition

of the CRREM 1.5°C scenario V2. Further details can be

found within the sector-specific narratives provided

below. All sector baseline values calculated are based

on data from a single year, rather than on multi-year

averages. During the next strategic period, we intend to

update our climate strategy, which includes pathways

and targets, with our ultimate aim remaining to achieve

net zero by 2050.

Independent of those changes, ABN AMRO is

establishing quality checks and a reassessment process

to ensure that reported progress towards existing

targets accurately reflects real decarbonisation, rather

than being affected by data or calculation changes. We

aim to implement these in 2026.

In our current climate strategy framework, two distinct

methodologies are used to calculate emission intensity

across different sectors: the portfolio share approach

and the Partnership for Carbon Accounting Financials

(PCAF) approach. In early 2025 it was decided that ABN

AMRO would use the PCAF approach for calculating

portfolio emissions intensity for all new and reassessed

targets unless applying the PCAF approach is not

feasible. As a result, we have aligned our commercial

real estate target and are in the process of aligning the

power generation target to the PCAF approach. Oil and

gas upstream and midstream and deep-sea shipping

are the sectors for which the portfolio share approach

will continue to apply.

Internal stakeholders were involved in setting these

targets, including sector leads and climate experts.

Apart from one external consultant, no other external

stakeholders were engaged in the process. The climate

targets have not been validated by an independent

external body.

Lastly, our sector targets primarily cover scope 1 and 2

emissions of our clients. While our clients’ scope 3

emissions are significant, they are challenging to

include due to limited data availability, high uncertainty

and our limited influence over value-chain activities.

Further details on all targets, including changes in

measurement methodologies, assumptions, limitations,


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≡	Sustainability Statements	Environment	Climate change

sources and data-collection processes, are provided in

the Overview per sector or Definitions sections.

Coverage of our climate strategy

In line with our climate strategy and the guidance

provided by the Net-Zero Banking Knowledge Hub, we

have set and published targets for several of the high-

emitting sectors that are considered significant and

material. The infographic below shows our total

exposure to high-emitting sectors. Compared to last

year, there are no significant changes in the coverage of

our climate strategy for each high-emitting sector.

The parts of the coverage portfolio that are not yet

addressed by a target are excluded for several reasons,

such as methodological assumptions, limited internal

data quality and availability, or because they are

classified as immaterial. In some cases, exclusions may

also reflect a focus on emissions where ABN AMRO has

a greater ability to influence outcomes, such as scope

1 and 2 emissions of clients. The materiality assessment

is carried out periodically, particularly for high-emitting

sectors for which we have not yet set targets. Sector-

specific details on these considerations are provided in

the relevant sections.

In 2025, we raised the materiality threshold for sector-

level targets from 0.25% to 1% of the corporate loan

book. Sectors below this level, such as iron & steel,

aluminium, cement and aviation, are considered

immaterial. This change aligns with peer practice,

focusing efforts on sectors with the greatest impact. We

remain dedicated to monitoring the exposure to these

sectors and will engage with clients in these sectors to

support their decarbonisation efforts.



Coverage of our climate strategy
		31 December 2025
		Gross carrying amount in scope of the target (in millions)	% GCA coverage compared to sector portfolio	% GCA coverage compared to total loans and advances
Climate strategy sub-sector	High-emitting sectors	Financed emissions in scope of the target (in ktCO 2 e)	% Financed emissions coverage compared to sector portfolio	% Financed emissions coverage compared to total financed emissions

Residential mortgages	Residential real estate	162,938	~100%	62%
Residential mortgages	Residential real estate	1,089	~100%	4%

Commercial real estate	Commercial real estate	11,590	85%	4%
Commercial real estate	Commercial real estate	274	85%	1%

Power generation ¹	Power generation	1,778	95%	1%
Power generation ¹	Power generation	0	0%	0%

Oil and gas - upstream	Oil and gas	1,659	76%	1%
Oil and gas - upstream and midstream	Oil and gas	512	57%	2%

Agriculture	Agriculture	3,745	57%	1%
Agriculture	Agriculture	1,502	52%	5%


Maritime transport - deep-sea shipping
Maritime transport - inland shipping
Maritime transport - inland shipping		4,113	52%	2%
Road transport - trucks	Transport	4,113	52%	2%
Road transport - trucks	Transport	1,835	55%	6%
Road transport - vans		1,835	55%	6%
Road transport - vans
Road transport - passenger cars


	Other	0	0%	0%
	Other	0	0%	0%
	Total gross carrying amount (in millions)	185,824	86%	70%
	Total financed emissions	5,212	53%	18%

1.The emissions from power generation are zero because only renewable energy clients were in scope, therefore resulting in 0% coverage of financed emissions.

Engage with clients

Supporting clients in their transition to net-zero is

central to our climate strategy and decarbonisation

efforts. Our clients’ ability to reduce emissions directly

impacts our own progress in decarbonising. To

accelerate this, we leverage client-specific data to

deliver tailored ESG insights and guide portfolios

towards decarbonisation targets.

A key tool in this is the Transition Readiness Assessment

(TRA), which helps determine how prepared a client is

to adopt sustainable practices and whether such a

⁸ It was decided to focus solely on Trucks and not expand the TRA to the other road transport sub-sectors (see the Road Transport sections for details).


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≡	Sustainability Statements	Environment	Climate change

transition is feasible. The TRA is used in several sectors

and provides insights into clients’ climate performances

and transition plans, enabling us to steer towards the

2030 emissions targets. We leverage our insights and

expertise to engage with clients, offering solutions for

decarbonisation and advising on reducing carbon

emissions.

Starting in January 2025, the TRA has been integrated

into our client assessment tooling for Shipping, Power

Generation, Oil & Gas Upstream and CRE. This new IT

environment ensures enhanced data management and

an optimised workload for end-users, as it incorporates

other ESG assessments currently utilised by ABN AMRO.

In 2025, the TRA coverage was expanded further to

cover trucks in road transport in addition to shipping, oil

and gas upstream, power generation, commercial real

estate, inland shipping and agriculture 8. Assessments

have been completed for most of the approximately

2000 clients in these sectors, except agriculture. The

Corporate Banking reorganisation has led to revision of

the TRA scope and design in the agriculture portfolio,

where TRAs were carried out for 80 clients in 2025.

Efforts are being allocated on the basis of materiality

and data availability. Moreover, we aim to collect

external client-level data over the course of 2026. This

will allow us to engage effectively and impactfully with

clients where necessary. A pilot on oil and gas

midstream has been completed, while the rollout

timelines are under discussion.

In 2025, we also completed our Climate Dashboard,

which provides relationship managers with access to

comprehensive ESG and TRA data, providing insights

into the client’s ESG metrics and helping to facilitate the

conversation on ESG with the client. See also the Risk

assessment and measurement section of this Annual

Report, where we discuss other types of client

engagement.

Promote sustainable finance products

We provide various sustainable finance products and

services designed to support clients in their transition

towards greater carbon efficiency and climate

resilience. For example, within our residential mortgage

offering, clients who purchase a home with, or upgrade

their home to, energy label A or B are eligible for

interest rate discounts, which is an incentive that helps

make sustainable living more financially accessible. We

provide a financing facility for our commercial real

estate clients to support energy-saving measures. While

the uptake of these solutions can be influenced by

external factors beyond our control, we remain

dedicated to enabling progress through tailored

offerings.

Integrate climate into decision-making

Our climate strategy, which contains key elements of

our transition plan, is included in ABN AMRO’s bank-

wide business strategy and financial planning, making it

a part of our standard operations and daily activities.

Financial planning processes allow for the allocation of

resources, ensuring that initiatives related to climate

and broader ESG factors are adequately budgeted,

funded and aligned with our financial goals. In this, we

focus on operational expenditure over capital

expenditure, as our climate targets largely rely on the

capital investments made by our clients rather than

those of ABN AMRO.

Strategic decisions, including target-setting and

progress evaluation against these targets, fall under the

responsibility of the Executive Board. Further details can

also be found in the Governance of sustainability

matters section.

Learn and upskill continuously

To effectively support our clients in their transition to

net-zero, we recognise the importance of continuously

upskilling our workforce. Our Sustainability Academy

plays a central role in this effort, offering a range of

learning opportunities, including e-learning modules

and tailored training programmes designed for specific

roles and sectors. These e-learnings are mandatory,

depending on the department.

We offer specialised learning paths tailored to specific

roles and sectors for employees whose roles are directly

impacted by the climate strategy. All learning

programmes for the initial focus sectors have been

completed. For the remaining sectors, learning needs

were assessed, with one sector having a learning

programme rolled out.

Mortgage advisers are trained as Sustainable Living

Advisers to guide clients on financing and energy-

efficient property improvements. Relationship

managers receive regular updates on sustainable

products and regulatory developments, which enables

them to provide informed guidance and solutions that

align with clients’ ESG goals.

Collaborate in key industry activities

Achieving our intermediate emission targets and action

plans requires collective action. The transition to net-

zero is a long-term effort, relying on collaboration and

active support from stakeholders across the public and


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≡	Sustainability Statements	Environment	Climate change

private sectors, despite expected challenges and

dependencies. We support such collaboration by

joining initiatives like the Alliance of CEO Climate

Leaders, which encourages governments to accelerate

renewable energy investments and streamlining

permitting and regulatory processes.

In the Netherlands, we work with the Dutch Banking

Association and the Financial Sector Climate

Commitment to collaborate with the Dutch

government, advancing a stable investment climate and

supporting our clients' sustainability transition while

contributing to broader climate solutions. When it

comes to specific sectors, for example agriculture, we

work with the government to push for clear policies that

advance decarbonisation efforts, within the dynamic

agricultural policy and legislative environment in the

Netherlands.

Overview per sector


		Gross carrying amount (in million EUR) ⁵	Metrics	Scopes covered ⁶	Baseline year value (baseline year)	2025 performance figures (previous year)	2025 financed emissions (in ktCO2e)	2030 interim target	2030 reduction required vs. 2025 performance	Benchmark scenario
	Residential mortgages	162,938	Physical intensity: kgCO 2 /m ²	Scope 1, 2	27.6	19.2	1,089	16.6	-14%	CRREM 1.5 NL scenario V2
					(2021)	(19.5)
	Commercial real estate	11,590	Physical intensity: kgCO 2 /m ²	Scope 1, 2	71.0	60.8	274	35.7	-41%	CRREM 1.5 NL scenario V1
					(2021)	(60.3)
	Power generation ¹	1,778	Convergence target: kgCO2 /MWh	Scope 1	17.6	0.0	0	< 188	0%	IEA NZE 2050 scenario
					(2021)	(3.5)
	Oil and gas - upstream ²	211	Absolute committed financing (EUR million)	Indirectly covering Scope 1, 2 and 3	1,268	566	100	987	0%	IEA NZE 2050 scenario
					(2021)	(804)
	Oil and gas - upstream and midstream ¹	1,659	Convergence target: kgCO 2 e/boe	Scope 1, 2	12.3	13.1	512	9.0	-32%	IEA NZE 2050 oil and gas
					(2022)	(16.0)
	Maritime transport - deep-sea shipping ^{1, 3}	3,366	Weighted Climate Alignment (%) (based on AER in gCO2 / DWT nautical miles)	Scope 1 and parts of Scope 3	0.3%	-2.1%	1,399	0%	-44% Target is to be fully aligned with DNV 1.5 trajectory, scenario 10	DNV 1.5°C Initiative, Scenario 10
					(2021)	(-2.0%)
	Maritime transport - inland shipping	345	Physical intensity: gCO2 e/tkm	Scope 1 and parts of Scope 3	25.8	26.0	351	18.3	-30%	IEA NZE 2050 Transport scenario
					(2023)	(26.2)
	Agriculture	3,745	Financed mtCO 2 e	Scope 1, 2	2.0	1.5	1,502	1.4	-5%	Dutch Coalition Agreement (2021)
					(2022)	(1.6)
	Road transport - trucks	252	Physical intensity: gCO2 /tkm	Scope 1	81.5	77.2	77	61.1	-21%	IEA NZE 2050 heavy-duty vehicles
					(2023)	(79.9)
	Road transport - vans	70	Physical intensity: gCO2 /vkm	Scope 1	225.5	198.3	6	141.4	-29%	IEA NZE 2050 passenger cars
					(2023)	(218.9)
	Road transport - passenger cars⁴	81	Physical intensity: gCO2 /vkm	Scope 1, 2	97.6	83.8	2	63.0	-25%	IEA NZE 2050 passenger cars, modified to include scope 2 emissions
					(2023)	(96.3)
1. Performance figures, financed emissions and 2030 reduction required are based on 2024 figures.
2. The baseline year value (2021) and 2030 interim target include both the outstanding and undrawn amount in millions (EUR).
3. The reported gross carrying amount includes the scope of Poseidon Principle vessels for which we were able to obtain actual GHG data and excludes vessels that have been financed in the course of 2025.
4. Excluding financed emissions from our Alfam portfolio. If these emissions had been included, our 2025 performance figure would have been 93.5 gCO₂/vkm.
5. For all sectors shown, based on 31 December 2025 figures.
6. Please refer to the Definitions section for more information on the emission scopes covered by our targets.

⁹ Gross residual mortgage debt is the outstanding mortgage debt before deduction of accrued values (e.g. savings-based mortgages).


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≡	Sustainability Statements	Environment	Climate change

Residential mortgages

Benchmark is CRREM 1.5 NL scenario V2

kgCO2/m²

14% reduction in carbon

intensity by 2030

compared with 2025

2021 2025

The above graph illustrates the 1.5°C-aligned reduction pathway for residential real

estate in the Netherlands as defined by the Carbon Risk Real Estate Monitor

(CRREM) 1.5°C scenario V2. The Y-axis represents emission intensity in kilograms

per square metre (kgCO2/m²), while the X-axis shows time from the baseline year

2021 to 2050. The graph shows the average carbon emissions per square metre for

residential real estate that CRREM 1.5°C scenario V2-aligned organisations are

expected to achieve.

In 2025, the emission intensity of the residential

mortgages portfolio decreased to 19.2 kgCO2/m²,

compared with 2024, when it was at 19.5 kgCO2/m².

This is mainly the result of the increase in homes that

we finance with energy label A or higher, and these

labels are associated with lower emission factors.

Details on the target's scope and calculation

methodology can be found in the Definitions section.

ABN AMRO follows the CRREM scenario V2 1.5°C-

aligned pathway specifically tailored to residential real

estate in the Netherlands. The decline outlined in the

CRREM scenario V2 pathway appears, at present,

unlikely to be achieved by 2030, as reflected in our

current target, which exceeds the 1.5°C-aligned

trajectory. Despite this challenge, we aim to reduce our

carbon footprint and steadily advance towards net-zero

emissions by 2050.

While the CRREM 1.5°C scenario V2 outlines an ideal

pathway, our target reflects challenges such as limited

government policies and insufficient homeowner

incentives for energy efficiency investments, which

necessitate a more gradual convergence. This allows us

time to strategically align with the benchmark in the

years up to and beyond 2030. Although we offer

products and services to support clients in improving

their energy efficiency, our influence on client

behaviour and market trends is limited. Decarbonising

the mortgage market depends on external factors such

as government regulations, technological advances,

supply chain changes, pricing, decrease in fossil fuel

use for electricity generation in the Netherlands, and

labour availability.

We monitor the credit risks related to the physical

climate risks for this sector, as disclosed further on in

the section on Climate scenario analyses.

Key actions to reach our target

See the Climate strategy section for actions taken that

count for all sectors. The actions specific to this sector

are listed here.

Supporting our clients’ transition journey:

• We offer interest rate discounts to clients financing a

home with energy label A or B or investing in

improving their existing home to energy label A or B

within 24 months of the interest rate origination or

reset date. By the end of 2025, 28% of our mortgage

portfolio (based on Gross Residual Mortgage Debt 9)

benefitted from a sustainability discount.

• Clients can finance energy-efficiency measures via a

Sustainable Home Mortgage, an Energy-Efficiency

Budget, or combining Energy Efficiency Measures

with a mortgage. By the end of 2025, our portfolio

comprised approximately 50,600 sustainability-linked

loan elements.

Aligning processes and policies:

• Our credit-granting policy complies with national

legislation and integrates environmental factors into

underwriting criteria, including loan-to-value and

loan-to-income rules for financing energy reduction

measures.

• In accordance with our internal Mortgage Advice

Policy, ABN AMRO’s client advisers must discuss

financing options for sustainability improvements

during every mortgage consultation and provide

suggestions for making properties more sustainable.

This is also addressed in our mortgage advice reports,

supported by the Energy Saving Check to identify

potential energy-saving measures.

Both these policies are the responsibility of the CCO of

Personal & Business Banking.


ABN AMRO	Annual Report 2025	225


≡	Sustainability Statements	Environment	Climate change

Commercial real estate

Benchmark is CRREM 1.5 NL scenario V1

kgCO2/m²

41% reduction in carbon

intensity by 2030

compared with 2025

2021 2025

The above graph illustrates the 1.5°C-aligned reduction pathway for commercial

real estate (CRE) in the Netherlands, as defined by the Carbon Risk Real Estate

Monitor (CRREM) 1.5°C scenario V1 and V2. The Y-axis represents emission intensity

in kilograms per square metre (kgCO2/m²), while the X-axis shows time from the

baseline year 2021 to 2050.

In 2025, the emission intensity of the commercial real

estate portfolio increased to 60.8 kgCO2/m², compared

with 2024, when it stood at 60.3 kgCO2/m². The slight

increase in intensity is due to the change in calculation

methodology. Based on our assessment, this

methodological change does not result in a significant

effect on the current or prior years. However, the

increase in the financed building area with energy label

A or higher is therefore not reflected in the emission

intensity.

We assessed and continue to uphold our target based

on the CRREM 1.5°C scenario V1 pathway, despite the

heightened ambition of the CRREM 1.5°C scenario V2,

which applies a revised carbon budget, resulting in a

steeper decarbonisation pathway.

At this time we have chosen not to align our 2030 target

with the CRREM 1.5°C scenario V2 pathway because

we do not consider this to be realistic for our portfolio.

We deem the CRREM 1.5°C scenario V1 to be more

realistic for our portfolio, as it enables more effective

steering towards gradual convergence with our long-

term net-zero target for 2050. Details on the target's

scope and calculation methodology can be found in the

Definitions section.

Progress against our current 2030 target of

35.7 kgCO2/m² based on the CRREM 1.5°C scenario V1

even reflects existing challenges such as limited

government policies regarding minimum energy label

requirements for existing buildings leading up to 2030,

the challenges of moving from gas use to all electric

due to grid congestion and decarbonisation of the

electrical grid. While we offer a sustainable finance

product to help current and future clients improve the

energy efficiency of their properties, our influence to

drive broader market trends and client behaviour

remains limited.

We monitor the credit risks related to the physical

climate risks for this sector, as disclosed further on in

the section on Climate scenario analyses.

Key actions to reach our target

See the Climate strategy section for actions taken that

count for all sectors. The actions specific to this sector

are listed here.

Supporting our clients’ transition journey:

• In April 2025, we introduced the free online Green

Building Tool to support clients in saving energy and

enhancing their energy label.

• ABN AMRO's Sustainability Facility

(‘Verduurzamingsfaciliteit’) supports CRE clients in

financing measures from the Recognised Energy

Savings Measures List (‘Erkende maatregelenlijsten

energiebesparing’, EML) by the Netherlands

Enterprise Agency (RVO), offering favourable

repayment and interest terms to advance

sustainability goals. All new and renewed loans

adhere to this principle.

Aligning processes and policies:

• Valuation reports now assess properties' market

values assuming a transition to energy label A, per

sustainability guidelines (DuPa 2.0). These reports

detail upgrade investments, highlight potential value

increases, and support reduced GHG emissions while

providing banks with insights into financing the

transition.

• It is ABN AMRO’s strategic ambition to focus on

financing label A properties while adhering to a

transition policy. Under this credit policy, a funded

capex plan is required to upgrade buildings with

energy label D (NL) or lower to label C or higher,

promoting energy efficiency improvements.

• ABN AMRO’s credit policy sets maximum tenors for

CRE financing, encouraging a dynamic portfolio.

Upon loan expiration, refinancing may be declined for

buildings with energy label D or lower if the client is

unwilling to invest in improving the energy label.

The policy is the responsibility of the CCO of Corporate

Banking.


ABN AMRO	Annual Report 2025	226


≡	Sustainability Statements	Environment	Climate change

Power generation

Benchmark is IEA NZE 2050 scenario

kgCO2/MWh produced

2021 2024

Power generation figures are not yet available for 2025 as the reported emissions

from our clients, which we rely on, are not yet available. We therefore report

progress on this sector with a year’s delay. The above graph curve represents the

1.5°C-aligned reduction pathway for global power generation from the

International Energy Agency’s (IEA) Net-Zero Emissions (NZE) 2050 scenario.

Amounts of CO₂ in kilograms per megawatt hour (MWh) produced are on the Y-axis.

Time is represented on the X-axis, starting in the year 2021 through to 2050. The

graph therefore shows the average CO₂ per megawatt hour emissions for power

generation that IEA NZE 2050-aligned organisations are expected to achieve.

Portfolio emission intensity decreased compared with

2023. This reduction reflects that in 2024 only

renewable energy clients were in scope of the intensity

target, resulting in a portfolio emission intensity of

0 kgCO₂/MWh, compared with 3.5 kgCO₂/MWh as

reported in 2023.

Our emission intensity is already well below the

benchmark intensity level and the 2030 target. This is

because we have offboarded significant parts of our

emission-intensive sectors since 2020 as part of the

wind-down of our Corporate & Institutional Banking

activities outside Europe, leaving us with a Northwest

European portfolio that started decarbonising well

before 2021. Details on the target's scope and

calculation methodology can be found in the Definitions

section.

ABN AMRO is dedicated to phasing out thermal coal by

2030, and includes requirements for coal-fired power

generation companies in the ESG Risk Standard with

Client Requirements. We will only finance clients with

over 5% reliance on thermal coal if they have a public

2030 phase-out plan. Exceptions exist for a number of

clients in Germany that are over 5% reliant on thermal

coal and directly or indirectly operate coal-fired power

stations that constitute critical infrastructure in terms of

Germany’s energy availability and security, and that are

scheduled to close down in accordance with the

German Coal Phase-out Act.

For this sector, the actions primarily align with those

outlined in the Climate Strategy section, which are

applicable across all sectors, rather than specific key

actions unique to this sector.

The action outlined for Carbon Environmental Solutions

(CES) in the previous year’s Annual Report has been

reassessed to determine its continued relevance for this

sector. While it remains very relevant, it spans multiple

sectors rather than being specific to Power Generation.

For this reason, it is no longer considered a key action

for this sector.

Oil and gas - upstream

Benchmark is IEA NZE 2050 scenario


Absolute reduction of committed amounts in EUR million	Oil & gas per IEA NZE 2050 supply curve (indexed: 2021 = 100%)

2021 2025

The graph shows the 1.5°C-aligned reduction pathway for the oil and gas sector,

based on the International Energy Agency’s (IEA) Net-Zero Emissions (NZE) 2050

scenario, expecting a significant decline of fossil fuels by 2050. Nevertheless fossil

fuels are expected to remain in carbon-embodied products and goods. The X-axis

represents the timeline from 2021 to 2050, while the Y-axis shows the absolute

reduction in committed financing for the oil and gas sector, measured in millions of

euros. This graph serves as a benchmark for assessing our commitments in the

upstream oil and gas industry.

As expected, and in line with our target, our oil and gas

upstream commitments continued to decline over the

past year, from EUR 804 million in 2024 to

EUR 566 million in 2025. We have continued

decreasing our exposure over 2025 due to refinancing

decisions and repayments by clients. Changes in the

EUR/USD exchange rate have also impacted our overall

exposure. We continued to exclude direct lending to oil

and gas fields licensed for development after 2023. This

aligns with the International Energy Agency’s (IEA) latest

Net Zero Emissions (NZE) 2050 scenario. We continue to

assess our policies and targets based on IEA updates.

Details on the target's scope and calculation

methodology can be found in the Definitions section.

We have also outlined a clear transition strategy for our

oil and gas portfolio. This strategy aims to incentivise

our clients’ energy transition and expand our portfolio

to include more renewable and decarbonisation

technologies, while also supporting our existing clients

in decarbonising their oil and gas activities through an

operational emissions intensity target (see below). More

information on our targets in financing renewables and


ABN AMRO	Annual Report 2025	227


≡	Sustainability Statements	Environment	Climate change

decarbonisation technologies can be found in the

Climate-related opportunities section.

For this sector, the actions primarily align with those

outlined in the Climate Strategy section, which are

applicable across all sectors, rather than specific key

actions unique to this sector.

Oil and gas - upstream and midstream

Benchmark is IEA NZE 2050 oil and gas

kgCO2e/boe

32% reduction in carbon

intensity by 2030

compared with 2024

2022 2024

The operational emission intensity figures for the Oil and Gas - upstream and

midstream portfolios are not yet available for 2025 as the reported emissions from

our clients, which we rely on, are not yet available. We therefore report progress on

this sector with a year’s delay. The graph shows the 1.5°C-aligned reduction

pathway for global oil and gas based on the IEA’s Net-Zero Emissions (NZE) 2050

scenario. CO₂ equivalent emissions (CO₂e) in kilograms (kg) per barrel of oil (boe)

produced, distributed or transported are on the Y-axis, with time on the X-axis from

2022 to 2050.

The goal of the IEA's Net-Zero by 2050 initiative is to

align with the Paris Agreement's 1.5°C scenario by

significantly reducing GHG emissions. Any remaining

emissions are expected to be offset through methods

such as carbon capture, removal and storage from the

atmosphere. The IEA's forecast for the total energy

supply by 2050 shows a remaining demand for oil and

gas.

Besides the upstream clients included in our absolute

financing reduction target (see above), we have a

combined operational emissions intensity reduction

target for our upstream and midstream client portfolios,

reflecting the specific composition and diverse activities

within our oil and gas portfolio. Our operational

emission intensity reduction target aligns with the IEA’s

Net-Zero emissions scenario by 2050, which focuses on

scope 1 and 2 operational emissions. This scenario

served as a benchmark for our target setting. While our

operational intensity target covers scope 1 and 2

emissions, we are also dedicated to making meaningful

progress in reducing scope 3 emissions. Our upstream

absolute financing reduction target ensures that

scope 3 emissions of the upstream segment – which is

recognised as the most emission-intensive part of our

oil and gas portfolio – are on a downward trajectory.

This dedication underscores our efforts to address the

broader impact of our operations and contribute to a

sustainable future.

Our 2030 target is a 27% reduction in operational

emissions intensity across our portfolio compared with

the 2022 baseline, aligning with the reduction outlined

by the IEA NZE for operational emissions intensity in the

oil and gas sector. Details on the target's scope and

calculation methodology can be found in the Definitions

section.

We report intensity figures with a one-year delay due to

timing differences in reporting. Our current, 2024,

portfolio operational emissions intensity is 13.1

kgCO₂e/boe, compared with 16.0 kgCO₂e/boe in 2023.

Given the small size of the upstream and floating

production, storage and offloading (FPSO) portfolio,

further fluctuations in the portfolio-level operational

emissions intensity are likely in 2025 and going forward;

however, we expect that it will stay well below the IEA’s

global benchmark, driven by our pan-European focus

and the significant share of midstream clients in our

portfolio. The latter generally exhibit lower emissions

intensity than upstream operations, which is one of the

factors contributing to our emissions intensity being

below the benchmark. We continue to assess our

policies and targets based on IEA updates.

For this sector, the actions align with those outlined in

the Climate Strategy section and other general actions

taken that are applicable across all sectors. This year,

we focused on enhancing the TRA, supported by the oil

and gas pilot.

Maritime transport – deep-sea shipping

Benchmark is DNV 1.5°C Initiative, Scenario 10

Weighted Climate Alignment in %

Target is to be fully aligned with

DNV 1.5 trajectory, scenario 10

(44% reduction in carbon

intensity by 2030 compared

with 2024)

2021 2024

Deep-sea shipping figures are not yet available for 2025 as the reported emissions

from our clients, which we rely on, are not yet available. We therefore report

progress on this sector with a year’s delay. The above graph illustrates the 1.5°C-

aligned reduction pathway for global deep-sea shipping, based on the Det Norske

Veritas (DNV) 1.5°C trajectory (Scenario 10). To measure alignment in the shipping

sector, we have chosen an intensity metric called the Weighted Climate Alignment

(WCA), shown as a percentage on the Y-axis. The WCA is based on the Annual

Efficiency Ratio (AER), which represents emissions intensity per deadweight ton per

nautical mile. WCA indicates portfolio performance relative to the target AER carbon

intensity, showing the % above, at, or below the 1.5°C trajectory. A lower WCA

reflects closer alignment with the 1.5°C trajectory, while a negative WCA signifies

carbon intensity below the target. The X-axis represents time, from 2021 to 2050.

¹⁰ WCA measures the portfolio’s overall alignment with the target trajectory. Therefore, 0 means in line with reduction targets, negative means

overperformance and positive means underperformance.


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≡	Sustainability Statements	Environment	Climate change

Our target metric, WCA, tracks our portfolio's alignment

with the DNV trajectory. Starting from a baseline WCA,

of 0.3% in 2021, we achieved a reduction to -2.1% in

2024, 10 surpassing our reference trajectory and

demonstrating our ongoing efforts to reduce emissions.

This progress is the result of initiatives such as financing

efficiency and optimisation technologies, as well as new

constructions designed for alternative fuels.

To stay aligned with the DNV 1.5°C trajectory, we need

to achieve a 44% reduction in emissions intensity by

2030 relative to 2024, which requires greater efforts.

We plan to accelerate progress by further shifting the

portfolio towards lower-emission vessels and

supporting additional decarbonisation initiatives. See

the section below, where some key actions are

highlighted.

Details on the target's scope and calculation

methodology can be found in the Definitions section.

The DNV trajectory (Scenario 10) uses a bottom-up

approach, incorporating regulations through 2026 and

addressing challenges such as retrofit capacity and

alternative fuel availability. This results in a

decarbonisation pathway that slows until 2026,

accelerates towards 2030, and aims for net-zero

emissions by 2050.

Key actions to reach our target

See the Climate Strategy section for actions taken that

count for all sectors. The following actions apply to the

entire deep-sea portfolio and across our offices in the

Netherlands, Greece and Norway.

Supporting our clients’ transition journey:

• Decarbonising shipping demands a transition to

alternative fuels and technologies, which we support

by financing sustainable retrofit technologies and

dual-fuel vessels for methanol and ammonia.

Aligning processes and policies:

• The Shipping Climate Dashboard enables us to have

clarity on the emission intensity at the asset, client

and sector levels, which allows us to direct our efforts

towards (for example) outlier vessels and clients, by

reconsidering financing these assets, lowering the

corresponding loan amounts and/or engaging in

meaningful dialogues with the clients to make

efficiency improvements. In 2025, all new

transactions (refinancing and new financing) were

evaluated based on the emission intensity of the

financed vessels compared to the decarbonisation

trajectory. This active steering is expected to help

align the portfolio with the climate strategy targets.

Maritime transport - inland shipping

Benchmark is IEA NZE 2050 Transport scenario

gCO2e/tkm

30% reduction in carbon

intensity by 2030

compared with 2025

2023 2025

The graph shows the 1.5°C-aligned reduction pathway for transport (freight &

shipping) based on the IEA’s Net-Zero Emissions (NZE) 2050 scenario. CO2

equivalent emissions in grams per tonne-kilometre (tkm) are on the Y-axis, with time

on the X-axis from 2021 to 2050. It presents the average carbon emissions per

tonne-kilometre expected for IEA NZE 2050-aligned organisations.

In the absence of a recognised benchmark for our

Dutch inland shipping portfolio, we use the IEA freight

and shipping benchmark. While this global benchmark

combines maritime shipping and trucking emissions

into a low baseline, it does not fully reflect the activity

or geographic focus of our Dutch inland shipping

portfolio. These differences explain why our portfolio's

intensity exceeds the pathway, resulting in a higher

baseline and our 2030 target not aligning with the

1.5°C reduction pathway. However, our objective

remains to converge with it before 2050.

In 2025, our emissions intensity changed slightly,

reaching 26.0 gCO2e/tkm compared with 26.2 gCO2e/

tkm in 2024. This small decrease is explained by

improved data quality and a change in portfolio

composition in terms of tonnage, with larger and more

efficient ships carrying more weight in the portfolio in

2025 compared with 2024. While we expect the

decarbonisation initiatives launched this year to have an

impact on the actual emission intensity of the vessels

financed, the absence of precise fuel usage data

constrains our ability to quantify this impact on portfolio

performance. Details on the target's scope and

calculation methodology can be found in the Definitions

section.


ABN AMRO	Annual Report 2025	229


≡	Sustainability Statements	Environment	Climate change

Key actions to reach our target

See the Climate Strategy section for actions taken that

count for all sectors. The actions specific to this sector

are listed here.

Supporting our clients’ transition journey:

• We support our clients in transitioning to net-zero by

discussing various levers, including biofuels,

repowering and sustainable retrofitting or new builds

with hybrid or alternative propulsion systems. The

process involves assessing factors such as the vessel, its

routes and operational patterns to identify the most

suitable and cost-effective solution, with the transition

period customised to each client’s unique needs.

• In 2025, we launched the Improvement Incentive

(‘Verbeterstimulans’ ) for the inland shipping sector to

encourage business owners to strengthen the

resilience and ESG of their operations. In the previous

year's Annual Report, this incentive appeared under

the name ‘label leap’, which has now been updated to

Improvement Incentive. Designed in collaboration

with EICB (the Expertise and Innovation Centre for

Dutch Inland Shipping), this initiative provides

additional support to help our business clients future-

proof their operations. It offers benefits such as

interest rate discounts or adjusted loan tenors tied to

the clients' efforts in achieving specific improvement

goals. These goals, achieved through initiatives such

as using biofuels and adopting zero-emission

shipping practices, result in a better label and lower

GHG emissions at vessel and portfolio level. Although

it is too early at present to assess the success of this

initiative, since the launch we have seen a positive

uptake of this initiative among our business clients.

We aim to refine it in the coming years while

engaging with industry and government.

Furthermore, the action outlined for collaboration in last

year's Annual Report is still relevant; however, it is now

addressed centrally under the Climate Strategy section.

Agriculture

Benchmark is Dutch Coalition Agreement (2021)

Financed mtCO2e

5% reduction in carbon

intensity by 2030

compared with 2025

2022 2025

In the graph above, the amount of financed CO₂ equivalent in megatons (mt) is

depicted on the Y-axis. Time is represented on the X-axis, from 2021 through 2040.

Because we follow the Dutch Coalition Agreement’s benchmark scenario, the

pathway for agriculture only goes until 2030. As the Dutch Coalition Agreement’s

benchmark scenario ends in 2030, the agriculture pathway does not extend beyond

that year.

ABN AMRO follows the Dutch Coalition Agreement

(‘well below 2°C’) scenario for the agriculture sector,

which aligns with the EU’s Fit for 55 plans. Although this

scenario aligns with our recently announced intentions

to update our climate strategy to a well below 2°C

pathway, we will continue to strive for 1.5°C alignment

in the agricultural sector once a national benchmark

becomes available that meets this ambition. Clear

government policy is essential to give farmers the clarity

needed to adapt their business models and income

strategies.

Our financed emissions decreased from 1.6 mtCO₂e

financed in 2024 to 1.5 mtCO₂e financed in 2025. This

fluctuation is primarily driven by a contraction of our

portfolio resulting from additional redemptions.

Our agriculture target covers five agricultural sub-

sectors within our portfolio: dairy cattle farming, calf

farming, pig farming, horticulture and floriculture. These

sub-sectors were chosen due to their financial

materiality in our portfolio, as well as the significant

volume of carbon emissions associated with activities in

these sub-sectors.

In 2025, we initiated a climate scenario analysis on the

dairy cattle sub-sector to assess the transition-related

credit risk effects on our corporate lending exposure to

this sector. Details on the target's scope and calculation

methodology can be found in the Definitions section.


ABN AMRO	Annual Report 2025	230


≡	Sustainability Statements	Environment	Climate change

Key actions to reach our target

While our target covers multiple sub-sectors, we have

chosen to concentrate our actions on Dairy (NACE

A01.41), which represents a significant share of the

sector’s emissions. In this targeted approach, we aim to

collect external client-level data over the course of

2026. This will allow effective and impactful

engagement with clients where necessary.

Supporting our clients’ transition journey:

• In 2025, we approved our internal guidance

document, the ‘Dairy Transition Plan’, which provides

strategic guidance for ABN AMRO teams serving the

dairy farming sub‑sector. It aims to support clients in

achieving sustainable development, while carefully

considering sector-specific risks, returns and key

impact areas.

• In 2025, we began surveying our clients in this sector

to better understand their emissions. These insights

will help our relationship managers discuss potential

measures to reduce emissions with farmers.

Although the actions described above support our

clients in their transition journey, they do not directly

impact the performance metric for this sector, which is

determined entirely by emission factors rather than

client data.

Furthermore, the actions outlined in the previous year's

Annual Report have been reviewed to assess their

continued relevance. This year, actions related to the

dashboard and engagement are addressed centrally

under the Climate Strategy section. The update to our

internal policies, which provides more flexibility in

structuring credit for agriculture clients, remains

relevant. However, after reassessment, it was not

included as it is not considered a key action for this year.

Road transport – Trucks

Benchmark is IEA NZE 2050 heavy-duty vehicles

gCO2/tkm

21% reduction in carbon

intensity by 2030

compared with 2025

2023 2025

Road transport – Vans

Benchmark is IEA NZE 2050 passenger cars

gCO2/vkm

29% reduction in carbon

intensity by 2030

compared with 2025

2023 2025

The above graph curves represent the 1.5°C-aligned reduction pathway for road

transport with heavy duty vehicles (trucks) and vans from the International Energy

Agency’s (IEA) Net-Zero Emissions (NZE) 2050 scenario. Amounts of CO₂ produced

in grams per tonne-kilometre (tkm) and per vehicle-kilometre (vkm) are on the Y-

axis. Time is represented on the X-axis, from 2021 through to 2050. The graphs

therefore show the average carbon emissions per tonne-kilometre for road transport

by heavy duty vehicles, and per vehicle-kilometre for vans.

We used the 2023 IEA NZE roadmap as a benchmark,

representing global sector decarbonisation by 2050 to

limit global warming to 1.5°C. As this is a global

benchmark, it includes countries such as the US and

Australia, which have a lower emissions per tonne-

kilometre due to high load grades. This contrasts with

Western Europe, which covers the vast majority of our

portfolio, where load grades are lower and more empty

kilometres are driven, resulting in higher emissions per

tonne-kilometre.

Given the additional European challenges, such as

limited truck-charging infrastructure and availability of

long-range electric trucks, we have chosen to follow the

2050 convergence pathway. Our 2030 target is

therefore not on the 1.5°C-aligned reduction pathway;

however, we remain dedicated to reaching net-zero by

2050. To reach our 2050 target, we are reliant on

external developments over which we have limited

control, such as greater availability of electric trucks and

vans with sufficient range, as well as charging

infrastructure along the main European routes.

The emissions intensity for trucks decreased slightly

from 79.9 gCO₂/tkm in 2024 to 77.2 gCO₂/tkm in 2025.

For vans, too, the emissions decreased, from 218.9

gCO₂/vkm in 2024 to 198.3 gCO₂/vkm in 2025. This

decrease is driven by two factors. First, the divestment

of the UK Lease portfolio, which was sold in its entirety

in 2025, lowered the overall emission intensity of both

portfolios, as the UK assets were on average less

sustainable than other assets in the portfolio. This effect

is especially visible in the Vans emissions intensity,

where the UK portfolio accounted for a large

percentage of the assets in scope. Second, both the


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≡	Sustainability Statements	Environment	Climate change

Trucks and Vans portfolios saw an increase in the

proportion of newly financed, more sustainable assets

compared with 2024, which contributed to lowering the

portfolios' emission intensity. After the divestment of

the UK portfolio, our emissions intensities for Road

Transport now cover part of our asset-based lease

portfolios in the Netherlands and Germany.

We aim to assess the impact of disinvestments on our

target when the portfolio restructuring is completed.

This approach will allow us to set more efficient and

realistic targets. This is also applicable to our passenger

cars target below.

In 2025, we performed a freight road transport climate

scenario analysis to assess the transition-related credit

risk effects on our corporate lending exposure to this

sector.

Details on the target's scope and calculation

methodology can be found in the Definitions section.

Key actions to reach our target

See the Climate strategy section for actions taken that

count for all sectors. The actions specific to this sector

are listed here.

We focus our efforts on the segment of our trucks

portfolio where we can achieve the greatest impact.

Other parts of the sector face structural challenges,

including high upfront costs for zero-emission

technologies and limited charging infrastructure, which

make rapid decarbonisation more complex and our

actions therefore have limited impact. At the same time,

EU regulations and incentive schemes are expected to

accelerate progress independently, reducing the need

for direct intervention in those areas.

Supporting our clients’ transition journey:

• We offer favourable terms for financing zero-emission

trucks and vans, which we define as having no direct

tailpipe emissions. Additionally, we finance initiatives

that enable the transition, such as charging

infrastructure, energy storage and green energy

production. We will assess the uptake of these

measures as more data becomes available.

• In 2025 we launched the Switch2ZE pilot, inviting a

select group of clients to replace their fossil-fuel

vehicles with zero-emission (ZE) alternatives. This pilot

supports the decarbonisation of our portfolio while

strengthening long-term client relationships.

The actions outlined in the previous year's Annual

Report have been reviewed to assess their continued

relevance. The action related to financial covenants has

been discontinued as it was determined not to be a

critical condition for our clients. The action related to

engagement with policymakers has been included

centrally under the Climate Strategy section.

Road Transport – passenger cars

Benchmark is IEA NZE 2050 passenger cars, modified to

include scope 2 emissions

gCO2/vkm


	25% reduction in carbon intensity by 2030 compared with 2025

2025

The graph above shows the 1.5°C-aligned reduction pathway for two portfolios

related to financing of passenger cars. The volume of CO₂ in grams per vehicle-

kilometre travelled (vkm) is on the Y-axis. Time is represented on the X-axis, starting

in the base year 2023 and continuing through to 2040. The graph therefore shows

the average grams of CO₂ per vehicle-kilometre travelled for passenger cars that

IEA NZE 2050-aligned organisations are expected to achieve. The benchmark for

passenger cars goes only to 2030 because we modified the IEA NZE 2050 scenario

to include the relevant and associated scope 2 emissions, for which the data is only

available to 2030.

Passenger cars are relatively carbon-intensive, relying

on diverse fuel and engine types: diesel, petrol,

alternative fuels, hydrogen, plug-in hybrids and battery

electric vehicles (BEVs). To address this, the sector must

shift to zero-emission solutions, with BEVs currently

seen as the main option. Various regulatory incentives

are driving the shift to zero emissions.

The European car CO₂ standards aim to slowly phase

out internal combustion engine (ICE) sales over the next

decade in favour of electric vehicles. National policies

such as the Dutch Climate Agreement mandate further

accelerate the transition. Additionally, upcoming

European regulations such as the EU Emissions Trading

Scheme (EU ETS) 2 are expected to offer financial

incentives.

However, the sector faces challenges, including political

volatility at both the national and international levels,

which impacts the ability to transition to net-zero in

both the short and the longer terms. Effective

enforcement of existing regulations will be key to

decarbonising ABN AMRO’s passenger car portfolio.

Both our 2023 baseline and our current performance

and 2030 target emissions for passenger cars are below

the benchmark scenario’s 2030 level, reflecting the

higher share of zero-emission vehicles in our

predominantly Western European portfolio compared

¹¹ WACI is used to quantify the carbon emissions of a portfolio by looking at the carbon intensity of the underlying holdings relative to their revenues. Its

value is then used to compare the carbon intensity of the model portfolios to the carbon intensity of the respective benchmark.


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≡	Sustainability Statements	Environment	Climate change

with the rest of the world. For 2030, we are targeting a

35% reduction in emission intensity compared with our

2023 baseline, bringing our emission intensity down to

63.0 gCO₂/vkm. In 2025, our emission intensity was

83.8 gCO₂/vkm, and for 2024 this was 96.3 gCO₂/vkm.

The decrease in emission intensity follows the same

trend as that of trucks and vans, caused partially by the

divestment of the UK lease portfolio and partially by a

growing share of newly financed assets with lower

emission‑intensity profiles. As a result, the share of

these types of financed assets increased compared with

2024, both for new deals and within the total portfolio.

The exclusion of our Alfam portfolio was another cause

of the decrease: if we had included Alfam, the emission

intensity would have been 93.5 gCO2/vkm.

The portfolio in scope consists of lease contracts for

motor vehicles, and include vehicles in the Netherlands

and Germany. Like trucks and vans, in the previous year

this also included the UK. See that section for more

information.

These countries were selected based on data availability

and alignment with ABN AMRO’s portfolio disclosures.

At this stage, we do not plan to expand the scope of the

passenger cars target. This decision reflects our

recognition of the significant dependence on external

developments and the resulting limitations in our ability

to meaningfully influence progress towards this target.

Details on the target's scope and calculation

methodology can be found in the Definitions section.

Key actions to reach our target

We observe that our portfolio is aligned with broader

sector developments, largely driven by regulatory

changes. EU regulations and incentives are expected to

accelerate sector decarbonisation independently,

contributing directly to the transition of our portfolio

towards net-zero. Importantly, our portfolio’s emission

intensity is already significantly below the benchmark

intensity level. Consequently, the focus of our current

efforts is on advocacy, where we actively engage with

policymakers to ensure our clients are well-informed

and equipped to make considered and sustainable

decisions in response to these developments.

The actions outlined in the previous year's Annual

Report have therefore been discontinued.

Client assets

Range of percentage deviations of equity building block WACI

scores against benchmark

Weighted Average Carbon Intensity (tCO2e/EUR million of revenue)

Ambition 2025:

entire range below -30%

Ambition 2030:

entire range below -50%

2025

The above graph represents the ambitions that ABN AMRO has set with respect to

lowering the GHG emissions of its clients' assets (currently covering direct line by

line equities). The CO₂ equivalent per million euros of revenues is on the Y-axis. Time

is represented on the X-axis.

Client assets are investments made on behalf of

ABN AMRO’s clients. Each dot on the graph stands for

one of the clients’ assets portfolios in scope, and

represents part of our dedication to reducing carbon

emissions. The position of each dot is determined by its

Weighted Average Carbon Intensity (WACI), 11 which is

one of the carbon intensity metrics recommended by

the Net-Zero Investment Framework (NZIF). It is one of

the three primary portfolio level metrics available for

investors to use when setting objectives for and

reporting on portfolio emissions. A higher dot indicates

a portfolio that manages its carbon emissions less

efficiently, while a lower dot represents one with better

carbon emissions efficiency.

Two portfolios are currently above the plotted reduction

pathway; one remains roughly 38% below its 2019

benchmark and therefore does not pose a concern in

reaching our set ambition, while the other is currently

elevated due to the onboarding of a high‑emissions

manufacturer. Having adopted a sector‑leading climate

strategy that we believe will align in the long term with

our set pathway, this manufacturer was included in the

portfolio.

Details on the target's scope and calculation

methodology can be found in the Definitions section.

Since we first embarked on these efforts in 2022, net-

zero and decarbonisation frameworks have steadily

matured. As part of this evolution, for 2025 we

identified an opportunity to refine our measurement

approach by setting a clear baseline. Previously, the

ambitions for 2025 and 2030 were shown as the

¹² The benchmarks used for each portfolio represent a proxy to the equity investment universe in 2019.


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≡	Sustainability Statements	Environment	Climate change

percentage difference compared with the market at

that moment. Now, in line with current guidance and

science-based net-zero investment frameworks, we

have shifted from a moving benchmark to a fixed 2019

baseline and have aligned our reduction pathway with

the Intergovernmental Panel on Climate Change (IPCC)

Special Report (SR) 1.5°C scenario. The change in our

baseline recognises the head start we had with our

climate ambitions due to our strong ESG process.

To measure our progress against our ambitions, we

compare the WACI of each model portfolio to the WACI

of the portfolio-specific benchmark 12 at the end of

2019. The 2019 value of the benchmark represents the

baseline which we use to compare the reduction

pathway of our portfolios, which is the IPCC SR 1.5°C

scenario that represents our chosen trajectory for

reaching net-zero by 2050. Based on this scenario, our

two intermediate ambitions are: to be -30% below the

baseline in 2025, and to be -50% below the baseline in

2030. After 2030, we aim for an average 7% year-on-

year reduction working towards net-zero by 2050.

With a total of EUR 129 billion (31 December 2025) of

client assets in securities, excluding HAL, our clients'

investments make a significant contribution to

emissions. To achieve our ambitions, we engage with

our investees and manage our portfolio, using the

WACI. Over the past year, the evolution of the WACI in

most portfolios has primarily been influenced by

changes in existing positions in companies with high

carbon intensity. Given that we see a trend of the

portfolios in scope moving in the direction of the

ambition, we believe we are on track to reach the

ambition.

We began with initiative centres on our Discretionary

Portfolio Management (DPM) portfolios, where we have

discretion on investment decisions. DPM portfolios

account for approximately 41% of client investment

securities. Within these portfolios, approximately 21%

of the securities consist of direct line-by-line equities,

which currently define the scope of our climate

ambition. In 2025, three new portfolios were added to

the reporting scope, for a total of 15 portfolios. The

scope of our current climate strategy covers

approximately 9% of our client assets in securities.

Please note that HAL securities are not in the climate

strategy scope for 2025.

The integration of climate metrics within the DPM

equity investment process is based on three steps:

i. Integrating climate indicators into equity analysis: the

teams have access to a broad range of data points

that can be analysed for any new stock ideas.

ii. Testing portfolios prior to transactions: the teams

have access to a tool allowing them to see what the

impact of a potential transaction might be on the

portfolio WACI.

iii. Monitoring the portfolios: a detailed analysis of the

portfolio WACI is conducted on a regular basis,

providing valuable insight into the biggest

contributors to and drivers of the portfolio WACI.

Key actions to reach our ambition

Supporting our clients’ transition journey:

• We remain actively engaged with investee companies

to address critical ESG-related issues. Our efforts

focus on driving climate action through GHG emission

reductions, evaluating the credibility of transition

plans and resilience to physical climate risks and

improving governance practices and transparency in

disclosures. We work in partnership with EOS at

Federated Hermes Limited, utilising their structured

milestone framework to engage with invested

companies. This framework monitors ESG initiative

progress over 3-5 years, ensuring a systematic

evaluation of their effectiveness.

Aligning processes and policies:

• The ESG Rules and Guidelines (‘ESG R&G’) for

Investment Products have been developed for the

purpose of setting ESG and sustainability criteria for

investment products and services, such as our WACI

climate ambition and the criteria for exclusions on

fossil fuel. The Head of Global Wealth Products is

accountable for its implementation. The ESG R&G

document aligns with ABN AMRO’s sustainability

strategy, the United Nations Principles for

Responsible Investment (‘PRI’), the UN Guiding

Principles on Business and Human Rights and the

OECD Guidelines for Multinational Enterprises.


ABN AMRO	Annual Report 2025	234


≡	Sustainability Statements	Environment	Climate change

Climate risk

Climate risks are deemed material in relation to our

clients (downstream: physical and transition risks) and

own operations (physical risk) as per the 2025 DMA (see

the section on Determining financial materiality of risks).

Climate risks are managed as explained under the Risk

management of ESG matters section.

Effect of climate risk on traditional risk types

The financial impact of climate risks was assessed as

material for credit risk, business risk and non-financial

risk, and as not material for market risk trading book,

market risk banking book and liquidity risk.

ESG risks are integrated into the regular risk

management processes of relevant traditional risk

types. Accordingly, related to each traditional risk type

there is responsibility for identifying, assessing,

monitoring and reporting on material ESG risks related

to their risk type, in accordance with the ESG risk

management framework and as per the risk policies in

place to manage ABN AMRO’s ESG matters. (For more

information, see the Risk management of ESG matters

section above.)

Credit risk

In relation to our corporate lending activities, climate

transition risks are assessed as material in the long term.

The governmental carbon reduction policies are

expected to lead to higher costs for our corporate

clients operating in vulnerable sectors (downstream),

negatively impacting their financial position and

creditworthiness.

Such risks are assessed, monitored and to the extent

possible mitigated, throughout the credit risk

management process, via ESG risk assessment during

new client take-on and credit approvals, client

engagement, monitoring of climate risk KRIs (see the

Risk management of ESG matters section), provisioning

and capitalisation. Effects of climate physical risk on the

residential and commercial real estate portfolios are

also closely monitored in accordance with the

regulatory requirements. See Current and anticipated

effects of risks and opportunities for more information

on provisioning and capitalisation.

Business risk

Climate transition risk is assessed as material in the long

term. Climate policies, technology, innovation and

changes in client behaviour can impact our products

and services (own operations), as well as our earnings

from the sectors vulnerable to the climate transition

(downstream). For more details on these risk drivers, see

the Business risk section. We assess the resilience of our

business model to these risks, and use our climate

strategy and portfolio steering to mitigate them.

Resilience of our business model and strategy is

disclosed in further detail in the section on Current and

anticipated effects of material matters - Effect on

strategy and business model. ESG matters have not yet

been explicitly integrated in our business risk policy. We

aim to address this in the next regular policy update.

Non-financial risk

We consider climate physical risk and climate transition

risk to be material at all time horizons. In our own

operations, data centre failure and greenwashing are

considered material risk events. Greenwashing refers to

the risk that our sustainability-related statements or

actions do not clearly and fairly reflect the underlying

sustainability profile of ABN AMRO, its products and its

services, and may therefore be misleading to our clients

or other stakeholders. Our committees review our

public disclosures for greenwashing risks. Periodic

reviews of our product disclosures, policies and

standards and staff training events also consider this

risk and how to mitigate it. In our downstream value

chain, the duty of care relating to our residential

mortgages’ portfolio is assessed as material. This refers

to climate risks such as the foundation risk assessed

under our climate scenario analyses for our mortgage

portfolios. We mitigate the duty of care risk by

monitoring litigations and by investing in client

awareness and data quality. The identified risk drivers

(transmission channels) for these risks are legal costs,

cost of compliance, operational losses and expenses.

Material climate risks in our business operations were

considered in the economic capital calculation and the

ICAAP stress test. The Non-financial risk section of the

Risk, capital & funding chapter provides further

information on management of non-financial risk types.

Climate risk management processes

Climate risk management takes place at all stages of

our ESG risk management framework. In this section,

we highlight quantitative insights from our climate risk

management processes.

Our environmental and social heatmaps relating to

climate risks enable us to identify corporate clients

(downstream) or suppliers (upstream) operating in

sectors vulnerable to climate risks. Through climate

scenario analyses, we assess the risks under our client

portfolios, particularly in residential and commercial

real estate sectors (downstream). Breaking down our

portfolios by energy label and GHG emissions enables

us to measure our progress.


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≡	Sustainability Statements	Environment	Climate change

Climate risk heatmap

The climate risk heatmap evaluates the sensitivity of

various sectors to climate-related physical and

transition risks, including negative impacts. For physical

risks, sensitivity is based on a combination of sector

characteristics, such as dependence on assets, labour

and ecosystem services, as well as the regional and

country-based exposure to hazards (such as flooding,

heat stress and sea level rise). For our portfolio located

in the Netherlands, we source exposure to flooding

from the Climate Impact Atlas of Climate Adaptation

Services (CAS), relying on 2050 projections, as well as

from Encore (Exploring natural capital opportunities

risks and exposure). For other hazards and geographies,

we source sensitivity estimations from Moody’s ESG

Solutions, relying on projections to 2040.

Both data sources assume a high-emission scenario

(Representative Concentration Pathway (RCP) 8.5

scenario). Transition risk sensitivity is determined by the

sector’s greenhouse gas emission intensity (derived

from PCAF and Global Impact Database sources),

alongside various regulatory, technological and market

parameters. The regulatory parameters function at two

levels:

• at a sector level, where we reference the annual

sector reduction requirements in the Dutch Climate

Agreement (focusing on projections to 2030)

• at a country level, where we refer to the most recent

policy-induced emission reductions targets in the

Environmental Performance Index

The chart below highlights sectors with high or

moderately high sensitivity to one or more of the three

key factors: physical risk sensitivity, transition risk

sensitivity and negative impact.

Climate change heatmap for corporate loans


				31 December 2025
Sub-sector (NACE)	Sensitivity to physical risk	Sensitivity to transition risk	Of which negative impact	Gross carrying amount ³ (EUR million)

Air transport (H)	MH	MH	H	8
Extraction of crude petroleum and natural gas (B)	M	MH	H	211
Food and beverage service activities (I)	MH	L	L	323
Fossil electricity production (D)	M	MH	H	64
Freight transport by road (H)	M	MH	M	820
Indoor growing of crops (A)	MH	M	ML	1,413
Inland freight water transport (H)	MH	H	H	573
Manufacture of animal protein food products (C)	MH	ML	ML	239
Manufacture of basic metals (C)	M	MH	H	235
Manufacture of prepared feeds for farm animals (C)	MH	ML	ML	77
Other Agriculture, forestry and fishing (A)	M	MH	H	586
Other Electricity, gas, steam and air conditioning supply (D)	ML	MH	MH	793
Other transportation and storage (H)	M	MH	MH	651
Raising of cattle (A)	MH	H	H	3,061
Raising of poultry and swine/pigs (A)	M	MH	MH	564
Sea and coastal freight water transport (H)	M	MH	H	4,843
Support activities for petroleum and natural gas extraction (B)	M	MH	MH	1,122
Transport via pipelines (H)	MH	MH	MH	6
Water supply; sewerage, waste management and remediation activities (E)	M	MH	H	611

Other sub-sectors ¹				70,319
Corporate loans ²				86,516


		High (H)		Moderately high (MH)		Moderate (M)		Moderately low (ML)		Low (L)

1. Includes exposures to all other sub-sectors.

2. Excluding loans at fair value through P&L.

3. Gross carrying amount excludes fair value adjustments from hedge accounting.


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≡	Sustainability Statements	Environment	Climate change

The results of the heatmap show that the highest

sensitivities (Moderately high and High) are in the

agricultural (NACE A), mining (NACE B), manufacturing

(NACE C), power generation (NACE D), transport sectors

(NACE H) and food and beverage service activities

(NACE I). Compared to last year, there are no significant

changes in subsector with moderately high or high

sensitivity. As these six sectors are the most sensitive to

climate change, we looked into the more specific sub-

sectors and identified that cattle farming

(EUR 3.1 billion) and sea and coastal freight water

transport (EUR 4.8 billion) had the highest sensitivities

and also represented a large portion of our lending

portfolio. We determine sub-sectors’ sensitivities

regardless of the exposure in our portfolio. The gross

carrying amount indicates our exposure to each sub-

sector, independent of the sensitivity level. The

sensitivity level of a sub-sector feeds into the CASY

questionnaire and determines the level of our

sustainability expectations at client level. This means we

expect better performance on sustainability-related

topics from clients active in sectors with higher ESG

sensitivity. The table above includes only those sub-

sectors that have either a sensitivity or negative impact

of Moderately high or High. As a result, EUR 70.3 billion

is not included in this table.

Sensitivity to physical climate risk

As shown in the geographic concentration table in the

Credit risk review section, our loans are concentrated in

the Netherlands. Correspondingly, our material physical

risk sits mainly in Dutch regions (NUTS classifications:

NL1 to NL4). Our physical risk assessment covers our

corporate loans, residential mortgages and commercial

real estate portfolios and constitutes 97% of our loan

book collateralised by physical assets. This section

provides insights into the physical risk in our corporate

loans portfolio.

For insights into physical and transition risks in our

mortgage portfolio, see the Climate scenario analyses

section.

In relation to the physical risk in our corporate loans

portfolio, the tables below outline the exposure to acute

and chronic risks, categorised along the axes of sector

and geography. Chronic events are associated with

progressive shifts, for which we have used data on heat

and water stress. Acute events are linked to extreme

events such as flooding and wildfires.

Sector and location together determine how sensitive

ABN AMRO is to certain risks. Consolidating sector and

location gives us a more comprehensive view of the

underlying risk drivers relating to climate events. As we

are using this consolidated approach across sector and

location for the first time, we have erred on the side of

caution and used more conservative assumptions. See

the climate risk heatmap, which outlines underlying

data sources, scenarios and timeline assumptions. The

starting point of the physical risk assessment is the

climate hazard exposure to a counterparty’s

geographical location or, where available, its collateral.

The exposure is marked as sensitive to acute or chronic

risks if the location is highly sensitive to one of the

underlying hazards, as per Moody’s ESG Solutions

methodology.

Given the national specifics, an alternative approach is

used for Dutch flooding events. An exposure is

classified as sensitive to acute risk if at least 10% of

buildings in the NUTS region are exposed to flooding of

more than half a metre. For certain sub-sectors prone to

climate risk, we assign a high sensitivity to the lending

exposure and use lower thresholds than those outlined

above. In the case, for example, of counterparties or

collateral located in the Netherlands, we apply a 2.5%

threshold (instead of the 10% threshold referred to

above) to account for sector characteristics such as

ecosystem services.


ABN AMRO	Annual Report 2025	237


≡	Sustainability Statements	Environment	Climate change

Physical risk by industry


				31 December 2025
(in millions)	Exposure located in areas sensitive to impact from chronic climate change effects³	Exposure located in areas sensitive to impact from acute climate change effects³	Exposure located in areas sensitive to impact both from chronic and acute climate change effects³	Exposure located in areas not sensitive to climate change events ⁴	Total gross carrying amount⁵
Agriculture, forestry and fishing	3,368	359	451	2,397	6,574
Mining and quarrying		157	74	1,267	1,499
Manufacturing	872	702	116	3,758	5,448
Electricity, gas, steam and air conditioning supply	420	355	613	1,273	2,661
Water supply; sewerage, waste management and remediation activities	211	5	13	381	611
Construction	192	300	21	2,563	3,077
Wholesale and retail trade; repair of motor vehicles and motorcycles	1,066	1,357	309	4,980	7,712
Transport and storage	600	751	578	5,979	7,908
Real estate activities	1,103	1,822	177	10,087	13,189
Corporate loans in sectors highly contributing to climate change	7,832	5,808	2,352	32,686	48,678
Other sectors¹	2,048	4,233	1,338	30,218	37,838
Corporate loans²	9,880	10,042	3,690	62,904	86,516
				31 December 2024
Agriculture, forestry and fishing	3,333	363	450	2,512	6,659
Mining and quarrying	4	350	66	1,156	1,576
Manufacturing	851	748	613	4,353	6,565
Electricity, gas, steam and air conditioning supply	86	515	328	1,312	2,241
Water supply; sewerage, waste management and remediation activities	270	3	50	342	664
Construction	216	356	53	2,327	2,952
Wholesale and retail trade; repair of motor vehicles and motorcycles	1,110	1,379	299	5,186	7,975
Transport and storage	632	787	591	6,738	8,749
Real estate activities	1,035	1,551	198	8,267	11,052
Corporate loans in sectors highly contributing to climate change	7,539	6,053	2,648	32,194	48,433
Other sectors¹	2,195	4,168	1,718	27,313	35,394
Corporate loans²	9,734	10,221	4,366	59,507	83,827
1. Includes exposures to all other NACE sectors.
2. Excluding loans at fair value through P&L.
3. Chronic events are sea-level rise, water stress and heat stress, and acute events are flooding, wildfires, hurricanes and typhoons.
4. Approximately 30% of these totals concerns exposures where no physical climate data was available.
5. Gross carrying amount excludes fair value adjustments from hedge accounting.

Physical risk by geography

As the physical risk by industry table shows, our largest

exposures sensitive to chronic climate change continue

to be in agriculture, forestry and fishing (EUR 3.4 billion),

wholesale and retail trade (EUR 1.1 billion) and real

estate activities (EUR 1.1 billion). Particularly agriculture

sector exposures located in the northern and eastern

regions of the Netherlands are sensitive to water stress

(an element of chronic risk).

Most of our exposures sensitive to chronic and/or acute

climate change effects are located in the Netherlands

and the rest of Europe, which are the main regions

where we offer our products and services.

In relation to our corporate lending portfolio, financial

effects from climate physical risk were assessed to be

limited and did not result in provisioning.


ABN AMRO	Annual Report 2025	238


≡	Sustainability Statements	Environment	Climate change


					31 December 2025
(in millions)	Exposure located in areas sensitive to impact from chronic climate change effects²	Exposure located in areas sensitive to impact from acute climate change effects²	Exposure located in areas sensitive to impact both from chronic and acute climate change effects²	Exposure located in areas not sensitive to climate change events³	Total gross carrying amount⁴
The Netherlands	8,465	8,122	1,832	31,849	50,268
Rest of Europe	1,029	1,698	1,041	24,687	28,456
USA	313	138	18	674	1,144
Asia	73	83	799	486	1,440
Rest of the world				5,209	5,209
Corporate loans¹	9,880	10,042	3,690	62,904	86,516
					31 December 2024
The Netherlands	8,461	7,916	1,929	31,677	49,983
Rest of Europe	728	2,143	788	21,763	25,422
USA	497	132	42	738	1,409
Asia	48	30	1,606	532	2,216
Rest of the world			1	4,796	4,797
Corporate loans¹	9,734	10,221	4,366	59,507	83,827
1. Excluding loans at fair value through P&L.
2. Chronic events are sea-level rise, water stress and heat stress, and acute events are flooding, wildfires, hurricanes and typhoons.
3. Approximately 30% of these totals concerns exposures where no physical climate data was available.
4. Gross carrying amount excludes fair value adjustments from hedge accounting.

Climate scenario analyses

We consider climate scenario analyses in medium- and

high-risk sectors as per our environmental and social

risk heatmaps to further investigate portfolio-specific

risks. In 2025, we performed climate scenario analyses

of our residential real estate, commercial real estate

and road transportation portfolios.

The analyses of our residential and commercial real

estate portfolios were performed against several long-

term (to 2050) climate change scenarios. They assessed

physical (e.g. floods, foundation problems, wildfires,

heat stress) and transition (e.g. policy changes and

technological shifts impacting industries) risk events

and considered risks in climate adaptation plans. The

underlying assumptions reflected a high-emission

scenario, where no additional efforts are made to

constrain greenhouse gas emissions.

For the physical risk assessment, vulnerability was

defined, among others, as clients with high loan-to-

value and loan-to-income ratios, and collateral with an

energy label of D or lower. The impact of climate risk

events on clients’ creditworthiness was assessed and

calculated in terms of RWA and provision requirements.

The outcomes of the assessment served as an input for

the financial materiality assessment.

For more information on this, see Determining financial

materiality in the Strategy and Business Model section.

Scenario choice and data

Foundation problems are an important driver of

physical climate risk in the Dutch real estate sector.

Property-specific data on foundation risks was obtained

from the Kennis Centrum Aanpak

Funderingsproblematiek (KCAF). Granular data on the

other physical climate risk drivers (flooding, wildfires

and heat stress) was obtained from Climate Adaptation

Services (CAS). The CAS data is partly based on

scenarios provided by the Royal Netherlands

Meteorological Institute (KNMI), which closely align with

the Network for Greening the Financial System (NGFS)

current policies scenario.

Results

The tables show the risk distribution of our commercial

real estate (CRE) and residential real estate (RRE)

portfolio exposures for four climate-related risks:

foundation risk, flood risk, wildfire risk and heat stress

risk. The analysis was performed by measuring the

chances of the risk events occurring during the years to

2050 for buildings in the Netherlands. The probabilities

of foundation problems are grouped into five buckets:

no risk, low risk, medium risk, high risk and no available

data.


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≡	Sustainability Statements	Environment	Climate change

Commercial real estate


							31 December 2025
	Acute				Chronic
	Wildfire risk		Flood risk		Heat stress risk		Foundation risk
(in millions)	Gross carrying amount¹	Percentage of total	Gross carrying amount¹	Percentage of total	Gross carrying amount¹	Percentage of total	Gross carrying amount¹	Percentage of total
No risk	8,725	64%	6,365	47%	1,139	8%	6,819	50%
Low risk	496	4%	3,655	27%	1,491	11%	2,036	15%
Medium risk	1,467	11%	857	6%	5,895	43%	1,876	14%
High risk	235	2%	45	0%	2,397	18%	295	2%
No available data	2,716	20%	2,716	20%	2,716	20%	2,613	19%

							31 December 2024
No risk	9,607	73%	6,804	52%	1,155	9%	7,034	54%
Low risk	389	3%	3,917	30%	1,623	12%		0%
Medium risk	1,483	11%	978	7%	6,480	49%	4,496	34%
High risk	268	2%	49	0%	2,489	19%	336	3%
No available data	1,356	10%	1,356	10%	1,356	10%	1,238	9%
1. Gross carrying amount excludes fair value adjustments from hedge accounting.

13% of our CRE portfolio has a medium or high risk of

being impacted by wildfires. This is mainly in the

regions around the Veluwe forest and the dune regions

along the Dutch coast. On the other hand, 68% of our

portfolio has no risk or a low risk of wildfires. As

experienced around the world in 2025, the combination

of prolonged drought, low humidity and rising

temperatures is resulting in increasing numbers of

wildfires. Any actual damage caused by wildfires will be

covered by the insurance required for the financed

buildings.

Almost half the buildings in our CRE portfolio are not at

risk of being flooded by the type of floods measured by

the flood risk analysis. A small part of our portfolio (6%)

has a medium or high chance of being impacted by a

flood. The risk of flooding is highest in the regions

around rivers and the Wadden Islands.

The table shows that 61% of our portfolio has a

medium or high risk of being impacted by heat stress.

Urban areas of the Netherlands are considered

particularly likely to experience heat stress.

Heat stress depends on the type of building and is

reduced by preventing sunlight from shining directly

into the building. Measures such as sun blinds, shade

provided by trees, floor cooling and water supplies can

mitigate this risk.

In our CRE portfolio 16% of the exposure has a medium

or high foundation risk. This is due to the location of the

buildings in areas of peat or clay such as Amsterdam,

Rotterdam and Utrecht, and the use of wooden poles

for foundations. Almost all properties with foundation

problems are built on peat soil and were built before

1970. Due to a change in the risk assessment, 15% of

the exposure moved from the medium risk bucket to

the low risk bucket compared with 2024. These risks

are referred to as chronic physical risks and reflect

longer-term shifts in climate patterns. These risks are

not insurable in the Netherlands.

The overall risk levels associated with the identified

climate‑related risk remain broadly consistent with

those reported for the previous year. This stability

reflects the largely unchanged composition of the

portfolio. The only notable deviation concerns the

foundation risk, where an apparent decrease in

medium‑risk exposure is observed. This reduction is the

result of a refined categorisation that now differentiates

more clearly between low‑ and medium‑risk levels,

rather than an underlying shift in the actual risk profile.


ABN AMRO	Annual Report 2025	240


≡	Sustainability Statements	Environment	Climate change

Residential real estate


							31 December 2025
	Acute				Chronic
	Wildfire risk		Flood risk		Heat stress risk		Foundation risk
(in millions)	Gross carrying amount¹	Percentage of total	Gross carrying amount¹	Percentage of total	Gross carrying amount¹	Percentage of total	Gross carrying amount¹	Percentage of total
No risk	109,843	67%	87,802	54%	23,821	15%	74,177	45%
Low risk	11,707	7%	53,214	33%	51,320	31%	67,113	41%
Medium risk	34,377	21%	17,336	11%	74,942	46%	15,175	9%
High risk	3,143	2%	717	0%	8,985	6%	4,008	2%
No available data	4,116	3%	4,116	3%	4,116	3%	2,712	2%

							31 December 2024
No risk	103,341	66%	82,994	53%	22,212	14%	70,151	45%
Low risk	11,019	7%	50,014	32%	49,167	31%		0%
Medium risk	32,849	21%	16,514	11%	70,707	45%	79,750	51%
High risk	3,006	2%	693	0%	8,130	5%	3,486	2%
No available data	5,993	4%	5,993	4%	5,993	4%	2,822	2%
1. Gross carrying amount excludes fair value adjustments from hedge accounting.

The Residential real estate (RRE) table shows the

exposure of the RRE portfolio to physical risks,

subdivided into four risk classes based on the likelihood

of each specific physical risk event occurring.

For wildfires, the susceptibility of regions to wildfires is

subdivided into risk classes. 67% of the portfolio has no

risk of wildfires occurring that impact the collateral, as

these collaterals are located in areas with negligible

chances of wildfires occurring. On the other hand, 23%

of the portfolio is expected to have a medium or high

susceptibility to wildfires by 2050. If a building is

impacted by a wildfire, the damage is estimated to be

equal to the rebuild value.

Flood risk is present around the coasts and lakes, but it

is most prominent around rivers. As only floods with

a minimum flood depth of 50 cm have a meaningful

impact on collateral damage, this table only contains

floods with a minimum depth of 50 cm. 54% of the

portfolio has no flood risk at all, while 33% has a low

risk of a flood occurring between now and 2050. Only

11% has a medium or high risk of floods occurring

between now and 2050. The damage associated with

a flood event can be estimated at EUR 1,730 on

average per square metre.

Heat stress is largely determined by the location and

quality of the building as well as the amount of adaptive

measures taken to mitigate the effects of heat stress.

Although heat stress does not cause damage to the

collateral, it could have an impact on the client and on

the collateral value. As the Netherlands is a densely

populated country, 52% of the portfolio has a medium

or high risk of experiencing the effects of heat stress by

2050. However, adaptive measures can be taken to

mitigate these effects.

The final physical risk denoted in the table is the risk of

foundation damage occurring until 2050. The

December 2025 risk subdivision deviates significantly

from the December 2024 risk subdivision, due to a

change in the risk assessment by KCAF. This change in

risk assessment caused 41% of exposure to move from

the medium risk bucket to the low risk bucket. This

means that currently 11% of the portfolio is expected to

have a medium or high risk of foundation damage

occurring between now and 2050. Most of these

buildings with potential foundation problems are

located on peat soil and were built before 1970, with

the result that the foundations are of poorer quality.

As the probability of foundation damage can be

amplified or lessened by long-term shifts in climate

patterns, the risk assessment can be complex rather

than straightforward. Foundation risk is a chronic

physical risk that is not insurable in the Netherlands. In

the event of foundation damage, the repair costs for an

average property could be as high as EUR 2,500 per

square metre.

We monitor our exposures to the climate physical risks.

See the section on the ESG risk appetite - key risk

indicators.


ABN AMRO	Annual Report 2025	241


≡	Sustainability Statements	Environment	Climate change

Breakdown of commercial real estate portfolio by energy label


			31 December 2025				31 December 2024
(in millions)	Gross carrying amount	- of which EPC label³	- of which estimated label	Percentage of total	Gross carrying amount	- of which EPC label³	- of which estimated label	Percentage of total
Higher than A	3,501	3,346	155	26%	2,841	2,660	181	22%
A	3,685	3,260	424	27%	3,696	3,295	401	28%
B	902	753	149	7%	918	815	103	7%
C	1,434	1,188	246	11%	1,530	1,291	239	12%
D	852	470	381	6%	708	513	195	5%
E	452	340	112	3%	484	380	104	4%
F	249	126	123	2%	310	172	137	2%
G	700	241	459	5%	1,233	300	933	9%
No label¹	876			6%	318			2%
Unknown label²	987			7%	1,066			8%
Total	13,638	9,725	2,050	100%	13,104	9,427	2,293	100%
1. Relates to asset types e.g. Parking, Land, Monuments and Properties meant for storage or processing, for which no energy labels are applicable. Wherever energy labels are available for asset types which are EPC eligible but not EPC applicable, the energy label is reported if available.
2. Relates to asset types which are expected to have an energy label.
3. Including both energy labels based on the applicable regulation before and after 1 January 2021.

An energy label indicates how energy-efficient a real

estate property is. The most energy-efficient category is

higher-than-A and the least energy-efficient category is

label G. The EPC labels in the table are from the

Netherlands Enterprise Agency (RVO) and consist of

a combination of energy labels under the old

methodology (NEN7120, before 1 January 2021) and

the new methodology (NTA8800). Where no official

energy label was available, we used the preliminary

energy labels, as issued by RVO in 2015, as the

estimated label.

As part of its climate strategy, ABN AMRO has set

targets to reduce the carbon footprint of its CRE

portfolio. ABN AMRO continues to work towards this

goal by seeking to increase the A and higher-than-A

energy labels in the CRE portfolio and lowering the

exposure to D-G energy labels. See the Climate strategy

section above for our targets.

In line with this strategy, the distribution of real estate

with an energy label higher than A and with energy

label C or higher improved to 26% and 71%

respectively (2024: 22% and 69%).

Similar to the previous year, 87% of assets in the

CRE portfolio had an energy label. Most energy labels

are the official registered labels supplied by the

Netherlands Enterprise Agency (Rijksdienst voor

Ondernemend Nederland). The estimated labels consist

of both outdated registered labels and estimated labels

provided by external providers. Out-of-scope assets

(such as land, parking and storage spaces) are assigned

to ‘No label’ and approximately 7% have an unknown

status owing to the property being under development,

not yet being registered or having no estimated label

available.

Breakdown of residential mortgage portfolio by energy label


			31 December 2025				31 December 2024
(in millions)	Gross carrying amount	- of which EPC label³	- of which estimated label	Percentage of total	Gross carrying amount	- of which EPC label³	- of which estimated label	Percentage of total
Higher than A	15,060	11,235	3,825	9%	11,542	6,872	4,669	7%
A	41,715	33,302	8,413	26%	38,768	31,842	6,926	25%
B	22,902	12,957	9,945	14%	21,821	12,043	9,778	14%
C	33,306	17,936	15,370	20%	32,239	17,284	14,955	21%
D	12,734	8,310	4,423	8%	12,333	8,406	3,927	8%
E	8,901	5,336	3,565	5%	8,870	5,571	3,300	6%
F	11,243	4,044	7,198	7%	11,860	4,523	7,337	8%
G	13,687	3,828	9,859	8%	14,480	4,375	10,105	9%
No label¹	1,450			1%	1,514			1%
Unknown label²	2,186			1%	2,782			2%
Total	163,185	96,949	62,599	100%	156,209	90,914	60,999	100%
1. Relates to asset types e.g. Parking, Land, Monuments and Properties meant for storage or processing, for which no energy labels are applicable. Wherever energy labels are available for asset types which are EPC eligible but not EPC applicable, the energy label is reported if available.
2. Relates to asset types which are expected to have an energy label.
3. Including both energy labels based on the applicable regulation before and after 1 January 2021.


ABN AMRO	Annual Report 2025	242


≡	Sustainability Statements	Environment	Climate change

The proportion of residential mortgages with an official

energy label of A or higher-than-A showed an

improvement compared with 2024. This increase was

partly the result of new inflow and migration from

lower-than-A labels to label A and higher-than-A. The

increase in A and higher-than-A labels is consistent with

ABN AMRO’s ambition, as expressed in our climate

strategy, to reduce the carbon footprint of the

residential mortgage portfolio. Refer to the sector-

specific section on residential mortgages for further

details on how we are progressing towards this target.

The percentage of official energy labels increased from

58% in 2024 to 59% in 2025. This was mainly because

new inflow usually has an official energy label, given

that such a label is mandatory at the time of a sale or

purchase. Additionally, based on the Dutch Building

Decree (Besluit Bouwwerken Leefomgeving), new-build

houses have an A+++ label as a minimum.

GHG monitoring

In line with ABN AMRO’s climate objectives, we

measure the greenhouse gas (GHG) emissions that are

associated with our banking activities. These emissions

are classified as scope 3 category 15, and are reported

in this section. The emissions related to our own

operations are reported in the ESG Annex of the

Sustainability Statements. For more detailed information

on the scoping, calculations and data sources of GHG

emissions or other sustainability terms, see the

Definitions section at the end of this Annual Report.

Total GHG emissions were 36,695 ktCO2e. Total

financed emissions for scopes 1, 2 and 3 in our lending

portfolio decreased, mainly due to lower emissions

from corporate loans. Our carbon footprint (emissions

per EUR 1 million invested) for client assets also

decreased. This decrease is mainly caused by an update

in emission factors for sovereign debt. The GHG tables

below provide further details per GHG emission

category.

GHG emissions


GHG emissions (in ktCO 2e)	31 December 2025	31 December 2024
Scope 3 category 15 – emissions of the balance sheet (client's scope 1 and 2) ¹	14,370	17,513
Scope 3 category 15 – emissions of the balance sheet (client's scope 3) ¹	15,310	14,711
Scope 3 category 15 – emissions of client assets (scope 1 and 2) ²	5,941	7,501
Scope 3 category 15 – facilitated emissions (scope 1, 2, and 3)	1,073	855
Total Scope 3 category 15 emissions	36,695	40,579
1. Based on the PCAF methodology, the total assets are used as the denominator, and the gross carrying amount is used as the attribution metric. Assets falling under the climate strategy may deviate from this approach, as they can have their own methodology.
2. The reporting scope of client assets for GHG emissions consists of equity, corporate bonds, and sovereign bonds. Excluding GHG emissions of HAL’s client assets portfolio.

Our financed emissions reporting provides an

approximate view of balance‑sheet emissions to

manage climate risks and to reduce emissions where

possible. Given the announcements that ABN AMRO

intends to sell its subsidiary Alfam and a small part of its

mortgage portfolio, emissions that relate to these

portfolios (37 ktCO2e scope 1 and 2 emissions) are not

included in the 2025 figures.


ABN AMRO	Annual Report 2025	243


≡	Sustainability Statements	Environment	Climate change

GHG financed emissions


							31 December 2025
(in millions)	Gross carrying amount in scope for financed emissions³	Gross carrying amount out of scope for financed emissions³	GHG emissions (in ktCO 2 e)	- of which scope 1 and 2 emissions (in ktCO 2 e)	- of which scope 3 emissions (in ktCO 2 e)	Carbon intensity scope 1 and 2 emissions (in tCO2 e/ EUR millions)	PCAF average data quality score scope 1 and 2 emissions	PCAF average data quality score scope 3 emissions
Cash and balances at central banks		49,486
Financial assets held for trading		2,044
Derivatives		3,933
Financial investments	48,693	3,125	6,846	4,897	1,949	101	1.6	1.0
Securities financing		40,173
Loans and advances banks		2,174
Residential mortgages	163,185		1,093	1,093		7	3.4
Consumer loans at amortised cost¹	2,233	4,033	87	87		39	3.5
Consumer loans at fair value through P&L¹		486
Corporate loans at amortised cost	86,516		21,609	8,250	13,360	95	4.3	4.6
Corporate loans at fair value through P&L	28		1		1	18	5.0	5.0
Other loans and advances customers²	342	5,594	44	44		127	1.0
Equity-accounted investments	233		1		1	1	5.0	5.0
Other assets		11,403
Total assets	301,230	122,451	29,680	14,370	15,310	48	3.4	3.3
1. From 2025 onwards we report CRE consumer loans in scope whereas this was not yet the case in 2024.
2. Including loans and advances customers at fair value through P&L.
3. Excluding fair value adjustments from hedge accounting.


							31 December 2024
(in millions)	Gross carrying amount in scope for financed emissions³	Gross carrying amount out of scope for financed emissions³	GHG emissions (in ktCO 2 e) ⁴	- of which scope 1 and 2 emissions (in ktCO 2 e)	- of which scope 3 emissions (in ktCO 2 e)	Carbon intensity scope 1 and 2 emissions (in tCO2 e/ EUR millions)	PCAF average data quality score scope 1 and 2 emissions	PCAF average data quality score scope 3 emissions
Cash and balances at central banks		44,464
Financial assets held for trading		2,503
Derivatives		4,347
Financial investments	48,155	0	7,010	6,705	305	139	1.8	1.1
Securities financing		26,989
Loans and advances banks		2,053
Residential mortgages	156,209		1,115	1,115		7	3.5
Consumer loans at amortised cost¹	272	7,303	25	25		92	4.0
Consumer loans at fair value through P&L¹	1	599	1	1		922	4.0
Corporate loans at amortised cost	83,827		24,015	9,609	14,406	115	4.3	4.7
Corporate loans at fair value through P&L	30		1	1	1	17	5.0	5.0
Other loans and advances customers²	298	6,191	52	52		176	1.0
Equity-accounted investments	244		5	5		20	5.0
Other assets		10,852
Total assets	289,035	105,301	32,224	17,513	14,711	61	3.4	3.4
1. Only motor vehicle loans are in scope for consumer loans at amortised cost.
2. Including loans and advances customers at fair value through P&L.
3. Excluding fair value adjustments from hedge accounting.
4. As of 2024, we do not report biogenic emissions as these are excluded for CBS and PCAF emission factors due to an update of the methodology and CSRD alignment.

The GHG tables above provide an overview of the assets

that are in scope of GHG emission reporting and the

Partnership Carbon Accounting Financials (PCAF) data

quality score. The lending portfolio’s GHG emissions are

calculated in accordance with the principles set by

PCAF. The exposures reported as out of scope for

financed emissions are due to the lack of available

methodology from PCAF. For sovereign debt, we use

the production emissions of the country, including land

use, land-use change and forestry (LULUCF), as the

basis for reporting. Attribution to our investments is

done by dividing our invested amount by the country’s

PPP-adjusted gross domestic product.

In 2025, total GHG financed emissions decreased to

29,680 ktCO2e (31 December 2024: 32,224 ktCO2e),

primarily caused by the decrease in emissions

connected to corporate loans at amortised cost.


ABN AMRO	Annual Report 2025	244


≡	Sustainability Statements	Environment	Climate change

Financed emissions for residential mortgages decreased

due to shifts to better energy labels and improved data

quality. Of our total assets, 71% of our total assets are in

scope for calculating GHG-financed emissions in line

with PCAF.

Updated PCAF standard

In December 2025, the PCAF Financed Emissions

Standard was updated to include three new asset

classes: Use of proceeds structures, Securitisations and

structured products, and Sub-sovereign debt. We are

currently addressing the applicability of the

requirements related to these new asset classes.

We aim to incorporate the applicable asset classes

during the upcoming years.

GHG financed emissions PCAF data quality score


			31 December 2025				31 December 2024
(in millions)	Gross carrying amount¹	GHG emissions (in ktCO 2 e)	- of which scope 1 and 2 emissions (in ktCO 2 e)	- of which scope 3 emissions (in ktCO 2 e)	Gross carrying amount¹	GHG emissions (in ktCO 2 e)	- of which scope 1 and 2 emissions (in ktCO 2 e)	- of which scope 3 emissions (in ktCO 2 e)
Data quality score 1 (highest)	48,556	8,575	6,592	1,983	44,147	8,454	8,203	252
Data quality score 2	871	1,331	1	1,330	2,412	1,578	968	610
Data quality score 3	109,781	1,864	980	884	100,174	871	871
Data quality score 4	71,807	2,912	2,912	1	67,060	2,075	2,075
Data quality score 5 (lowest)	70,215	14,997	3,886	11,112	75,244	19,246	5,396	13,849
Total in scope	301,230	29,680	14,370	15,310	289,035	32,224	17,513	14,711
Not in scope	122,451				105,301
Total assets	423,681	29,680	14,370	15,310	394,336	32,224	17,513	14,711
1. Excluding fair value adjustments from hedge accounting.

The decrease in the total financed emissions was partly

attributable to the improved data quality. This can also

be observed as a decline in the financed emissions with

a data‑quality score of 5.

Corporate loans in sectors that highly contribute to climate change


			31 December 2025				31 December 2024
(in millions)	Gross carrying amount³	GHG emissions (in ktCO 2 e)	- of which scope 1 and 2 emissions (in ktCO 2 e)	- of which scope 3 emissions (in ktCO 2 e)	Gross carrying amount³	GHG emissions (in ktCO 2 e)	- of which scope 1 and 2 emissions (in ktCO 2 e)	- of which scope 3 emissions (in ktCO 2 e)
Agriculture, forestry and fishing	6,574	6,202	2,876	3,327	6,659	6,577	3,018	3,559
Mining and quarrying	1,499	1,319	510	809	1,576	1,443	582	861
Manufacturing	5,448	3,312	377	2,935	6,565	6,083	1,279	4,803
Electricity, gas, steam and air conditioning supply	2,661	1,097	568	529	2,241	786	321	465
Water supply; sewerage, waste management and remediation activities	611	107	49	58	664	241	95	146
Construction	3,077	543	58	485	2,952	556	66	490
Wholesale and retail trade; repair of motor vehicles and motorcycles	7,712	1,473	91	1,381	7,975	1,461	98	1,363
Transport and storage	7,908	4,077	2,857	1,220	8,749	4,877	3,369	1,507
Real estate activities	13,189	246	174	72	11,052	218	156	63
Corporate loans in sectors highly contributing to climate change	48,678	18,377	7,560	10,817	48,433	22,242	8,985	13,258
Other sectors¹	37,838	3,232	690	2,543	35,394	1,773	625	1,148
Corporate loans²	86,516	21,609	8,250	13,360	83,827	24,015	9,609	14,406
1. Includes exposures to all other NACE sectors.
2. Excluding loans at fair value through P&L.
3. Excluding fair value adjustments from hedge accounting.


ABN AMRO	Annual Report 2025	245


≡	Sustainability Statements	Environment	Climate change

Compared with 31 December 2024, the bank’s total

exposure to sectors highly contributing to climate

change increased by EUR 0.2 billion to EUR 48.7 billion.

The increase comes mainly from the real-estate

activities sector (EUR 2.1 billion) and is counterbalanced

by a decrease in manufacturing (EUR 1.1 billion) and

transport & storage (EUR 0.8 billion) sectors.

Financed scope 1 and 2 emissions decreased to

7,560 ktCO2e (31 December 2024: 8,985 ktCO2e),

primarily due to the lower exposure in the

manufacturing and transport & storage sectors. The

decrease also reflects the updated underlying emissions

data within the existing methodology.

Carbon-related assets


			31 December 2025				31 December 2024
(in millions)	Gross carrying amount³	GHG emissions (in ktCO 2 e)	- of which scope 1 and 2 emissions (in ktCO 2 e)	- of which scope 3 emissions (in ktCO 2 e)	Gross carrying amount³	GHG emissions (in ktCO 2 e)	- of which scope 1 and 2 emissions (in ktCO 2 e)	- of which scope 3 emissions (in ktCO 2 e)
Mining and quarrying	1,333	987	467	520	1,396	1,308	545	763
Manufacturing	5	2		2	6	2		2
Electricity, gas, steam and air conditioning supply	69	41	35	5	105	42	14	27
Carbon-related corporate loans in sectors highly contributing to climate change	1,407	1,029	503	527	1,507	1,352	560	792
Other sectors¹	85,109	20,580	7,747	12,833	82,320	22,663	9,050	13,614
Corporate loans²	86,516	21,609	8,250	13,360	83,827	24,015	9,609	14,406
1. Includes exposures to all other NACE sectors.
2. Excluding loans at fair value through P&L.
3. Excluding fair value adjustments from hedge accounting.

The definition of carbon-related assets follows the

definition for companies excluded from EU Paris-

aligned benchmarks in accordance with Article 12.1(d)

to (g) and Article 12.2 of the Climate Benchmark

Standards Regulation. Carbon-related assets are

therefore our assets and client assets that directly relate

to the financing of the fossil fuel industry (Article 12.1)

or to the financing of companies that are

found or estimated to significantly harm one or more of

the environmental objectives referred in the Taxonomy

Regulation (Article 12.2). See the Definitions of other

sustainability terms section at the end of this Annual

Report for the detailed methodology. Compared with

31 December 2024, the bank’s exposure to carbon-

related sectors decreased from EUR 1.5 billion to

EUR 1.4 billion.

Sectors that highly contribute to climate change – client assets


		31 December 2025		31 December 2024
(in millions)	Amount ^{2, 3}	Percentage of total	Amount ^{2, 3}	Percentage of total
Client assets in sectors highly contributing to climate change¹	53,355	58%	50,089	59%
Client assets in other sectors	38,010	41%	34,831	41%
Subtotal	91,365	99%	84,920	100%
No data available	936	1%	380	0%
Total	92,301	100%	85,300	100%
1. Please refer to the Definitions for the definition of sectors that contribute highly to the climate change.
2. The client assets in scope consist of equity and corporate bonds.
3. Excluding HAL's client assets portfolio.

Carbon-related – client assets


		31 December 2025		31 December 2024
(in millions)	Amount ^{2, 3}	Percentage of total	Amount ^{2, 3}	Percentage of total
Carbon-related client assets¹	5,358	6%	5,568	7%
Non-carbon-related client assets	83,983	91%	76,627	90%
Subtotal	89,342	97%	82,195	96%
No data available	2,960	3%	3,105	4%
Total	92,301	100%	85,300	100%
1. Please refer to the Definitions for the definition of carbon-related assets.
2. The client assets in scope consist of equity and corporate bonds.
3. Excluding HAL's client assets portfolio.


ABN AMRO	Annual Report 2025	246


≡	Sustainability Statements	Environment	Climate change

GHG facilitated emissions


31 December 2025
	Facilitated amount in scope (in millions)	GHG emissions (in ktCO 2e)	- of which scope 1 and 2 emissions (in ktCO2 e)	- of which scope 3 emissions (in ktCO 2 e)	Carbon intensity scope 1 and 2 (in tCO 2 e/EUR millions)	PCAF average data quality score scope 1 and 2 emissions ²	PCAF average data quality score scope 3 emissions ²
In sectors highly contributing to climate change ¹	3,272	245	50	195	15	2.8	3.4
In other sectors	10,200	828	7	821	1	3.1	4.0
Total	13,472	1,073	58	1,015	4	3.0	3.8
1. Please refer to the Definitions section for sectors that contribute highly to climate change.
2. PCAF average data quality score is calculated on the facilitated amount.


31 December 2024
	Facilitated amount in scope (in millions)	GHG emissions (in ktCO 2e)	- of which scope 1 and 2 emissions (in ktCO2 e)	- of which scope 3 emissions (in ktCO 2 e)	Carbon intensity scope 1 and 2 (in tCO 2 e/EUR millions)	PCAF average data quality score scope 1 and 2 emissions ²	PCAF average data quality score scope 3 emissions ²
In sectors highly contributing to climate change ¹	2,109	435	105	330	50	3.7	4.6
In other sectors	8,454	420	9	411	1	3.0	4.4
Total	10,563	855	114	741	11	3.1	4.4
1. Please refer to the Definitions section for sectors that contribute highly to climate change.
2. PCAF average data quality score is calculated on the facilitated amount.

In line with the PCAF guidelines, the GHG facilitated

emissions table shows primary markets (new issuances),

but not secondary markets or the trade in existing

capital market instruments. In addition, only the portion

of primary issuances that are actually facilitated or sold

to investors are in scope of facilitated emissions

calculations. If an issuance is undersubscribed, unsold

securities are not accounted for.

The GHG facilitated emissions table includes all new

public debt and equity issuances facilitated during

2025, as well as equity and debt investments in private

companies. Furthermore, syndicated loans are also

accounted for. Excluded from the scope are sovereigns,

supranationals, agency issuers, securitised products,

covered bonds, green bonds and commercial papers.

Emissions are calculated using the formula outlined by

PCAF, and using a 33% weighting and the transaction

volume over 1 year (2025).

In 2025, the total facilitated amount in scope was

EUR 13.5 billion, while the total emissions amounted to

1,073 ktCO2e. Approximately one fifth of the facilitated

amount in scope is in sectors highly contributing to

climate change.

Climate-related opportunities

Although ABN AMRO is still developing policies on

climate opportunities, our DMA has identified

renewable energy, decarbonisation technologies and

equity and equity-like investments focused on

decarbonisation as material opportunities. We have

established 2030 financing targets for renewables and

early-stage capital to monitor progress, as outlined

below. Sector leads and Corporate Banking’s

Sustainability team developed the financing targets that

are applied across various portfolios. External

stakeholders were not involved in the process, and the

targets have not been independently validated.

Investments in equity and hybrid debt

As part of our climate strategy, a growth target has

been established for early-stage capital by 2030. The

energy transition requires investing in early-stage

companies that have climate change mitigation as a

business objective. Many low-carbon technologies

already exist or are in development, but they often face

funding gaps between research and development,

early-stage adoption and full-scale commercialisation.

Within Corporate Banking, Corporate Investments aims

to provide the necessary capital in exchange for

ownership shares to scale these companies,

accelerating their development and broader

commercial adoption of innovative decarbonisation

solutions.

Progress is reviewed quarterly by Corporate

Investments, and results are aggregated into the overall

Climate Dashboard for all sectors. Investments that are

still on our balance sheet and are not sold yet are

registered mostly under financial investments at fair

value through income and expense. This target is

cumulative, meaning that we count every investment

since the start of the measurement.


ABN AMRO	Annual Report 2025	247


≡	Sustainability Statements	Environment	Climate change


Investments in equity and hybrid debt

	Direct Equity The Sustainable Impact Fund (SIF) facilitates direct equity investments, concentrating on three key areas: the energy transition, the built environment and sustainable consumption.	Fund Investments These are third-party climate- focused funds aimed at ensuring diversification in the climate transition, classified under Article 8 or Article 9 of the EU Sustainable Finance Disclosure Regulation (SFDR).	Hybrid Debt Hybrid debt is provided to a select number of scale-up companies seeking to mitigate climate change, targeting innovative firms with near- term positive cash flows. This assessment is made on a case- by-case basis.


1		2		3
1	We started in 2022, with EUR 145 million.	2	In 2025, we deployed EUR 75 million, comprising EUR 24 million in direct equity, EUR 48 million in fund investments, and EUR 3 million in hybrid debt, bringing the total cumulative capital deployed to EUR 408 million.	3	By 2030, up to EUR 1 billion will be allocated to accelerate the transition to a decarbonised economy.
	We started in 2022, with EUR 145 million.

Renewable energy and decarbonisation

technologies

In 2022, as part of the climate strategy, a target was set

for a lending commitment (drawn and undrawn

amounts) of at least EUR 4 billion for renewables and

decarbonisation technologies by December 2025,

supporting clients' green energy transition. In 2025, we

set an interim target of EUR 8 billion by 2028 as part of

our pathway to EUR 10 billion by 2030. The financing in

scope is identified by the lending teams based on a

predefined list of EU Taxonomy activities, which can be

found in the Definitions of other sustainability terms

section at the end of this Annual Report. To determine

what EU Taxonomy activities are eligible for our target,

ABN AMRO uses the EU Taxonomy substantial

contribution criteria or, alternatively, the sustainability

criteria defined internally for credit and leasing facilities.

Additionally, the target also includes the proportion of

renewable energy within the exposures ABN AMRO

holds towards power generation utility companies. The

share assigned to renewable energy is identified via

EU Taxonomy disclosures in the annual reports of our

power generation utility clients.

Progress is monitored quarterly by management. To

meet our financing target for new energy, ABN AMRO

focuses on financing companies delivering products

and services that are key for the energy transition. Using

our advisory expertise and financing capabilities, we

collaborate with new and existing clients to enable

diverse solutions such as renewable energy generation,

clean fuel manufacturing, low-carbon hydrogen

production, energy storage, clean transportation and

related infrastructure.


Support our clients’ transition to green energy

	Renewable energy This includes activities, assets, infrastructure and projects in the field of and companies dedicated to the development, construction, installation, manufacturing, maintenance, operation or consultancy related to renewable energy sources and storage techniques.	Decarbonisation technologies These are activities involving renewable energy generation, manufacturing of hydrogen, energy storage, clean transport and infrastructure deals within ABN AMRO Corporate Bank’s financing activities, excluding those already categorised under the renewable energy component.


1		2		3		4
1	In 2022, the baseline value of EUR 3.1 billion was incorporated into our climate strategy, and we reached our goal two years ahead of schedule.	2	By the end of 2025 we reached a total commitment of EUR 5.8 billion.	3	Target of EUR 8 billion by 2028.	4	Target of EUR 10 billion by 2030.
					Target of EUR 8 billion by 2028.		Target of EUR 10 billion by 2030.


ABN AMRO	Annual Report 2025	248


≡	Sustainability Statements	Environment	Biodiversity

Biodiversity

The economy and human well-being are deeply intertwined with nature.

Global biodiversity has declined due to linear economic activities,

significantly affecting the functioning of ecosystems and the services they

provide, which are essential to financial stability and human well-being.

This dependence on biodiversity directly affects ABN AMRO and its clients.

Through our DMA, we have defined Biodiversity as a

material matter from an impact materiality perspective.

This is based on its relevance to the sectors we finance,

such as dairy farming and deep-sea shipping, in our

downstream value chain. We are currently investigating

and further specifying the impacts for these sectors.

By providing financial products to our clients, we

support their value creation processes, which directly

impact biodiversity. Negative impact occurs via multiple

drivers of biodiversity loss, affecting sectors in differing

ways. Our approach to biodiversity therefore focuses on

mitigating the impact of our clients’ activities.

ABN AMRO makes use of the transitional provisions for

E4-Biodiversity that were introduced through the

targeted 'quick fix' amendments to the first set of ESRS.

Material matters included in this chapter

Material topics

Type

Linked to portfolio & industries

Topic

Subtopic

ABN AMRO

label

Definition

Type of

materiality

Value chain

identification

Personal

loans &

mortgages

Corporate

loans1

Client assets

Biodiversity

and

ecosystems

Direct

impact

drivers of

biodiversity

loss

Biodiversity

Biodiversity loss caused by

climate change, land-use

change, fresh water-use change

and sea-use change, indirect

exploitation and invasive

species, caused by the activities

of our clients

Negative

impact

Downstream

Impact:

Nitrogen

emissions

Agriculture

(dairy farming),

transportation

& storage

(deep-sea

shipping)

1. The list of sectors depicted is non-exhaustive.

ABN AMROs approach to nature is informed by the

Kunming-Montreal Global Biodiversity Framework

(GBF), which aims to halt and reverse biodiversity loss

by 2030. Under the GBF, governments commit to take

action on several targets with the involvement of the

rest of society. Some of these targets relate in particular

to the financial industry. ABN AMRO aims to contribute

to these targets by integrating biodiversity into relevant

policies and decision-making (Target 14); by assessing

our exposure to biodiversity-related impacts,

dependencies and risks (Target 15) and by identifying

commercial opportunities to support clients where

applicable (Target 19).

To collaborate effectively with stakeholders, we are

actively involved in initiatives such as the Dutch Central

Bank (DNB) Biodiversity Working Group, the Partnership

for Biodiversity Accounting Financials (PBAF) and the

Deltaplan Biodiversiteitsherstel, which focuses on

helping reverse biodiversity loss through stakeholder

collaboration and land user incentives.

Policies related to biodiversity

Negative biodiversity impacts in our downstream value

chain are managed through the ESG Risk Policy

Framework. At the bank level, we exclude the direct

provision of financial products or services to activities

on our Exclusion List, including for biodiversity

considerations. This means that we will not knowingly

provide financial products or services for activities on

our Exclusion List. General biodiversity-related

exclusions apply to activities that result in the

conversion or degradation of protected areas or critical

habitats. Additional biodiversity-related exclusions

specifically address deforestation or pollution.

Biodiversity impacts of corporate clients are assessed

using the Client Assessment on Sustainability (CASY)

questionnaire. The CASY questionnaire includes a

generic requirement and several sector-specific

requirements on biodiversity impacts, which are all

detailed in the Standard with Client Requirements. For

example, clients operating in sectors for raising cattle

and breeding poultry and swine are assessed on their

efforts on manure management. Clients operating in the

deep sea shipping sector are assessed on their ballast


ABN AMRO	Annual Report 2025	249


≡	Sustainability Statements	Environment	Biodiversity

water treatment systems and other sustainable seas

practices.

Actions related to biodiversity

ABN AMRO’s publically disclosed Nature Statement

outlines our principles, which provide the basis for high-

level guidance on the bank's nature actions.

To incorporate nature into our core business,

ABN AMRO continues to assess impacts, dependencies

and risks with regard to biodiversity through the CASY

questionnaire. Moreover, biodiversity considerations are

integrated into credit risk management through client

engagements and due diligence. However, the

quantification of the impact has not been planned yet.

Following the mitigation hierarchy, we prioritise

avoiding negative impacts by excluding loans for

nature-related activities on our exclusion list and

reducing impacts through client dialogues and policies

on client requirements.

We have further improved our sector- and location-

based information actions, including by finalising a pilot

for dairy farming clients to transition to nature-inclusive

or regenerative practices. We have integrated the

biodiversity-related metrics for dairy and arable farming

that were, before 2025, selected in Nature focus track

on agriculture. Nevertheless, in general we are in a

phase of orientation regarding biodiversity-related

metrics.

We have additionally increased our upskilling efforts.

These include publishing an e-learning course on nature

that is available to all ABN AMRO employees. Client-

facing staff have received guidance on assessing

biodiversity impacts and risks, such as training on

biodiversity in the food sector and an event on nature-

inclusive agriculture that bridges the knowledge of

farmers, banks and policymakers.

Metrics and targets related to biodiversity

In recognition of the importance of setting biodiversity-

related targets, ABN AMRO will begin by identifying

material and feasible metrics as a starting point for

setting targets. Our progress is limited by the still

evolving methodologies for aggregated biodiversity

measurement based on entity-level client data. We

remain in an exploratory phase of identifying metrics

and considering targets to enhance our ability to

measure and manage aggregated biodiversity impacts.

While we are able to analyse the primary drivers of

biodiversity loss and their links to our clients’ activities,

the data remains unsuitable for target-setting.

Currently, data from client assessments and

engagement efforts is used to monitor progress and

guide ongoing improvements.


ABN AMRO	Annual Report 2025	250


≡	Sustainability Statements	Social

Social

Directly or indirectly, companies play a role in impacting their own

workforce and their consumers and end-users. It is therefore important

to manage related impacts proactively.

Through our DMA of the Social standards, we have

identified Own workforce and Consumers and end-

users as material topics. In comparison with 2024,

Workers in the value chain is no longer a material topic;

however, relevant information is provided in the ESG

Annex.

We are dedicated to respecting the human rights of all

people who can be affected by our operations and

those of our business relations. We have adopted

specific statements on human rights that guide our

work, and are dedicated to the relevant international

human rights standards such as the UN Guiding

Principles on Business and Human Rights, the ILO

Declaration on Fundamental Principles and Rights at

Work and the OECD Guidelines for Multinational

Enterprises. ABN AMRO follows the human rights due

diligence approach prescribed by these international

standards.

As an employer, ABN AMRO engages with its own

workforce, whose human rights may be affected, and

consults with organisations and/or employee

representation bodies that represent their interests of

the workforce. For example, the Employee Council in

the Netherlands and the European Staff Council directly

represent employees in ABN AMRO's governance.

ABN AMRO also maintains relationships with trade

unions in the Netherlands and, where applicable, in

other countries where we operate.

Under the International Framework Agreement (IFA),

ABN AMRO has pledged to respect ILO Conventions

No. 29 on Forced Labour and No. 105 on the Abolition

of Forced Labour, as well as Convention No. 182 on the

Worst Forms of Child Labour. Every year, in compliance

with the UK Modern Slavery Act, ABN AMRO publishes a

Modern Slavery Statement that details what steps we

are taking to combat modern slavery, including risks of

labour exploitation and human trafficking. ABN AMRO

addresses modern slavery, including human trafficking,

in its Modern Slavery Statement.

¹ Such as contractors and temporary agency employees.

² Private individuals working for ABN AMRO under a contract and under the supervision of a third party and contributing to the core business of

ABN AMRO.


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≡	Sustainability Statements	Social	Own workforce

Own workforce

We need a workforce that is fit for the future and reflects our society.

Our employees are therefore one of the main stakeholder groups that we

distinguish when considering impacts, risks and opportunities.

Material matters included in this chapter

Material topics

Type

Linked to portfolio & industries

Topic

Subtopic

ABN AMRO

label

Definition

Type of

materiality

Value chain

identification

Personal

loans &

mortgages

Corporate

loans

Client assets

Own

workforce

Equal

treatment

and equal

opportunity

Diversity,

equity &

inclusion

Equal treatment and equal

opportunity of workers,

prevention of harassment,

ensuring non-discrimination

within ABN AMRO

Negative &

positive

impact

Own

operations

Not linked to a particular portfolio, sector or

product

Based on the Double Materiality Assessment, we have

identified the impact of Diversity, Equity and Inclusion

(DE&I) as the sole material matter in relation to our own

workforce. See the table above for further details.

In the ‘Own workforce’ category of the ESRS, a

distinction is made between employees (whom we

define as our internal employees) and non-employees

(whom we define as our external employees 1 and non-

employees 2 whose contracts are issued through third-

party suppliers). In this chapter, we explore what

initiatives ABN AMRO has in place to develop and

support its workforce, including targets set within

ABN AMRO to promote diversity, equity and inclusion.

In addition, ABN AMRO applies the quick-fix transitional

provisions to certain own workforce disclosures

regarding collective bargaining coverage in non-EEA

countries, average number of training hours by gender,

percentage of employees that took an entitlement to

family-related leave, and disclosures on non-

employees.

Policies related to own workforce

ABN AMRO has multiple policies in place to address

material impacts on its own workforce.

The policies mentioned below apply to ABN AMRO

Bank N.V. and all subsidiaries, branches and

representative offices under its control globally,

regardless of location, role or seniority level, unless

explicitly stated otherwise and/or subject to legal

restrictions. The Executive Board is accountable for

managing the HR and behavioural risks across

ABN AMRO, with day-to-day management

responsibilities delegated to the Group Risk Committee

(GRC).

HR Risk Policy

ABN AMRO defines the HR risk as part of its risk

taxonomy, which integrates into ABN AMRO's Enterprise

Risk Management (ERM) framework. The HR risk

encompasses the potential challenges ABN AMRO may

face in attracting, developing and retaining the critical

skills and diverse talent necessary to achieve its

strategic objectives. This includes complying with HR-

related laws and regulations. Specific areas of HR risk

cover discrimination, employee relations, health and

safety, remuneration and employee suitability. The HR

Risk Policy is applicable to internal employees, and

where relevant to external employees and non-

employees working for ABN AMRO through third-party

suppliers.

The HR Risk Policy aims to adhere to the principles of

the European System of Central Banks & the Single

Supervisory Mechanism Equality and Inclusion Charter.

This Charter commits ABN AMRO to a workplace free

from discrimination and inappropriate behaviour,

upholding both European Union and national laws. The

HR Risk Policy also refers to DE&I best practices in line

with the Dutch Corporate Governance Code. To guide

employees in ethical behaviour, both within and outside

the organisation, ABN AMRO emphasises its Code of

Conduct alongside HR risk management policies.

Diversity, Equity & Inclusion policy

ABN AMRO's DE&I policy is an integral part of our HR

Risk Policy. This policy reaffirms ABN AMRO's

dedication to fostering a diverse, inclusive and


ABN AMRO	Annual Report 2025	252


≡	Sustainability Statements	Social	Own workforce

equitable workplace by promoting equal opportunity

and focusing on preventing harassment and

discrimination, as well as compliance with local labour

and employment laws. The scope and accountability of

the DE&I policy align with those of the HR Risk Policy.

For non-employees working for ABN AMRO through

third-party suppliers, these principles are reinforced

within the Supplier Code of Conduct.

Our DE&I policy encourages equal treatment and equal

opportunity across all areas of the organisation through

initiatives such as the Diversity Circle and Diversity

Table within the Netherlands, to promote inclusion and

eliminate discrimination. Protected characteristics under

this policy include gender, race, nationality, ethnicity,

age, religion, disability, sexual orientation, union

affiliation, political affiliation and other statuses

protected by applicable laws.

ABN AMRO has integrated its DE&I policy into various

processes to promote inclusivity across the

organisation. For example, ABN AMRO conducts annual

surveys on equal pay for work of equal value. These

surveys focus on identifying and addressing any

disparities in opportunities or pay between women and

men. Procedures aiming to prevent, mitigate and

remediate discrimination are included in the policy, for

example disciplinary actions to be taken if

discrimination is detected.

Behavioural Risk Policy

The Behavioural Risk Policy is designed to safeguard an

enabling and supportive working environment,

empowering internal and external employees to act in

line with ABN AMRO's core values: care, courage and

collaboration, and our Code of Conduct. This policy also

anchors the importance of 'speak-up channels’ for

employees to share concerns and feedback in a safe

and constructive manner. To monitor the behavioural

risk, ABN AMRO conducts employee surveys to gain

insights into their views of the work environment. These

insights help the organisation take targeted action

where needed.

The policy contributes to strengthening ABN AMRO’s

culture and promoting desirable behaviour across all

levels of the organisation. By addressing the

behavioural risk proactively, the policy helps protect our

clients, employees, society and ABN AMRO from

potential negative outcomes, with the aim of upholding

trust and integrity.

Dialogue and engagement with our own

workforce

ABN AMRO has established multiple channels to

engage with its own workforce on a wide range of

topics. Key engagement processes include employee

councils, employee surveys and ongoing interaction

with trade unions. Specific topics, such as development,

performance and personal circumstances, are often

addressed through direct dialogue between the

employee and their line manager.

The DE&I policy, which is accessible to our workforce,

outlines the organisation's involvement in driving

inclusive policies, interventions and activities.

Engagement with employees on DE&I topics occurs

through initiatives such as the Diversity Table and

Circles, ABN AMRO's internal networks, and forums for

employee feedback such as employee advice sessions,

internal surveys, and colleague discussions. These

engagement activities are conducted multiple times

each year. The Executive Board is accountable for

managing the DE&I policy, with day-to-day

management responsibilities delegated to the Group

Risk Committee (GRC).

ABN AMRO is also a signatory of the International

Framework Agreement (IFA) with Dutch trade union

federation FNV and the UNI Global Union. This

agreement formalises ABN AMRO's commitment – and

that of its suppliers – to uphold labour rights and its aim

to ensure a workplace free from discrimination and

harassment. The IFA Monitoring Committee, comprising

ABN AMRO and trade union representatives, provides a

platform for updates on ABN AMRO's adherence to the

IFA and offers unions an opportunity to share

workforce-related insights.

Regular employee surveys are used to determine areas

of success and identify opportunities for improvement

within ABN AMRO. These surveys include questions

about the DE&I policy and employees' perspectives on

its effectiveness. Our own workforce is encouraged to

provide additional feedback or ideas related to DE&I

through our Employee Resource Groups, enabling

ABN AMRO to assess the effectiveness of its

engagement and inclusivity efforts.

For non-employees working for ABN AMRO through

third-party suppliers, the bank opens a Supplier

Conduct Feedback Channel, allowing them a channel to

express their perspectives as well.

Focus groups

We have identified several focus groups within

ABN AMRO Netherlands for our own workforce and

implemented targeted initiatives to support them:

Women

ABN AMRO aims to promote gender equality in

recruitment and remuneration. Each year, ABN AMRO

reviews its compensation practices to ensure that men


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≡	Sustainability Statements	Social	Own workforce

and women receive equal pay for equal work. To attract

more female applicants, ABN AMRO has designed

gender-sensitive job advertisements and aims to ensure

that interviews are conducted by both male and female

interviewers. ABN AMRO has several Women’s

Employee Resource Groups to raise awareness. These

also provide workshops and networking opportunities.

ABN AMRO tracks progress on increasing the number of

women in senior roles. (For more details, see the

Diversity targets table in the Sustainability section of the

Performance on our strategy chapter).

People with a migration background

ABN AMRO supports ethnic and cultural diversity within

its own workforce. ABN AMRO's Cultural Task Force,

comprising directors and senior managers from minority

ethnic backgrounds, develops organisation-wide plans

and initiatives. ABN AMRO’s Diversity Network (DNA)

hosts events that create awareness on several cultural

moments such as Diwali, Keti Koti and Ramadan

Experience. To aid career advancement, we also offer

programmes such as cultural leadership training for

employees from minority ethnic and cultural

backgrounds, helping them navigate their career paths

within the organisation.

People with occupational disabilities

Through our B-Able programme, we identify suitable

job opportunities at ABN AMRO for people with

occupational disabilities. This initiative involves

collaboration with various client units/functions and

consultation with social enterprises such as Onbeperkt

aan de Slag and Ctalents. ABN AMRO participates in a

lobbying group that advocates for people with

disabilities and regularly engages with social

organisations such as the UWV employee insurance

agency. ABN AMRO also has a target to hire a number

of employees with occupational disabilities. (For more

details, see the Diversity targets table in the

Sustainability section of the Performance on our

strategy chapter).

Neurodiversity

Our focus here is on communicating the many

neurodiverse traits and qualities present in our own

workforce with the aim to facilitate their recognition

and overcome stigmas associated with them. Through

the Neurodiversity Network, we aim to coordinate and

integrate efforts that help us achieve the synergy that

neurodiversity offers. We also seek to stimulate and

promote mutual understanding so that we can value,

embrace and celebrate differences and use them to

complement each other.

Identity and gender orientation

ABN AMRO's Pride employee network advocates for the

interests of LGBTIQ+ colleagues and fosters

connections between allies and LGBTIQ+ employees.

The Pride+ Network regularly conducts surveys to

assess inclusion and enable a supportive environment

for LGBTIQ+ employees. The latest survey was

conducted in 2025. The results show that most

employees feel they can be themselves at work and

recognise the organisation’s dedication to diversity and

inclusion. Awareness of the Pride+ Network remains

strong, and many respondents see its initiatives as

contributing to a more supportive environment. The

survey shows encouraging progress and also points to

opportunities for further growth

People with a refugee background

Our Reboot programme offers individuals with refugee

status an opportunity to connect with ABN AMRO

managers. Successful matches lead to paid

employment, empowering refugees to achieve financial

independence and build a stable future. Since 2017,

ABN AMRO has helped 127 refugees find meaningful

employment through the Reboot programme.

Generational diversity

ABN AMRO recognises the value of different

generations working together. To strengthen

collaboration and innovation, we have established the

Generational Compass, which provides comprehensive

information and insights on the four generations:

Generation Z, Millennials, Generation X and Boomers. In

addition, an assessment and toolkit have been created

in order to help teams and managers to create an

inclusive team culture.

There are two Employee Resource Groups focussing on

generations: Young ABN AMRO and the Experienced

Employees Network. Understanding these perspectives

helps us create an inclusive workplace and leverage

diverse experiences to achieve our goals.

Processes to remediate negative impacts

and channels for own workforce to raise

concerns

ABN AMRO has implemented multiple processes to

address and remediate any potential negative impacts

should they arise. Key initiatives include gender equality

and equal pay, training and skills development in DE&I,

behavioural risk policy, measures against workplace

violence and harassment and channels for our own

workforce to raise concerns.


ABN AMRO	Annual Report 2025	254


≡	Sustainability Statements	Social	Own workforce

Gender equality and equal pay

ABN AMRO is dedicated to equal treatment for all

employees and aims to ensure that decisions are free

from biases related to race, nationality, ethnic origin,

religion, disability, gender, sexual orientation, age,

union membership or political affiliation. Our Global

Reward Policy as described in the Remuneration report

emphasises equal pay for work of equal value. Annual

pay surveys focus on identifying and addressing any pay

gaps between women and men, allowing

ABN AMRO to track progress and assess areas for

improvement in pay equity.

Training and skills development in DE&I

ABN AMRO provides training on diversity, equity and

inclusion to promote an inclusive culture and prevent

unconscious bias. Available digitally to all employees

through ABN AMRO’s Academy the DE&I training

curriculum includes modules on Unconscious Bias,

Inclusive Banking, Gender, Culture, Neurodiversity and

LGBTIQ+. ABN AMRO also offers training opportunities

and reverse mentoring programmes where junior

employees from diverse ethnic and cultural

backgrounds mentor senior colleagues to share their

perspectives on advancing diversity and supporting

underrepresented talent. In addition, all new managers

are required to complete the Start2lead programme,

which includes DE&I as an integral part of the

curriculum.

Measures against workplace violence and

harassment

Employees are encouraged to raise concerns or report

incidents through 'speak-up channels’. Various

initiatives, including an e-learning module (mandatory

for leadership), our continuous learning programme

called SHARP, and a speak-up toolkit, inform

employees about these channels and underscore the

importance of maintaining a respectful and safe

environment.

Channels for own workforce to raise concerns

ABN AMRO provides various channels for its own

workforce to express concerns and address needs,

collectively referred to as 'speak-up channels’ (where

applicable and/or subject to legal restrictions):

Inappropriate Behaviour Adviser

Internal and external employees experiencing

inappropriate behaviour – such as harassment,

discrimination, bullying, aggression or violence – can

reach out to the Inappropriate Behaviour Adviser.

ABN AMRO has a zero-tolerance approach to such

behaviour.

The Confidential Adviser Integrity

Internal and external employees who feel their interests

are being compromised or who face challenging

situations they cannot discuss with their line manager

or colleagues can consult the Confidential Adviser

Integrity.

Whistleblowing channel

This channel allows our own workforce to confidentially

report suspected wrongdoings they feel cannot be

addressed through the regular reporting or other speak-

up channels. ABN AMRO’s Whistleblower Policy

protects employees against retaliation, ensuring they

can raise concerns without fear of adverse

consequences. The Whistleblowing channel is also

open to clients and third parties.

Mediation Office

Open to all internal employees, external employees,

managers and teams, the Mediation Office provides an

informal but structured process for voluntary and

collaborative resolution of workplace conflicts, aiming

for sustainable outcomes.

Employee Council Adviser

Employees can approach the Employee Council, a

group of around 50 colleagues who serve as council

members alongside their regular roles. Topics

addressed by the Employee Council include tensions

related to reorganisations, workloads and working

environment concerns.

These channels are communicated to employees

through multiple internal platforms, including

ABN AMRO's intranet, engagement surveys, e-learning

modules and the collective labour agreement.

In the Employee Engagement Survey, internal and

external employees are asked if they understand how to

report inappropriate behaviour. ABN AMRO encourages

employees to freely report any issues through these

available channels. Additionally, the Supplier Code of

Conduct requires a reporting mechanism for non-

employees working for ABN AMRO through third-party

suppliers to report incidents if necessary, via the

grievance mechanisms available at the third-party

suppliers.

Our approach to action towards own

workforce

ABN AMRO takes several actions to mitigate negative

impacts on its workforce and has implemented

procedures that govern initiatives safeguarding against

significant changes resulting in material negative

impacts for our workforce.


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≡	Sustainability Statements	Social	Own workforce

Our DE&I policy aims to create an environment that

welcomes diverse perspectives. When our workforce

reflects the diverse communities we serve, we are more

responsive to clients' expectations and needs. We aim

to create a culture where employees from diverse

backgrounds feel welcome and respected, empowered

to bring their authentic selves to work and recognised

for their contributions to ABN AMRO's growth and

client success.

In March 2025, in response to the US Decree prohibiting

DE&I policies, ABN AMRO’s Executive Board

reconfirmed its dedication to providing all colleagues

with a diverse and inclusive work environment.

The DE&I programme influences policies and practices

across HR, Product Development, Communications,

Social Impact and other areas. We maintain an ongoing

dialogue with employees through surveys, DE&I Circles

and engagement circles to continuously evaluate and

refine our approach to DE&I. Employees are encouraged

to suggest areas of potential impacts through the

various available channels.

ABN AMRO is dedicated to being a place where

individuals can be themselves, while recognising that

some may need additional support or encouragement

to seize opportunities. That is why we focus on creating

equal opportunities for specific groups, including:

• women

• the LGBTIQ+ community

• people with occupational disabilities

• people from migrant and refugee backgrounds

• neurodiversity

• generational diversity

To assess the impact of these efforts, we rely on

employee surveys, quarterly reports and other metrics.


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≡	Sustainability Statements	Social	Own workforce

Below is an overview of all the programmes and

activities related to DE&I that ABN AMRO took for each

focus area in 2025 and that are planned for 2026:


Focus Area	Programmes & Activities 2025	Programmes & Activities 2026 (planned)
General	DE&I Learning Academy: ABN AMRO provides numerous courses, workshops, videos and learning materials that can be followed to improve knowledge and skills around diversity and inclusion.
	• Recommitment on DE&I as a response to US Decree prohibiting DE&I policies • Diversity day	• New governance structure DE&I • New DE&I KPIs and targets
Gender	Mentoring programme: The mentoring programme is designed for women and forcolleagues from ethnically diverse backgrounds. This one-year programme aims to accelerate talent development and empower our colleagues. Boardroom coaching programme: A Talent to the Top programme in which Board members are linked to women one or two layers below the top (cross-company)
	• Equal Pay Day and annual Equal Pay report • International Women’s Day • Women’s Health Event	• Gender events will continue in 2026
Cultural	Roots Inspire programme: Together with our partner, Roots Inspire, ABN AMRO offers a challenging course for ambitious professionals from different cultural backgrounds who are ready for the next step in their career. Future-proof career programme, 6th edition: The course has been developed to stimulate the progression of bicultural talent to the sub-top, with a focus on the soft skills needed alongside hard skills to successfully advance. Two-way cross-mentoring programme, Agora Network: The programme focuses on empowering the mentees and providing them with tools for their further career development.
	• Celebrating cultural diversity by organising inclusive events throughout the year (such as Ramadan Experience, Lunar New Year, Keti Koti, Diwali celebration, Nowruz) • Kick-off African Diaspora Community	• Cultural events will continue in 2026
B-able	There were no active programmes for B-Able in 2025; however, see activities for B-Able focus group below.
	• Week of accessible banking (‘toegankelijk bankieren’) • World Disability Day	• B-Able events will continue in 2026
Reboot	Reboot Azure Academy: offers a 10-week programme that prepares individuals with a refugee background to become (junior) data engineers in the I&T department at ABN AMRO. Mentoring programme: the mentoring programme is designed for women and for colleagues from ethnically diverse backgrounds. This one-year programme aims to accelerate talent development and empower our colleagues. Both of these programmes were put on hold as at 1 April 2025, but are planned to be continued in 2026.
	• World Refugee Day • Training provided by LinkedIn	• Reboot events will continue in 2026 • ‘Walking in my shoes’ experience: An interactive experience to give colleagues insight into the real challenges and strengths of refugees entering the labour market
LGBTIQ+	Defiantly Different: leadership programme for LGBTIQ+ top talent
	• Amsterdam Diner: Senior ABN AMRO leaders attended this benefit event supporting HIV and AIDS prevention, reflecting our dedication to social responsibility and public health • Rainbow Families Symposium: This symposium highlighted diverse family structures within and outside the LGBTIQ+ community, fostering greater awareness and understanding across the organisation. • WorkPlace Pride Impact Awards Gala: As a WorkPlace Pride partner, ABN AMRO joins this annual gala celebrating impactful contributions to LGBTIQ+ inclusion.	• LGBTIQ+ events will continue in 2026. • World Pride 2026: Amsterdam will host World Pride for the first time in 25 years, coinciding with the 25th anniversary of legalised same-sex marriage. • WorkPlace Pride Global Benchmark: Continued participation to advance LGBTIQ+ inclusion.
Neurodiversity	There were no active programmes for Neurodiversity in 2025; however, see activities for Neurodiversity focus group below.
	• Seminars for managers • Empowerment Event Neurodiversity • Parents of Neurodiverse Kids event	• Neurodiversity events will continue in 2026 • Celebrating neurodiversity through World Autism Day, World Dyslexia Day, HSP Day and Neurodiversity Pride Day.
Generational diversity	There were no active programmes for Generational diversity in 2025; however, see activities for Generational diversity focus group below.
	• Launch Experienced Employees Network (EEN) • Generation Compass • Young Talent Award • Young ABN AMRO Events	• Events for generational diversity will continue in 2026


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≡	Sustainability Statements	Social	Own workforce

Targets related to own workforce

ABN AMRO NL DE&I targets :

The following targets are specific to employees in

ABN AMRO Netherlands as defined in this chapter:

the workforce as a whole.

Gender representation

• Ensure at least 48% of the Extended Leadership Team

are women

• Target 35% of senior and middle management

positions to be held by women

• Set gender diversity targets for senior leadership

positions within subsidiaries of ABN AMRO. For target

setting at subsidiaries, see our website.

Cultural diversity

• Achieve 8% of senior management, and 9% of middle

management with a migration background

Inclusion of vulnerable and underrepresented

groups:

• Support the participation of at least 225 people with

an occupational disability

• Continue the annual hiring of 20 people with

a refugee background

The hiring freeze implemented in April 2025 has

impacted ABN AMRO’s workforce composition and,

consequently, our diversity figures. For example, the

pause of the B-Able programme between April and

November resulted in 147 colleagues with occupational

disabilities, compared with the long term target of 225.

In addition, we did not meet our annual target of hiring

20 people with a refugee background; the total remains

127, unchanged from 2024. In line with our dedication

to social responsibility, exceptions were made during

the hiring freeze to allow B-Able and Reboot employees

to continue entering the organisation, ensuring ongoing

support for this important group.

Gender diversity targets continue to be an area of focus.

Women currently represent 34% of the Extended

Leadership Team against a 48% ambition, with senior

and middle management representation also below the

35% target. Cultural diversity targets were met at the

middle‑management level, while senior management

offers opportunities for further improvement (for more

details, see the Diversity targets table in the

Sustainability section of the Performance on our

strategy chapter).

We will continue to build momentum and work steadily

towards our long term ambitions.

Oversight, accountability and reporting

Diversity targets are set by the Diversity, Equity &

Inclusion department in collaboration with Diversity

Circles within ABN AMRO. These targets are approved

by the management teams of the client units/functions

before receiving final approval from the Executive

Board and the Supervisory Board. Progress towards

these targets is monitored annually.

For insights and results, see Diversity, Equity & Inclusion

in our operations in the Sustainability section in the

Strategy, value creation & performance chapter, which

includes:

• objectives of the DE&I policy

• strategies for achieving DE&I policy goals

• outcomes of the DE&I policy over the past financial

year.

For the period 2026 to 2029, drawing on input from our

DE&I circles and guided by the most recent regulatory

developments, ABN AMRO aims to set new targets for

gender representation and cultural diversity within Hay

grades 12 to 15. Our previous gender targets were in

place until the end of 2025, which is why we are

introducing new, bank-wide objectives. In addition,

cultural diversity targets will be updated to align with

the new definition established by Statistics Netherlands

(CBS).


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≡	Sustainability Statements	Social	Own workforce

Our employees at a glance

Headcount

24,632


Country split
20,300	3,791	245	168	128
The Netherlands	Rest of Europe	USA	Asia	Rest of the world


Gender diversity (in headcount)
Overall	The Netherlands	Top management


Breakdown by contract types (in headcount)
Temporary	Permanent	Full-time	Part-time


	Male		Female		Other & unknown


	Male		Female		Other & unknown

Other own workforce related metrics

Age breakdown of employees (in %)


	2025	2024
Gender pay gap	18%	16%
Employees with occupational disability¹	1%	1%
Remuneration Ratio	13	12
Outflow	2,629	2,213
Turnover rate	11%	10%
Average number of training hours per employee	8	7


2025		2024


	<24		24-29		30-39		40-49		50-59		>59

1. Employees with occupational disability for 2025 decreased to 0.72% compared with 0.79% in 2024.

space

Our employees at a glance

This section includes a brief description of

characteristics of ABN AMRO’s own workforce as

portrayed in the infographic above, followed by all S1-

related material metrics. Compared with the previous

year, the figures presented in this section reflect a

change driven by the acquisition of HAL, whose

inclusion in our consolidated reporting has resulted in

updated workforce totals and related breakdowns.

Headcount & diversity metrics

The total number of employees shown above is

presented on a headcount basis. This figure reflects the

actual number of employees as at 31 December 2025,

without the use of assumptions or averages. This figure

is different from the FTE figure presented, as it does not

take into account contractual working hours but the

actual number of employees. The total number of

employees in FTEs is disclosed in our Financial

performance section.


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≡	Sustainability Statements	Social	Own workforce

ABN AMRO is required to report separately on the

headcount and the breakdown in gender for countries

representing at least 10% of the total number of

employees (Netherlands). This is reflected in the

infographic above.

For the age breakdown, active employees are split over

six age brackets as in the infographic above.

Employee turnover includes the total number of

employees who left voluntarily, were dismissed, retired

or passed away during service. To calculate the turnover

rate, ABN AMRO used the headcount as at

31 December 2025.

For the employee breakdown by contract type, the

active number of employees is split by type of contract

and then further split by gender.

For the gender diversity at the top management level

(as defined in the ESRS), we split the employees in the

Extended Leadership Team by gender (34% female and

66% male).

Collective bargaining coverage and

Social dialogue

In the Netherlands, we have various different works

councils and an overarching Employee Council. Besides

these works councils, we have established the European

Staff Council (ESC). The ESC qualifies as a European

Works Council and it represents ABN AMRO’s Corporate

Banking and Wealth Management staff in the

Netherlands and in the other European countries where

ABN AMRO has corporate banking and wealth

management activities. More information on the ESC

can be found under General meeting and shareholder

structure in the Leadership & Governance chapter.

ABN AMRO is required to report, at the consolidated

level, the percentage of employees covered by a

collective labour agreement (CLA). This percentage is

calculated by dividing the number of employees under

a CLA by the total number of active employees

multiplied by 100. The outcome of this metric is

93.17%. This percentage reflects that the Netherlands,

Brazil, France, Germany and Belgium each have a CLA in

place, and that the vast majority of our employees in

these countries are covered by it.

In addition, ABN AMRO must disclose, for any country

representing at least 10% of the total number of

employees, the percentage of employees covered by a

CLA as well as the percentage represented by workers’

representatives. For 2025, this applied only to the

Netherlands. These percentages are calculated by

dividing the total number of active employees in the

Netherlands that fall under a CLA/workers'

representatives by the total number of active

employees in the Netherlands multiplied by 100.

97.58% of ABN AMRO's Dutch workforce are covered

by a collective labour agreement and 99.76% of

employees in the Netherlands are covered by workers'

representatives.

The percentages are similar to 2024, when the

corresponding figures were 97.72% and 99.77%,

respectively.

People with occupational disabilities

The percentage of employees with occupational

disabilities includes only those within ABN AMRO

Netherlands.

We plan to include data from entities outside the

Netherlands, subject to legal restrictions on data

collection in those countries in the short term. To

calculate the percentage of employees with a disability,

the number of disabled employees are divided by the

total number of active internal employees (within

ABN AMRO Netherlands) and multiplied by 100.

Training and skills development metrics

For these metrics we have applied the quick-fix,

meaning we only provide a partial disclosure relating to

training below on a voluntary basis.

ABN AMRO's performance management methodology

'Together & Better' applies to most internal employees

worldwide, though some subsidiaries follow their own

performance management processes.

We calculate the average number of study hours for all

active internal employees based on all completed

courses and information regarding the study hours per

course. ABN AMRO also has a continuous learning

programme called SHARP for all employees. For 2025,

the average number of hours spent on training was

8.05 hours per employee. This figure can be split to

5.15 study hours per employee spent on mandatory

courses and 2.9 hours spent on SHARP.

We emphasise the importance of life-long learning and

continuous growth. Together & Better supports

sustainable employee performance through regular

dialogues between employees and their managers,

where objectives are set to align with ABN AMRO's

purpose. These objectives – covering results, behaviour,

and development – are recorded in the online

Together & Better form within the Talent2Grow system.

In addition to individual objectives, objectives also are

predefined for identified staff at the organisational,

client unit and functional levels.

¹ Our new CEO was appointed in March; therefore, her included remuneration does not cover a full year. Our HAL colleagues joined ABN AMRO on

1 July, so only their second‑half‑year remuneration is included.


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≡	Sustainability Statements	Social	Own workforce

Together, employees and managers review progress

regularly and discuss ways to improve. Currently, 95.6%

of our employees (95.3% male, 95.9% female and

100% undefined [other & unknown]) have registered

their objectives in Talent2Grow The metric includes all

employees who have recorded their objectives in

Together & Better, divided by the total population in

Together & Better in 2025. The figures for 2025 have

improved slightly compared with the previous year:

in 2024 92.7% of our employees had registered their

objectives (male: 92.4%, female: 93.1% and undefined

[other & unknown]: 97.6%).

Our Together & Better process also plays a vital role in

our annual cycle of Talent Identification, People

Reviews, Position Management and Communication &

Development, through which we support business

continuity and prepare leaders and successors for

critical roles within ABN AMRO. This process offers

a consistent approach, promotes talent development

and provides a succession plan that aligns with legal

requirements. In addition, we offer extensive learning

and development programmes for various levels of

leadership, including an executive development

programme with INSEAD for our senior management.

Pay gap and total remuneration 1

The remuneration ratio is calculated by dividing the

annual total remuneration for ABN AMRO's highest paid

individual over median employee annual total

remuneration (excluding the highest paid individual).

The gender pay gap, as defined by the ESRS, refers to

the difference in average earnings between men and

women, presented as a percentage. It is calculated by

dividing the difference between the average gross

hourly pay level of male employees and the average

gross hourly pay level of female employees by the

average gross hourly pay level of male employees and

multiplied by 100%.

For both metrics we see an increase compared with last

year. In 2024, ABN AMRO reported a remuneration ratio

of 12; for the current reporting year, this has increased

to 13. The gender pay gap has also increased, rising

from 16% last year to 18% in the current reporting year.

This development can be explained by two changes.

First, improvements were made to the calculation by

adding several components – including pension

contributions for the Netherlands – which were not part

of last year’s calculation. The second change relates to

the inclusion of HAL employees, who became part of

ABN AMRO on 1 July 2025.

To address the pay gap, ABN AMRO is focusing on

increasing gender diversity at higher job levels, which

should help narrow the gap over time. This dedication

aligns with ABN AMRO's broader DE&I targets to ensure

more equitable representation and pay across our

workforce.

The gender pay gap and remuneration ratio presented

in this section differ from the figures presented in our

Remuneration report (the Remuneration report includes

the CEO Pay ratio). This is due to the difference in

methodology used in the Sustainability Statements

(which are aligned with the ESRS) and the

Remuneration report.

Social protection and work-life balance

At ABN AMRO, all employees are fully covered by social

protection – either through national legislation or

benefits provided by ABN AMRO. This coverage

safeguards employees against loss of income due to

major life events, including sickness, unemployment

(from the start of employment), employment injury and

acquired disability, parental leave and retirement.

Work-life balance refers to the percentage of

employees within ABN AMRO who are entitled to take

family-related leave. This is 100% as it is included in

national legislation and/or included in the benefits

provided by ABN AMRO to its employees. For this

metric, we applied the phase-in in 2024, and the quick-

fix in 2025. This means that we have included a partial

disclosure on a voluntary basis.

Incidents, complaints and severe human

rights impacts

ABN AMRO has established multiple channels for its

employees to report incidents. Each incident is

addressed on a case-by-case basis, ensuring the

relevant departments are involved.

In 2025, ABN AMRO recorded a total of 15 incidents

related to discrimination and harassment, which were

handled by HR Labour Affairs. This is higher compared

with 2024, when 7 incidents were recorded and

handled. In addition, HAL identified 2 incidents in 2025;

HAL dealt with them internally, as it had not yet been

integrated into ABN AMRO’s HR Labour Affairs channels

during the reporting year.

To enhance the accuracy and completeness of incident

reporting, ABN AMRO is working towards a unified

process for registering all incidents reported across the

separate channels. Until this process is fully


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≡	Sustainability Statements	Social	Own workforce

implemented, the reported incidents for 2025 only

include those registered with HR Labour Affairs.

Consequently, the total number of incidents reported

through the ‘speak-up channels’ in 2025 is not

disclosed here. ABN AMRO is formalising the

governance process for its speak-up channels, with the

aim of full implementation in the coming years.

Consequently, the total number of incidents reported

through the speak- up channels for 2025 will not be

disclosed.

Similar to 2024, ABN AMRO did not receive any

complaints through the National Contact Points for

OECD Multinational Enterprises in 2025. Furthermore,

there were no significant fines, penalties or

compensations for damages resulting from violations

related to social and human rights issues. In 2025,

ABN AMRO did not register any severe human rights

violations, including non-compliance with the UN

Guiding Principles on Business and Human Rights, the

ILO Declaration on Fundamental Principles and Rights

at Work, or the OECD Guidelines for Multinational

Enterprises. Furthermore, in relation to these

international standards, no fines, penalties or

compensation for damages were recorded for 2025.


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≡	Sustainability Statements	Social	Consumers and end-users

Consumers and end-users

As ABN AMRO is one of the three largest banks for households in the

Netherlands, it offers a wide range of products and services - from

payments and savings accounts to debit and credit cards, investment

services and consumer and mortgage loans.

When we refer to consumers, we mean individuals who

use goods and services for personal use, either for

themselves or for others, and not for resale or

commercial purposes. End-users, on the other hand, are

individuals who ultimately use or are intended to

ultimately use a particular product or service.

Throughout this chapter, we use the term ‘consumers

and end-users’ to refer to our clients collectively.

However, it is important to note that the scope of the

disclosure is largely limited to consumers only and does

not include corporate clients.

Through our DMA, we have identified Privacy of client

data and Suitability of products and services as material

matters from an impact materiality perspective.

ABN AMRO makes use of the transitional provisions for

S4-Consumers and end-users that were introduced

through the targeted 'quick fix' amendments to the first

set of ESRS.

Material matters included in this chapter

Material topics

Type

Linked to portfolio & industries

Topic

Subtopic

ABN AMRO

label

Definition

Type of

materiality

Value chain

identification

Personal

loans &

mortgages

Corporate

loans

Client assets

Consumers

and end-

users

Personal

safety

Suitability

of products

& services

Development of suitable

products and services that

adequately meet the needs,

characteristics and situation of

ABN AMRO’s intended clients/

target groups, as well as

adequately acting in the best

interest of clients to protect

them from foreseeable harm, in

line with the client centricity

principles

Negative

impact

Own

operations

Not linked to a particular portfolio, sector or

product

Information-

impacts

Privacy of

client data

The protection of our clients'

data through ABN AMRO’s

banking systems and policies

Negative

impact

Own

operations &

upstream

Not linked to a particular portfolio, sector or

product

Privacy

ABN AMRO acknowledges the potential negative

impacts related to privacy. It explains how these are

addressed through a set of integrated measures

embedded in both operational processes and long-term

planning. These measures, reflected in our policies and

actions, aim to ensure that the consideration of impacts

is at the core of our business model, supporting

resilience and sustainable value creation.

Policies related to privacy

Individuals provide their personal data to ABN AMRO

with the expectation that it will be handled responsibly

and securely. Compliance with the relevant privacy

legislation, alongside a good understanding among

staff of its impact and importance, is a foundational

requirement for handling personal data.

Our Personal Data Policy outlines the minimum

standards that all staff must follow when processing

personal data. It describes the principles and

requirements that govern each stage of the data

lifecycle, from collection through to erasure. This policy

is grounded in the principles of the EU General Data

Protection Regulation (GDPR). It also implements

relevant parts of ABN AMRO’s Binding Corporate Rules

(BCRs), which aim to contribute to affording an

adequate level of protection to personal data

transferred from ABN AMRO’s EU entities to entities

outside the EU.


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≡	Sustainability Statements	Social	Consumers and end-users

The Personal Data Policy applies to all personal data

originating within the European Economic Area (EEA).

Staff outside the EEA who have access to this data must

also adhere to its principles. Additionally, this policy

generally extends to personal data originating outside

the EEA.

Oversight, execution and monitoring responsibilities are

designated to the Executive Board and Senior

Management, ensuring that the governance of personal

data handling is embedded at the highest levels of the

organisation.

The Third Party & Outsourcing Risk Policy sets the

minimum requirements for managing the third party

and outsourcing risk. The Third Party & Outsourcing Risk

Policy is supported by the ABN AMRO Procurement

Standard and consequently the Supplier Code of

Conduct. Through that Code, ABN AMRO aims to ensure

that our suppliers meet our requirements and principles

as stipulated in the Personal Data Policy and BCRs with

respect to data security and privacy.

We expect our suppliers to safeguard personal data and

confidential information from unauthorised use,

disclosure, access, loss, alteration, damage and

destruction. The Supplier Code of Conduct also aims to

ensure that suppliers handle information in compliance

with national and other laws, regulations and guidelines

and have a documented Data Privacy & Protection

Policy. Furthermore, the Supply Chain Security Standard

reinforces security measures, such as cyber threat

monitoring, to ensure robust protection of client data

throughout the supply chain.

Dialogue and engagement related to privacy

ABN AMRO safeguards client privacy through a

structured framework of proactive and reactive

measures, including lawful data processing, respect for

data subject rights, robust data security, controlled data

retention, responsible data sharing and transfer,

oversight of automated decision-making and profiling,

and effective handling of privacy complaints.

Comprehensive details on GDPR compliance and client

privacy rights are outlined in the ABN AMRO Privacy

Statement, which is accessible via ABN AMRO’s website,

mobile apps and client documentation. Clients are kept

informed through those channels about data use and

their privacy rights.

ABN AMRO uses reactive engagement channels to

address data breaches, privacy complaints and data

subject rights requests. In the event of a data breach,

ABN AMRO follows a strict protocol to adhere to the

regulatory notification requirements in the proper time.

Affected clients are informed of relevant breaches

unless there are compelling reasons not to do so.

Privacy complaints are addressed through a structured

grievance mechanism designed to resolve issues

promptly.

Under the GDPR, ABN AMRO ensures that data subject

rights, including access, rectification, erasure, restriction

of processing, data portability and objection to

processing, are managed by specialised staff.

Consumer engagement occurs mainly during data

breaches, complaints and data subject rights requests.

Privacy risk accountability lies with the Executive Board

members and is integrated into the bank’s broader risk

management framework. This framework focuses on

identifying, mitigating and monitoring privacy-related

risks. Together, these responsibilities ensure continuous

improvement in privacy practices through feedback,

audits and reviews.

All privacy efforts align with ABN AMRO’s Duty of Care

& Client Centricity principles, emphasising consumer

interests in our decision-making, as reinforced by the

Privacy Statement.

Grievance mechanisms and remediation

channels

ABN AMRO ensures effective feedback channels for

consumers and end-users to report privacy concerns.

Complaints are handled promptly across multiple

platforms, tracked until resolution, and followed by

satisfaction surveys to evaluate effectiveness and client

satisfaction.

ABN AMRO addresses material privacy-related negative

impacts through its complaints and operational

management processes, ensuring concerns raised

through official channels are addressed. Privacy

negative impact management is aligned with the

general ESG risk management approach, which is

explained in the Risk management of ESG matters

section. Escalation and crisis management procedures

ensure effective handling of significant privacy issues.

ABN AMRO uses the Privacy Dashboard to identify

recurring issues and drive process improvements, and

monitor the effectiveness of its privacy measures,

integrating data into risk reports and evaluations. The

Complaints Management Dashboard identifies trends in

recurring privacy-related issues and supports

identification of mitigating actions to prevent future

recurrence.


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≡	Sustainability Statements	Social	Consumers and end-users

Our approach to action for privacy

ABN AMRO is dedicated to safeguarding the data,

privacy and assets of its clients and employees by

fostering a robust privacy foundation. The bank has

implemented procedures under its Personal Data Policy

to mitigate negative impacts across its entire value

chain.

ABN AMRO expects its direct suppliers to adhere to the

Supplier Code of Conduct and comply with applicable

privacy and data protection standards, as part of its

dedication to responsible business practices throughout

its supply chain. To support this objective, appropriate

monitoring activities are carried out. Furthermore, direct

suppliers are required to submit comprehensive

information regarding their data and IT security

measures, including relevant security certifications,

Information Security Policies and incident management

processes.

ABN AMRO has also initiated a bank-wide privacy

programme to strengthen its privacy risk management

framework. Current efforts focus on translating Personal

Data Policy requirements into actionable standards,

procedures and guidelines. We are in the process of

establishing renewed controls to monitor and evaluate

privacy-related negative impacts.

Targets related to privacy

In 2025, no privacy-specific targets were tracked.

Reporting is conducted as outlined in the Risk Appetite

Statement, which monitors the percentage of data

breaches reported beyond the required timeframe and

the volume of client complaints related to data

protection.

Suitability of products & services

Within the Personal & Business Banking (P&BB) and

Wealth Management (WM) client units, ABN AMRO

serves millions of households. We acknowledge what

impact we can have on our consumers and strive to

provide them with suitable products and services.

Policies related to suitability of products &

services

The section below includes disclosures on the policies

relevant to the bank-wide strategy to address the

material impacts related to suitability of products &

services.

Product Approval and Review Policy

ABN AMRO's Product Approval and Review (PAR) Policy

is designed to ensure that our products and services

serve the best interests of our clients and are offered to

a defined target market, while considering relevant

negative impacts for clients, ABN AMRO and external

stakeholders.

The PAR Policy outlines minimum standards for

approving, reviewing and modifying new and existing

products and services and related processes and

systems. It requires that products must be adapted to

reflect macroeconomic, social and sustainability

changes and that they must comply with all relevant

regulations. Additionally, the policy aligns with

ABN AMRO’s Client Centricity Principles and is an

integral part of the bank’s risk governance.

The Executive Board holds accountability for managing

product approvals and maintaining an effective PAR

process, and the GRC has responsibility for oversight.

Duty of Care and Client Centricity Policy

The Duty of Care and Client Centricity (DoC & CC)

Policy establishes our approach to managing Duty of

Care (DoC) Risk. This policy builds on the bank’s Client

Centricity Principles. The bank-wide Client Centricity

Principles guide how we handle our clients’ interests,

covering aspects from understanding clients’ needs and

behaviours to ensuring that products and services are

suitable, useful and easily understood. By upholding

these principles in our daily work, we are dedicated to

enabling our clients to make responsible and informed

decisions.

The DoC & CC policy serves as an umbrella policy,

providing structure and direction for DoC & CC-related

policies and controls. The DoC & CC Policy includes:

1. definitions and scope for DoC Risk and Client

Centricity

2. key concepts and aspects of DoC Risk management

3. bank-wide requirements to integrate DoC Risk into

the Enterprise Risk Management (ERM) cycle

Oversight on policy adherence is assigned to

Compliance.

Client Categorisation, Suitability and

Appropriateness Policy

The Client Categorisation, Suitability and

Appropriateness Policy sets the minimum requirements

applicable when providing investment services and

activities and ancillary services. Specifically, this policy

describes how clients who make use of such services

are classified and when/how suitability assessments and

appropriateness assessments must be conducted.

Compliance has responsibility, as the policy owner, for

regularly reviewing this policy and ensuring it is up-to-

date, for example in line with regulatory requirements.


ABN AMRO	Annual Report 2025	265


≡	Sustainability Statements	Social	Consumers and end-users

Complaints Management Policy

The Complaints Management Policy provides a

structured approach to improving our products and

services by ensuring effective complaint handling and

registration. This policy outlines clear definitions of

complaints, specifies roles and responsibilities and sets

standards for timely and accurate resolution.

Additionally, it mandates a regular analysis of major

complaint causes to drive continuous improvement and

ensures adherence to all relevant complaints handling

laws and regulations. The Complaints Management

department within Legal holds an independent

mandate to develop, review and oversee ABN AMRO’s

Complaints Management Policy. In 2025, the Chief

Operating Office maintained overall ownership of the

complaints handling process within ABN AMRO.

Dialogue and engagement for suitability of

products & services

To deepen our understanding of client perspectives and

needs, we engage on an ad hoc basis with various

stakeholders – conducting roundtables, surveys, client

panels and pilot programmes. For example, in 2025 we

conducted a series of research with small groups of

clients on the accessibility of both our banking app and

our online environment. We also use insights and

feedback from client behaviour to better align our

offerings with client preferences and needs.

Our engagement approach varies depending on the

type of interaction. For instance, the Customer Digital

Engagement department has worked both directly and

through third-party researchers to gather insights on

clients’ experiences, such as booking appointments

online, accessibility of processes and services and

sustainability expectations. Additionally, when

organisations such as the Dutch consumers’ association

Consumentenbond reach out to us with insights from

their consumer surveys, we take these into account.

Our objective is to leverage client and stakeholder

feedback to enhance our products and services,

ensuring they effectively address client needs.

Engagements help us assess the suitability of our

offerings, and we also use product approval reviews to

evaluate whether products and services remain

valuable for their target markets. This process includes

conducting scenario analyses and incorporating

product-related complaints into our feedback loop,

allowing us to refine product characteristics and target

market definition.

Grievance mechanisms and remediation

channels for suitability of products & services

Under ABN AMRO’s official complaints procedure,

clients can submit complaints via the website, using our

online chat facility, by phone or through the app. This

procedure is available for any concerns clients may wish

to raise, including in relation to accessibility, suitability,

discrimination and the use of our products and services.

We provide an initial response, at a minimum

confirmation of receipt of the complaint, within

5 business days. If a client does not receive a timely

response they can escalate the complaint to the Kifid

(the Dutch Institute for Financial Disputes). If an initial

response is provided in a timely fashion, the client can

lodge an appeal if they are not satisfied with this

response. After receiving the final response, the client

can escalate the complaint to the Kifid.

In addition, clients are always free to initiate

proceedings with other dispute resolution bodies, such

as the courts, anti-discrimination agencies or other

relevant institutions.

To assess the effectiveness of our complaints channels,

we invite clients to provide feedback through a survey.

The insights gathered from this feedback help us

enhance the complaints handling process and improve

outcomes for our clients. This feedback mechanism is

an integral part of our closed feedback loop, driving

continuous reviews of our products and processes.

Relevant stakeholders, including product- and client-

focused teams, have access to the complaints

dashboard, enabling them to derive lessons from

complaints and take actionable steps for improvement.

The Complaints Management team within Legal also

provides quarterly reports to the Executive Board and

other stakeholders. Those reports analyse complaint

trends, helping us identify critical issues and explore

potential solutions to address them.

If a complaint raises concerns about specific aspects of

one of our products, it may initiate the Product Approval

and Review (PAR) process to assess the product’s

suitability and accessibility. Based on the findings from

this evaluation, necessary adjustments to products and

services can be made to better meet client needs.

Clients who purchase our products through

intermediaries or third parties can directly access our

complaints mechanism for any issues. In all cases,

complaints regarding our products or services will

ultimately be handled by ABN AMRO.


ABN AMRO	Annual Report 2025	266


≡	Sustainability Statements	Social	Consumers and end-users

Our approach to action for suitability of

products & services

Product suitability is a topic that is highly regulated in

the European market for almost every financial product

or service that banks offer to consumers. Products

includes payment cards and accounts, (consumer)

credit and mortgage credit, investment services and

insurance. This involves providing clear and

comprehensible information. We continuously evaluate

the effectiveness of our efforts through mechanisms

such as client feedback, complaints and regular

monitoring.

Targets related to suitability of products &

services

At this time we have not established any additional

outcome-oriented or time-bound targets to measure

progress. ABN AMRO is dedicated to adhering to our

duty of care and preventing the negative impact which

non-adherence could have on our clients. The

effectiveness of our policies and actions related to

product suitability is therefore tracked via several

adherence indicators to ensure compliance.


ABN AMRO	Annual Report 2025	267


≡	Sustainability Statements	Business conduct

Business conduct

Good corporate governance is key to successfully delivering on our

purpose. Our culture, based on our core values, guides the decisions we

make every day, as well as the interactions we have with internal and

external stakeholders.

Based on the DMA, Client Integrity (CI) was identified as

the sole material topic in relation to Business Conduct

from a financial materiality perspective. See the table

below for further details. ABN AMRO is subject to strict

national and international regulatory requirements. In

this chapter, we describe the policies and mechanisms

ABN AMRO has in place to monitor compliance and

operational effectiveness, enhancing risk awareness,

effective risk management, and a culture of integrity.

Material matters included in this chapter

Material topics

Type

Linked to portfolio & industries

Topic

Subtopic

ABN AMRO

label

Definition

Type of

materiality

Value chain

identification

Personal

loans &

mortgages

Corporate

loans

Client assets

Business

conduct

Entity-

specific

topic

Client

Integrity

Client Integrity encompasses the

practices that ABN AMRO

implements in its interactions

with clients. Within the bank, it

includes the following domains:

Anti-Money Laundering, Anti-

Bribery and Corruption,

Combating the Financing of

Terrorism, Tax, Fraud and

Sanctions

Financial risk

Downstream

Not linked to a particular portfolio, sector or

product

Client Integrity

The CI risk at ABN AMRO encompasses six key risk

types: Money Laundering, Financing of Terrorism,

Bribery & Corruption, Tax Evasion, Fraud and Sanction

Circumvention. These forms of financial crime have a

profound negative economic and societal effect. Our

key stakeholders in this area include clients, regulators,

employees, shareholders and society at large.

ABN AMRO attaches great importance to conducting

business with integrity and takes its legal obligation to

combat financial crime seriously. For this purpose, a set

of CI policies have been implemented. These policies

adopt industry best practices and foster a positive

culture to mitigate and manage financial crime risks,

while also ensuring compliance with applicable

legislation (e.g. the Dutch Financial Supervision Act, the

Dutch Anti Money Laundering and Anti-Terrorist

Financing Act and the Dutch Sanctions Act 1977).

The Client Acceptance and Anti-Money Laundering

(CAAML) Policy aims to protect ABN AMRO’s products

and services from being used for money laundering and

the financing of terrorism (ML/FT). It establishes the

measures and requirements by which we seek to

prevent and detect ML/FT, as well as the principles and

rules by which we mitigate and manage these risks.

The Anti-Bribery and Corruption (ABC) Policy aims to

protect ABN AMRO from any direct or indirect

involvement in bribery or corruption and sets the

framework for managing bank-wide bribery and

corruption risks. Regarding CI, the policy describes

several bribery and corruption risk indicators (e.g.

adverse media).

The Tax Policy outlines the tax framework within which

ABN AMRO operates. It defines the global tax mandate,

provides specific guidance on responsible tax

behaviour, defines the bank’s tax strategy and specifies

when Group Tax involvement is required. Additionally, it

describes the bank’s tax risk appetite and provides

guidance for tax risk management, including the tax

control framework.

The Fraud Risk Policy establishes the standards and

requirements to safeguard the bank’s risk profile in

relation to fraud risks, including first party fraud (i.e.

fraud by clients causing financial losses and/or

reputational damage). The policy enhances

ABN AMRO’s fraud risk management by ensuring a

proactive approach to managing fraud risk through

prevention, detection and response. The policy is

implemented within a comprehensive framework


ABN AMRO	Annual Report 2025	268


≡	Sustainability Statements	Business conduct

designed to adapt to the rapidly evolving fraud

landscape.

The Sanctions Policy aims to protect ABN AMRO’s

products and services from being used for prohibited

transactions, as well as in relation to sanctions evasion

and circumvention. The policy sets the framework for

managing bank-wide sanctions risks, defines the rules

and requirements for compliance with applicable laws

and regulations, lays out the consequences for non-

compliance and describes the processes for escalation

and reporting.

All policies apply globally to all ABN AMRO entities.

Where national laws and regulations are more stringent,

they take precedence. All policies are available on the

bank’s intranet and are shared with relevant internal

stakeholders. An AML/CTF & Sanctions Statement, as

well as the ABC Policy, are available on our website.

ABN AMRO’s risk governance follows the three lines of

defence principle, which assigns clear responsibilities

for owning, managing, challenging, monitoring and

reporting risks. The Executive Board and Supervisory

Board oversee and advise on policies. Within the

Executive Board, the Chief Executive Officer (CEO) is

accountable for the CAAML and Sanctions Policy, the

Chief Risk Officer (CRO) for the ABC and Fraud Risk

Policies and the Chief Financial Officer (CFO) for the Tax

Policy. The Risk & Capital Committee (R&CC) maintains

a focus on compliance-related matters and oversees

the integration of ESG risks (e.g. CI) into the bank’s risk

control framework. The R&CC receives quarterly

updates on the activities of Detecting Financial

Crime (DFC).

Our CI activities aim to prevent financial crime. To this

end, in 2019 ABN AMRO established DFC. This

department ensures the effective implementation of CI

policies into systems and processes, such as the client

lifecycle (CLC), designed to detect financial crime.

The CLC process consists of client onboarding, ongoing

due diligence (ODD) and client exit. During client

onboarding we assess what risk level a client poses. An

ODD framework is in place to continuously monitor our

clients. We periodically review our clients (every 1 to 5

years, depending on the client’s risk score) and perform

transaction monitoring, client monitoring, transaction

filtering, client filtering and manual triggers. If risks are

flagged and enhanced due diligence is warranted, an

event-driven review (EDR) is initiated. Unacceptable CI

risks (e.g. fraud, money laundering) may lead

ABN AMRO to exit the client relationship. This is done

only after thorough investigation and in accordance

with legal requirements. The CLC process is supported

by a yearly Systematic Integrity Risk Analysis (SIRA) and

by our policies.

ABN AMRO requires all employees to have sufficient

knowledge and understanding of CI risks. Employees

need to be able to act appropriately if they encounter

client behaviour that deviates from our policies.

Awareness training on CI matters is mandatory for all

staff, as presented in the table below. An additional

curriculum of CI training on specific topics is available

which is mandatory for specific ABN AMRO employees.

Awareness training on Client Integrity matters¹


Topic	Target audience	Coverage ²	Frequency	Delivery method and duration
Always be aware of tax	All Staff	99%	One-off	25 min E-Learning
Introduction to our gatekeeper role	All Staff	99%	One-off	60 min E-Learning
Risk refresher	All staff	99%	Yearly	90 min E-Learning
Anti-Bribery and Corruption ³	All Staff	99%	Every 3 years	60 min E-learning
1. HAL employees are excluded from the training data.
2. This percentage shows the coverage on December 2025. Percentages may fluctuate throughout the year, given the frequency and availability of training.
3. This percentage reflects staff who have received training since June 2021.

ABN AMRO continues to enhance its internal AML

processes and systems to increase both effectiveness

and sustainable compliance with regulatory

requirements. ABN AMRO’s focus is on the effectiveness

of our monitoring processes and the quality of client due

diligence. ABN AMRO maintains a dialogue with the

Dutch central bank DNB, keeping it regularly informed.

DNB continues to monitor progress and provides

observations, such as previously identified shortcomings

in ABN AMRO’s EDR process. DNB has indicated that

these shortcomings may lead to enforcement measures.

A potential financial impact cannot be reliably estimated,

and no provision has been recorded.


ABN AMRO	Annual Report 2025	269


≡	Sustainability Statements	EU Taxonomy

EU Taxonomy

Green Asset Ratio

The EU Taxonomy Regulation provides a system for

classifying activities as environmentally sustainable. The

objective of the taxonomy disclosures is to determine

what portion of ABN AMRO’s assets is taxonomy-

aligned, and therefore is considered sustainable. The

ratio of environmentally sustainable assets to the assets

covered by the regulation is called the Green Asset

Ratio (GAR).

To determine whether an activity qualifies as

environmentally sustainable under the EU Taxonomy

Regulation, it must undergo a thorough evaluation

based on specific Technical Screening Criteria (TSC).

First, an assessment is conducted to determine the

substantial contribution of the activity to one of the six

environmental objectives. Next, the activity is assessed

for compliance with the do-no-significant-harm (DNSH)

principle. Lastly, the activity is assessed for adherence

to minimum social safeguards. For a more detailed

explanation of these criteria, see the Definitions section.

Taxonomy eligibility & alignment

After the CSRD replaced the NFRD in 2024, the year

2025 marks the first instance where ABN AMRO's

EU Taxonomy figures are derived from clients' annual

reports prepared under the CSRD framework. The

transition from the NFRD to CSRD has resulted in an

expanded scope, now including non-EU undertakings

whose securities are admitted to trading on an EU-

regulated market. Due to uncertainties surrounding the

transposition of the CSRD into national law, operational

constraints and ongoing Omnibus negotiations,

ABN AMRO has decided that, for its corporate loan

portfolio, 2025 reporting will continue to be based on

the NFRD criteria instead of the CSRD criteria. Hence,

the scope for this portfolio is subject to NFRD clients

incorporated in the EU.



1 Identification of eligible economic activities	2 Analysis of substantial contribution	3 Do No Significant Harm Assessment to other environmental objectives	4 Verification of minimum safeguard	5 Calculation of financial metrics

ABN AMRO’s scope for eligibility remains similar to

the reporting covering the 2025 financial year.

In ABN AMRO’s 2025 Annual Report, the scope of

alignment reporting has been expanded to include four

additional environmental objectives: water and marine

resources, circular economy, pollution and biodiversity

& ecosystems. These are in addition to climate change

mitigation and climate change adaptation, which were

already reported in ABN AMRO’s 2024 Annual Report.

The majority of our taxonomy-aligned exposures is

within our residential mortgage portfolio.

General-purpose financing, eligibility and alignment are

assessed at the entity level, which is relevant for CSRD

entities. This approach relies on the eligibility and

alignment ratios derived from the 2024 annual reports

of our clients. Due to counterparties’ data limitations,

the sum of the individual alignments per environmental

objective may not always equal the total ‘of which

Taxonomy-aligned’ reported by the counterparty.

Therefore, ABN AMRO uses the total alignment as

reported by the counterparty rather than calculating this

figure separately. Specific-purpose financing, eligibility

and alignment are determined using the regulation's

TSC conducted at the activity level. Before applying the

TSC, it is necessary to determine if a financed activity is

eligible under the EU Taxonomy, meaning that it is

potentially environmentally sustainable. Once eligibility

is confirmed, the activity can be assessed for taxonomy

alignment according to the TSC.

¹ ESRS 1 Article 113 also exempts Article 8 disclosures under the EU Taxonomy Regulation from broader ESRS requirements, such as providing

comparative figures.


ABN AMRO	Annual Report 2025	270


≡	Sustainability Statements	EU Taxonomy

2025 approach

On 4 July 2025, the European Commission adopted the

amended Delegated Act as part of the February 2025

Omnibus package. The Delegated Act was published in

the Official Journal of the European Union on

8 January 2026 and entered into force on

28 January 2026. The simplification measures apply

retrospectively from 1 January 2026, covering the 2025

financial year. Although undertakings are given the

option to apply implementation in the 2026 financial

year, ABN AMRO has implemented the measures

wherever feasible, effective the 2025 financial year.

Key measures implemented include the incorporation

of the simplified reporting templates with the

environmental objective splits for taxonomy alignment

in all templates and the adjusted denominator. Due to

the adjusted denominator, ABN AMRO’s main KPI GAR

significantly increased. Details on this increase are

provided in the section on EU Taxonomy – Summary of

KPIs. ABN AMRO also discontinued reporting all

separate Gas & Nuclear templates and incorporated

these exposures into the GAR Sector information,

maintaining the same scope as in last year’s reporting.

Lastly, ABN AMRO excluded non-material off-balance

sheet KPIs Financial Guarantees and Assets under

Management, following the introduction of a 10%

materiality threshold. In response to the requirement to

disclose sector-level information for non-material

economic activities, Financial Guarantees are largely

provided to clients operating in the same sectors as our

corporate loan portfolio. For a sectoral breakdown of

our corporate loan portfolio, see the Risk Management

section. ABN AMRO’s Assets under Management are

invested globally and may be allocated to any sector in

the real economy, depending on the sector of the

underlying portfolio company. The only sectors

excluded from investment are those on our Exclusion

List. Lastly, adopting the simplification measures means

postponing the reporting on the Trading Book KPI and

the Fees and Commission KPI by two years to the 2028

reporting year.

In accordance with the European Commission’s

December 2025 notice on the interpretation and

implementation of the amended Delegated Act,

ABN AMRO discloses comparative figures only for its

‘Summary of KPIs’, as this template is considered the

most relevant. Comparative figures for ’Assets for the

calculation of GAR’ and ‘GAR KPI Stock’ are not

disclosed, as disclosing these figures would not permit

an accurate comparison, nor is it required by the

amended Delegated Act. 1 Due to the timing of this

amended Delegated Act and existing data and process

limitations, certain elements could not be incorporated

into the 2025 Annual Report. Specifically, inclusion of

the non-assessed exposures columns and the GAR

sector information capex template was not feasible for

this reporting period.

ABN AMRO acknowledges the European Commission’s

November 2024 guidance on the EU Taxonomy, issued

as an FAQ document. ABN AMRO has further integrated

this guidance into the 2025 Annual Report where it is

not contradictory to the amended Delegated Act

published in the EU Official Journal in January 2026.

Reporting for subsidiaries in a consolidated KPI was an

additional requirement introduced by this FAQ.

However, following the requirements under the

amended Delegated Act, ABN AMRO has not

incorporated the separate EU Taxonomy KPI reporting

for subsidiaries.

Following the EC’s FAQ guidance, taxonomy-aligned

green bonds were required to be included in the

numerator of the GAR irrespective of the counterparty,

encompassing non-NFRD green bonds. ABN AMRO has

opted to report these exposures voluntarily for the 2025

reporting year. ABN AMRO acknowledges the FAQ

regarding the requirement to apply minimum social

safeguards assessments for households as a specific

counterparty type. However, given the ongoing debate

on this requirement in the sector, ABN AMRO has

concluded that the level of detailed data that would be

required to meet this requirement is practically

impossible to obtain.

² Following the simplification of the reporting templates, the assets ‘Derivatives’, ‘Cash and cash equivalents’, ‘On demand interbank loans’, ‘Other

assets’ (including goodwill and commodities) and ‘Undertakings not subject to the CSRD’ are removed from the GAR denominator. This is consistently

applied throughout all templates.


ABN AMRO	Annual Report 2025	271


≡	Sustainability Statements	EU Taxonomy

EU Taxonomy - Summary of KPIs

GAR KPI - Turnover-based

(in millions)

Assets that fall within the

scope of the EU Taxonomy

disclosure requirements.

Total assets¹

Covered assets²

Taxonomy-eligible assets are determined

by NACE code or activity description.

Eligible assets

Taxonomy alignment determined

by the technical screening criteria.

Aligned assets

1. Gross carrying amount excludes fair value adjustments from hedge accounting.

2. Excluding exposures to central governments, supranational issuers and central banks, as well as trading book positions, undertakings and entities

not subject to CSRD, derivatives, on-demand interbank loans, cash and cash-related assets, and other asset categories such as goodwill, while

including non-NFRD green bonds as voluntary exposures.

The Summary of KPIs – GAR shows the green asset ratio

based on alignment information from our clients on

turnover and capital expenditures. It also shows other

proportions related to the scope of the GAR.

Summary of KPIs - GAR


						31 December 2025
		Total exposure to Taxonomy aligned activities
		Turnover-based	CaPex-based	KPI¹	KPI²	Coverage (over total assets)
Main KPI	Green asset ratio (GAR) stock	40,630	40,879	21%	21%	45%

						31 December 2024
Main KPI	Green asset ratio (GAR) stock	35,866	36,277	11%	12%	80%
1. Based on the turnover KPI of the counterparty.
2. Based on the CapEx KPI of the counterparty, except for lending activities where the general lending turnover KPI has been used.

Summary of KPIs - Additional KPIs


						31 December 2025
		Total exposure to Taxonomy aligned activities
		Turnover-based	CaPex-based	KPI¹	KPI²	Coverage (over total assets)
Additional KPIs	GAR (flow)	6,205	6,320	22%	22%	29%

						31 December 2024
Additional KPIs	GAR (flow)	4,793	4,979	23%	24%
1. Based on the turnover KPI of the counterparty.
2. Based on the CapEx KPI of the counterparty, except for lending activities where the general lending turnover KPI has been used.

Impact of adjusted denominator on GAR

As explained in the section on ‘2025 approach’,

ABN AMRO chose to implement simplification measures

to the 2025 Annual Report wherever feasible. The

simplification covers a reduction of the scope of assets 2

included in the denominator of the KPIs. Due to this

simplification, the denominator significantly decreased,

resulting in an increase of ABN AMRO’s main KPI GAR

from 11% (31 December 2024) to 21%. For

comparison, ABN AMRO also calculated the GAR using

the previous methodology, which resulted in 12%.


ABN AMRO	Annual Report 2025	272


≡	Sustainability Statements	EU Taxonomy

Covered assets stock – Turnover


								31 December 2025
	Total gross carrying amount	- of which taxonomy eligible
(in millions)			- of which taxonomy aligned	Climate Change Mitigation	Climate Change Adaptation	Water and marine resources	Circular economy	Pollution	Biodiversity and ecosystems
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings¹	21,733	5,285	558	555	2
Loans and advances	16,603	4,027	429	428	1
Debt securities, including UoP	5,061	1,258	129	128	1
Equity instruments	69
Non-financial undertakings	4,237	796	188	169	2	1	17	1
Loans and advances	4,192	796	188	169	2	1	17	1
Debt securities, including UoP	42
Equity instruments	3
Households	164,572	164,572	39,866	39,866
Loans collateralised by residential immovable property	164,527	164,527	39,866	39,866
Building renovation loans	46	46
Motor vehicle loans
Local governments financing
House financing
Other local government financing
Collateral obtained by taking possession: residential and commercial immovable properties	3	3
Exposures included on a voluntary basis	18	18	18	18
Total GAR assets	190,563
Other assets not covered for GAR calculation	233,118
Central governments and supranational issuers	33,763
Central banks exposure	58,626
Trading book	2,044
Undertakings and entities not subject to CSRD²	111,675
SMEs and NFCs (other than SMEs) not subject to CSRD disclosure obligations	101,302
Loans and advances	93,627
- of which loans collateralised by commercial immovable property	20,835
- of which building renovation loans	74
Debt securities including UoP	6,516
Equity instruments	1,159
Non-EU country counterparties not subject to CSRD disclosure obligations	10,373
Loans and advances	10,351
Debt securities
Equity instruments	22
Derivatives	3,933
On demand interbank loans	1,120
Cash and cash-related assets	479
Other categories of assets	21,477
Total assets	423,682
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.
2. Financial undertakings not subject to CSRD disclosure obligations are reported within this category, covering both EU-based and non EU-based financial undertakings.


ABN AMRO	Annual Report 2025	273


≡	Sustainability Statements	EU Taxonomy

Covered assets stock - Turnover continued


					31 December 2025
	Total gross carrying amount	- of which taxonomy eligible
(in millions)			- of which taxonomy aligned	- of which use of proceeds	- of which transi- tional	- of which enabling
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings¹	21,733	5,285	558		27	81
Loans and advances	16,603	4,027	429		24	73
Debt securities, including UoP	5,061	1,258	129		3	8
Equity instruments	69
Non-financial undertakings	4,237	796	188		1	66
Loans and advances	4,192	796	188		1	66
Debt securities, including UoP	42
Equity instruments	3
Households	164,572	164,572	39,866	39,866
Loans collateralised by residential immovable property	164,527	164,527	39,866	39,866
Building renovation loans	46	46
Motor vehicle loans
Local governments financing
House financing
Other local government financing
Collateral obtained by taking possession: residential and commercial immovable properties	3	3
Exposures included on a voluntary basis	18	18	18	18
Total GAR assets	190,563
Other assets not covered for GAR calculation	233,118
Central governments and supranational issuers	33,763
Central banks exposure	58,626
Trading book	2,044
Undertakings and entities not subject to CSRD²	111,675
SMEs and NFCs (other than SMEs) not subject to CSRD disclosure obligations	101,302
Loans and advances	93,627
- of which loans collateralised by commercial immovable property	20,835
- of which building renovation loans	74
Debt securities including UoP	6,516
Equity instruments	1,159
Non-EU country counterparties not subject to CSRD disclosure obligations	10,373
Loans and advances	10,351
Debt securities
Equity instruments	22
Derivatives	3,933
On demand interbank loans	1,120
Cash and cash-related assets	479
Other categories of assets	21,477
Total assets	423,682
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.
2. Financial undertakings not subject to CSRD disclosure obligations are reported within this category, covering both EU-based and non EU-based financial undertakings.


ABN AMRO	Annual Report 2025	274


≡	Sustainability Statements	EU Taxonomy

Covered assets stock - Capex


								31 December 2025
	Total gross carrying amount	- of which taxonomy eligible
(in millions)			- of which taxonomy aligned	Climate Change Mitigation	Climate Change Adaptation	Water and marine resources	Circular economy	Pollution	Biodiversity and ecosystems
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings¹	21,733	5,788	738	735	2
Loans and advances	16,603	4,556	609	607	1
Debt securities, including UoP	5,061	1,232	129	128	1
Equity instruments	69
Non-financial undertakings	4,237	1,195	257	252	2	2	3
Loans and advances	4,192	1,195	257	252	2	2	3
Debt securities, including UoP	42
Equity instruments	3
Households	164,572	164,572	39,866	39,866
Loans collateralised by residential immovable property	164,527	164,527	39,866	39,866
Building renovation loans	46	46
Motor vehicle loans
Local governments financing
House financing
Other local government financing
Collateral obtained by taking possession: residential and commercial immovable properties	3	3
Exposures included on a voluntary basis	18	18	18	18
Total GAR assets	190,563
Other assets not covered for GAR calculation	233,118
Central governments and supranational issuers	33,763
Central banks exposure	58,626
Trading book	2,044
Undertakings and entities not subject to CSRD²	111,675
SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations	101,302
Loans and advances	93,627
- of which loans collateralised by commercial immovable property	20,835
- of which building renovation loans	74
Debt securities including UoP	6,516
Equity instruments	1,159
Non-EU country counterparties not subject to NFRD disclosure obligations	10,373
Loans and advances	10,351
Debt securities
Equity instruments	22
Derivatives	3,933
On demand interbank loans	1,120
Cash and cash-related assets	479
Other categories of assets	21,477
Total assets	423,682
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.
2. Financial undertakings not subject to CSRD disclosure obligations are reported within this category, covering both EU-based and non EU-based financial undertakings.


ABN AMRO	Annual Report 2025	275


≡	Sustainability Statements	EU Taxonomy

Covered assets stock - Capex continued


					31 December 2025
	Total gross carrying amount	- of which taxonomy eligible
(in millions)			- of which taxonomy aligned	- of which use of proceeds	- of which transi- tional	- of which enabling
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings¹	21,733	5,788	738		38	229
Loans and advances	16,603	4,556	609		33	219
Debt securities, including UoP	5,061	1,232	129		4	10
Equity instruments	69
Non-financial undertakings	4,237	1,195	257		4	119
Loans and advances	4,192	1,195	257		4	119
Debt securities, including UoP	42
Equity instruments	3
Households	164,572	164,572	39,866	39,866
Loans collateralised by residential immovable property	164,527	164,527	39,866	39,866
Building renovation loans	46	46
Motor vehicle loans
Local governments financing
House financing
Other local government financing
Collateral obtained by taking possession: residential and commercial immovable properties	3	3
Exposures included on a voluntary basis	18	18	18	18
Total GAR assets	190,563
Other assets not covered for GAR calculation	233,118
Central governments and supranational issuers	33,763
Central banks exposure	58,626
Trading book	2,044
Undertakings and entities not subject to CSRD²	111,675
SMEs and NFCs (other than SMEs) not subject to NFRD disclosure obligations	101,302
Loans and advances	93,627
- of which loans collateralised by commercial immovable property	20,835
- of which building renovation loans	74
Debt securities including UoP	6,516
Equity instruments	1,159
Non-EU country counterparties not subject to NFRD disclosure obligations	10,373
Loans and advances	10,351
Debt securities
Equity instruments	22
Derivatives	3,933
On demand interbank loans	1,120
Cash and cash-related assets	479
Other categories of assets	21,477
Total assets	423,682
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.
2. Financial undertakings not subject to CSRD disclosure obligations are reported within this category, covering both EU-based and non EU-based financial undertakings.


ABN AMRO	Annual Report 2025	276


≡	Sustainability Statements	EU Taxonomy

Covered assets flow - Turnover


								31 December 2025
	Total gross carrying amount	- of which taxonomy eligible
(in millions)			- of which taxonomy aligned	Climate Change Mitigation	Climate Change Adaptation	Water and marine resources	Circular economy	Pollution	Biodiversity and ecosystems
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings¹	2,974	941	107	107
Loans and advances	1,409	722	81	81
Debt securities, including UoP	1,565	219	26	26
Equity instruments
Non-financial undertakings	1,426	569	103	97			6	1
Loans and advances	1,415	569	103	97			6	1
Debt securities, including UoP	11
Equity instruments
Households	24,190	24,190	5,995	5,995
Loans collateralised by residential immovable property	24,178	24,178	5,995	5,995
Building renovation loans	11	11
Motor vehicle loans
Local governments financing
House financing
Other local government financing
Collateral obtained by taking possession: residential and commercial immovable properties
Exposures included on a voluntary basis
Total GAR assets	28,589	25,700	6,205	6,198			6	1
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.

Covered assets flow - Turnover continued


					31 December 2025
	Total gross carrying amount	- of which taxonomy eligible
(in millions)			- of which taxonomy aligned	- of which use of proceeds	- of which transitional	- of which enabling
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings¹	2,974	941	107		1	50
Loans and advances	1,409	722	81			49
Debt securities, including UoP	1,565	219	26		1	1
Equity instruments
Non-financial undertakings	1,426	569	103			25
Loans and advances	1,415	569	103			25
Debt securities, including UoP	11
Equity instruments
Households	24,190	24,190	5,995	5,995
Loans collateralised by residential immovable property	24,178	24,178	5,995	5,995
Building renovation loans	11	11
Motor vehicle loans
Local governments financing
House financing
Other local government financing
Collateral obtained by taking possession: residential and commercial immovable properties
Exposures included on a voluntary basis
Total GAR assets	28,589	25,700	6,205	5,995	1	75
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.


ABN AMRO	Annual Report 2025	277


≡	Sustainability Statements	EU Taxonomy

Covered assets flow - Capex


							31 December 2025
	Total gross carrying amount	- of which taxonomy eligible
(in millions)			- of which taxonomy aligned	Climate Change Mitigation	Water and marine resources	Circular economy	Pollution	Biodiversity and ecosystems
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings¹	2,974	1,045	225	225
Loans and advances	1,409	893	210	210
Debt securities, including UoP	1,565	152	15	15
Equity instruments
Non-financial undertakings	1,426	735	100	99	1
Loans and advances	1,415	735	100	99	1
Debt securities, including UoP	11
Equity instruments
Households	24,190	24,190	5,995	5,995
Loans collateralised by residential immovable property	24,178	24,178	5,995	5,995
Building renovation loans	11	11
Motor vehicle loans
Local governments financing
House financing
Other local government financing
Collateral obtained by taking possession: residential and commercial immovable properties
Exposures included on a voluntary basis
Total GAR assets	28,589	25,970	6,320	6,318	1
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.

Covered assets flow - Capex continued


					31 December 2025
	Total gross carrying amount	- of which taxonomy eligible
(in millions)			- of which taxonomy aligned	- of which use of proceeds	- of which transitional	- of which enabling
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings¹	2,974	1,045	225			179
Loans and advances	1,409	893	210			179
Debt securities, including UoP	1,565	152	15
Equity instruments
Non-financial undertakings	1,426	735	100			34
Loans and advances	1,415	735	100			34
Debt securities, including UoP	11
Equity instruments
Households	24,190	24,190	5,995	5,995
Loans collateralised by residential immovable property	24,178	24,178	5,995	5,995
Building renovation loans	11	11
Motor vehicle loans
Local governments financing
House financing
Other local government financing
Collateral obtained by taking possession: residential and commercial immovable properties
Exposures included on a voluntary basis
Total GAR assets	28,589	25,970	6,320	5,995	1	213
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.


ABN AMRO	Annual Report 2025	278


≡	Sustainability Statements	EU Taxonomy

GAR KPI stock - Turnover

This table shows the proportion of environmentally

sustainable assets compared to the covered assets

recorded in the main EU Taxonomy. The purpose of this

table is to show the proportion of total assets covered

by the GAR for each line item.

GAR KPI stock - Turnover


							31 December 2025
	Taxonomy eligible
		Taxonomy aligned
(in millions)			Climate Change Mitigation	Climate Change Adaptation	Water and marine resources	Circular economy	Pollution	Biodiversity and ecosystems
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings¹	24%	3%	3%	0%	0%	0%	0%	0%
Loans and advances	24%	3%	3%	0%	0%	0%	0%	0%
Debt securities, including UoP	25%	3%	3%	0%	0%	0%	0%	0%
Equity instruments	0%	0%	0%	0%	0%	0%	0%	0%
Non-financial undertakings	19%	4%	4%	0%	0%	0%	0%	0%
Loans and advances	19%	4%	4%	0%	0%	0%	0%	0%
Debt securities, including UoP	0%	0%	0%	0%	0%	0%	0%	0%
Equity instruments	0%	0%	0%	0%	0%	0%	0%	0%
Households	100%	24%	24%	0%		0%
Loans collateralised by residential immovable property	100%	24%	24%	0%		0%
Building renovation loans	100%	0%	0%	0%		0%
Motor vehicle loans	100%	0%	0%
Local governments financing	0%	0%	0%	0%	0%	0%	0%	0%
House financing	0%	0%	0%	0%		0%
Other local government financing	0%	0%	0%	0%	0%	0%	0%	0%
Collateral obtained by taking possession: residential and commercial immovable properties	100%	0%	0%	0%		0%
Exposures included on a voluntary basis	100%	100%	100%	0%		0%
Total GAR assets	90%	21%	21%	0%	0%	0%	0%	0%
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.


ABN AMRO	Annual Report 2025	279


≡	Sustainability Statements	EU Taxonomy

GAR KPI stock - Turnover continued


						31 December 2025
	Taxonomy eligible
		Taxonomy aligned				Proportion of Taxonomy aligned in Taxonomy eligible
(in millions)			- of which use of proceeds	- of which transi- tional	- of which enabling
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings¹	24%	3%	0%	0%	0%	11%
Loans and advances	24%	3%	0%	0%	0%	11%
Debt securities, including UoP	25%	3%	0%	0%	0%	10%
Equity instruments	0%	0%		0%	0%	0%
Non-financial undertakings	19%	4%	0%	0%	2%	24%
Loans and advances	19%	4%	0%	0%	2%	24%
Debt securities, including UoP	0%	0%	0%	0%	0%	0%
Equity instruments	0%	0%		0%	0%	0%
Households	100%	24%	24%	0%	0%	24%
Loans collateralised by residential immovable property	100%	24%	24%	0%	0%	24%
Building renovation loans	100%	0%	0%	0%	0%	0%
Motor vehicle loans	100%	0%	0%	0%	0%	0%
Local governments financing	0%	0%	0%	0%	0%	0%
House financing	0%	0%	0%	0%	0%	0%
Other local government financing	0%	0%	0%	0%	0%	0%
Collateral obtained by taking possession: residential and commercial immovable properties	100%	0%	0%	0%	0%	0%
Exposures included on a voluntary basis	100%	100%	100%	0%	0%	100%
Total GAR assets	90%	21%	21%	0%	0%	0%
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.


ABN AMRO	Annual Report 2025	280


≡	Sustainability Statements	EU Taxonomy

GAR KPI flow - Turnover

This table shows the proportion of environmentally

sustainable assets for new exposures that were incurred

during the year compared to the inflow of total assets

covered by the GAR. The purpose of this table is to

provide insight into the extent to which ABN AMRO’s

capital for sustainable activities changes over time,

providing an indication of the efforts towards making

our portfolio more taxonomy-aligned.

GAR KPI flow - Turnover


							31 December 2025
	Taxonomy eligible
		Taxonomy aligned
(in millions)			Climate Change Mitigation	Climate Change Adaptation	Water and marine resources	Circular economy	Pollution	Biodiversity and ecosystems
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings¹	32%	4%	4%	0%	0%	0%	0%	0%
Loans and advances	51%	6%	6%	0%	0%	0%	0%	0%
Debt securities, including UoP	14%	2%	2%	0%	0%	0%	0%	0%
Equity instruments	0%	0%	0%	0%	0%	0%	0%	0%
Non-financial undertakings	40%	7%	7%	0%	0%	0%	0%	0%
Loans and advances	40%	7%	7%	0%	0%	0%	0%	0%
Debt securities, including UoP	0%	0%	0%	0%	0%	0%	0%	0%
Equity instruments	0%	0%	0%	0%	0%	0%	0%	0%
Households	100%	25%	25%	0%	0%	0%	0%	0%
Loans collateralised by residential immovable property	100%	25%	25%	0%	0%	0%	0%	0%
Building renovation loans	100%	0%	0%	0%	0%	0%	0%	0%
Motor vehicle loans	0%	0%	0%	0%	0%	0%	0%	0%
Local governments financing	0%	0%	0%	0%	0%	0%	0%	0%
House financing	0%	0%	0%	0%	0%	0%	0%	0%
Other local government financing	0%	0%	0%	0%	0%	0%	0%	0%
Collateral obtained by taking possession: residential and commercial immovable properties	0%	0%	0%	0%	0%	0%	0%	0%
Exposures included on a voluntary basis	0%	0%	0%	0%	0%	0%	0%	0%
Total GAR assets	90%	22%	22%	0%	0%	0%	0%	0%
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.


ABN AMRO	Annual Report 2025	281


≡	Sustainability Statements	EU Taxonomy

GAR KPI flow - Turnover continued


						31 December 2025
	Taxonomy eligible
		Taxonomy aligned				Proportion of Taxonomy aligned in Taxonomy eligible
(in millions)			- of which use of proceeds	- of which transitional	- of which enabling
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings¹	32%	4%	0%	0%	2%	11%
Loans and advances	51%	6%	0%	0%	3%	11%
Debt securities, including UoP	14%	2%	0%	0%	0%	12%
Equity instruments	0%	0%	0%	0%	0%	0%
Non-financial undertakings	40%	7%	0%	0%	2%	18%
Loans and advances	40%	7%	0%	0%	2%	18%
Debt securities, including UoP	0%	0%	0%	0%	0%	0%
Equity instruments	0%	0%	0%	0%	0%	0%
Households	100%	25%	25%	0%	0%	25%
Loans collateralised by residential immovable property	100%	25%	25%	0%	0%	25%
Building renovation loans	100%	0%	0%	0%	0%	0%
Motor vehicle loans	0%	0%	0%	0%	0%	0%
Local governments financing	0%	0%	0%	0%	0%	0%
House financing	0%	0%	0%	0%	0%	0%
Other local government financing	0%	0%	0%	0%	0%	0%
Collateral obtained by taking possession: residential and commercial immovable properties	0%	0%	0%	0%	0%	0%
Exposures included on a voluntary basis	0%	0%	0%	0%	0%	0%
Total GAR assets	90%	22%	21%	0%	0%	24%
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.


ABN AMRO	Annual Report 2025	282


≡	Sustainability Statements	EU Taxonomy

GAR KPI stock - Capital expenditures

GAR KPI stock - Capex


							31 December 2025
	Taxonomy eligible
		Taxonomy aligned
(in millions)			Climate Change Mitigation	Climate Change Adaptation	Water and marine resources	Circular economy	Pollution	Biodiversity and ecosystems
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings##1##	27%	3%	3%	0%	0%	0%	0%	0%
Loans and advances	27%	4%	4%	0%	0%	0%	0%	0%
Debt securities, including UoP	24%	3%	3%	0%	0%	0%	0%	0%
Equity instruments	0%	0%	0%	0%	0%	0%	0%	0%
Non-financial undertakings	28%	6%	6%	0%	0%	0%	0%	0%
Loans and advances	29%	6%	6%	0%	0%	0%	0%	0%
Debt securities, including UoP	0%	0%	0%	0%	0%	0%	0%	0%
Equity instruments	0%	0%	0%	0%	0%	0%	0%	0%
Households	100%	24%	24%	0%	0%	0%	0%	0%
Loans collateralised by residential immovable property	100%	24%	24%	0%	0%	0%	0%	0%
Building renovation loans	100%	0%	0%	0%	0%	0%	0%	0%
Motor vehicle loans	100%	0%	0%	0%	0%	0%	0%	0%
Local governments financing	0%	0%	0%	0%	0%	0%	0%	0%
House financing	0%	0%	0%	0%	0%	0%	0%	0%
Other local government financing	0%	0%	0%	0%	0%	0%	0%	0%
Collateral obtained by taking possession: residential and commercial immovable properties	100%	0%	0%	0%	0%	0%	0%	0%
Exposures included on a voluntary basis	100%	100%	100%	0%	0%	0%	0%	0%
Total GAR assets	90%	21%	21%	0%	0%	0%	0%	0%
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.


ABN AMRO	Annual Report 2025	283


≡	Sustainability Statements	EU Taxonomy

GAR KPI stock - Capex continued


						31 December 2025
	Taxonomy eligible
		Taxonomy aligned				Proportion of Taxonomy aligned in Taxonomy eligible
(in millions)			- of which use of proceeds	- of which transitional	- of which enabling
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings¹	27%	3%	0%	0%	1%	13%
Loans and advances	27%	4%	0%	0%	1%	13%
Debt securities, including UoP	24%	3%	0%	0%	0%	10%
Equity instruments	0%	0%	0%	0%	0%	0%
Non-financial undertakings	28%	6%	0%	0%	3%	22%
Loans and advances	29%	6%	0%	0%	3%	22%
Debt securities, including UoP	0%	0%	0%	0%	0%	0%
Equity instruments	0%	0%	0%	0%	0%	0%
Households	100%	24%	24%	0%	0%	24%
Loans collateralised by residential immovable property	100%	24%	24%	0%	0%	24%
Building renovation loans	100%	0%	0%	0%	0%	0%
Motor vehicle loans	100%	0%	0%	0%	0%	0%
Local governments financing	0%	0%	0%	0%	0%	0%
House financing	0%	0%	0%	0%	0%	0%
Other local government financing	0%	0%	0%	0%	0%	0%
Collateral obtained by taking possession: residential and commercial immovable properties	100%	0%	0%	0%	0%	0%
Exposures included on a voluntary basis	100%	100%	100%	0%	0%	100%
Total GAR assets	90%	21%	21%	0%	0%	0%
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.


ABN AMRO	Annual Report 2025	284


≡	Sustainability Statements	EU Taxonomy

GAR KPI flow - Capital expenditures

GAR KPI flow - Capex


							31 December 2025
	Taxonomy eligible
		Taxonomy aligned
(in millions)			Climate Change Mitigation	Climate Change Adaptation	Water and marine resources	Circular economy	Pollution	Biodiversity and ecosystems
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings¹	35%	8%	8%	0%	0%	0%	0%	0%
Loans and advances	63%	15%	15%	0%	0%	0%	0%	0%
Debt securities, including UoP	10%	1%	1%	0%	0%	0%	0%	0%
Equity instruments	0%	0%	0%	0%	0%	0%	0%	0%
Non-financial undertakings	52%	7%	7%	0%	0%	0%	0%	0%
Loans and advances	52%	7%	7%	0%	0%	0%	0%	0%
Debt securities, including UoP	0%	0%	0%	0%	0%	0%	0%	0%
Equity instruments	0%	0%	0%	0%	0%	0%	0%	0%
Households	100%	25%	25%	0%	0%	0%	0%	0%
Loans collateralised by residential immovable property	100%	25%	25%	0%	0%	0%	0%	0%
Building renovation loans	100%	0%	0%	0%	0%	0%	0%	0%
Motor vehicle loans	0%	0%	0%	0%	0%	0%	0%	0%
Local governments financing	0%	0%	0%	0%	0%	0%	0%	0%
House financing	0%	0%	0%	0%	0%	0%	0%	0%
Other local government financing	0%	0%	0%	0%	0%	0%	0%	0%
Collateral obtained by taking possession: residential and commercial immovable properties	0%	0%	0%	0%	0%	0%	0%	0%
Exposures included on a voluntary basis	0%	0%	0%	0%	0%	0%	0%	0%
Total GAR assets	91%	22%	22%	0%	0%	0%	0%	0%
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.


ABN AMRO	Annual Report 2025	285


≡	Sustainability Statements	EU Taxonomy

GAR KPI flow - Capex continued


						31 December 2025
	Taxonomy eligible
		Taxonomy aligned				Proportion of Taxonomy aligned in Taxonomy eligible
(in millions)			- of which use of proceeds	- of which transitional	- of which enabling
GAR - Covered assets in both numerator and denominator
Loans and advance, debt securities and equity instruments not held for trading eligible for GAR calculation
Financial undertakings¹	35%	8%	0%	0%	6%	22%
Loans and advances	63%	15%	0%	0%	13%	23%
Debt securities, including UoP	10%	1%	0%	0%	0%	10%
Equity instruments	0%	0%	0%	0%	0%	0%
Non-financial undertakings	52%	7%	0%	0%	2%	14%
Loans and advances	52%	7%	0%	0%	2%	14%
Debt securities, including UoP	0%	0%	0%	0%	0%	0%
Equity instruments	0%	0%	0%	0%	0%	0%
Households	100%	25%	25%	0%	0%	25%
Loans collateralised by residential immovable property	100%	25%	25%	0%	0%	25%
Building renovation loans	100%	0%	0%	0%	0%	0%
Motor vehicle loans	0%	0%	0%	0%	0%	0%
Local governments financing	0%	0%	0%	0%	0%	0%
House financing	0%	0%	0%	0%	0%	0%
Other local government financing	0%	0%	0%	0%	0%	0%
Collateral obtained by taking possession: residential and commercial immovable properties	0%	0%	0%	0%	0%	0%
Exposures included on a voluntary basis	0%	0%	0%	0%	0%	0%
Total GAR assets	91%	22%	21%	0%	1%	24%
1. Including undertakings such as pension funds and clearing houses. These undertakings are classified as non-financial undertakings under the Taxonomy Regulation, but are classified as financial undertakings under Financial reporting. These undertakings are classified according to Financial reporting, but Taxonomy eligibility and alignment is determined with the assessment for non-financial undertakings.


ABN AMRO	Annual Report 2025	286


≡	Sustainability Statements	EU Taxonomy

GAR sector information¹


								31 December 2025
	Gross carrying amount
(in millions)		- of which Taxonomy eligible	- of which Taxonomy aligned	Climate Change Mitigation	Climate Change Adaptation	Water and marine resources	Circular economy	Pollution	Biodiversity and ecosystems
Rental and leasing of cars and light motor vehicles	351	351	11	8			3
Other information technology and computer service activities	219	85	11				10
Construction of water projects	160	73	67	62			4	1
Sea and coastal freight water transport	120	54	2	2
Wireless telecommunications activities	320	34	33	33
Service activities incidental to air transportation	27	26	26	26
Management of real estate on a fee or contract basis	56	26
Manufacture of other chemical products n.e.c.	57	24
Production of electricity	81	24	22	21
Forging, pressing, stamping and roll-forming of metal; powder metallurgy	20	19	1	1
Nuclear activities²	11	11	10
Fossil gas activities²	20	19
1. GAR sector information is based on the top 10 NACE codes 4 levels of detail and has been filtered for eligibility.
2. The scope of GAR sector information remains limited to Non-Financial Companies, consistent with prior year reporting, except for Nuclear and Fossil gas exposures, where the original scope is maintained to also include Financial Companies.


ABN AMRO	Annual Report 2025	287


≡	Sustainability Statements	ESG Annex

ESG Annex

This section does not form part of the Sustainability Statements prepared in accordance

with ESRS and therefore is not in scope of the limited assurance engagement on the

Sustainability Statements. It contains disclosures on ESG such as ESG rating requirements

or requirements from other frameworks. In addition, and due to its activities in Norway,

we include the requirements under the Norwegian Transparency Act.

GHG emissions - own operations


		31 December 2025		31 December 2024		Milestones and targets
(in tCO 2 e)	Base year 2015	Total		Total		Change (in %)	Target 2025	Target 2030
(in tCO 2 e)			- of which the Netherlands		- of which the Netherlands				Annual % target / Base year
Reported GHG emissions
Scope 1
Energy (natural gas, solar PV & other)		1,053	795
Mobility (lease cars - internal combustion engine)		972	289
Total scope 1 emissions		2,025	1,084
Energy (natural gas, solar PV & other) - considering green gas		281	23	174	23	61%
Mobility (lease cars - internal combustion engine)		972	289	1,285	585	-24%
Total scope 1 emissions - considering green gas	19,770	1,253	312	1,459	608	-14%	344	0	6.7%
Scope 2
Energy (electricity, heating, and cooling) - market-based		886	552	810	515	9%
Mobility (lease - electric vehicles) - market-based
Total scope 2 market-based emissions	20,150	886	552	810	515	9%	1,971	0	6.7%
Energy (electricity, heating, and cooling) - location-based		8,502	7,224	10,047	8,827	-15%
Mobility (lease - electric vehicles) - location-based
Total scope 2 location-based emissions		8,502	7,224	10,047	8,827	-15%
Scope 3 ²
1. Purchased goods and services				7,897	7,886
- of which Off-premise datacenters & Software-as-a-service				7,897	7,886
6. Business travel		5,966	4,125	8,177	5,929	-27%
‐ of which in scope for target ³	12,392	5,018	3,224	7,272	5,078	-31%	4,701	4,987	4.0%
7. Employee commuting		14,765	13,294	14,830	13,244	0%
Total scope 3 emissions		20,731	17,419	30,904	27,059	-33%
Total emissions - market based		22,870	18,283	33,173	28,182	-31%
Total emissions - location based		31,258	25,727	42,410	36,494	-26%
'-of which carbon avoidance credits are purchased for ⁴				33,173	28,182
1. Scope 1 emissions considering green gas reflect the use of purchased Guarantees of Origin (GvOs), which cover all natural gas consumption in the Netherlands in 2025. These emissions are added to the market‑based total. Gross Scope 1 emissions, thus without considering GvOs, are included in the location‑based total.
2. Scope 3 category 1 is not reported due to the decision to stop reporting on scope 3 emissions that are not in scope of our targets or external commitments.
3. The target scope for business travel includes air travel, international rail travel and hotel visits. Excluded is national (business) rail travel and business travel by private vehicle.
4. We have started purchasing carbon removal credits to reach our net zero goal in 2030. The credits purchased are verified against recognised quality standards. We will start retiring these credits from 2030 onwards.


ABN AMRO	Annual Report 2025	288


≡	Sustainability Statements	ESG Annex

While our environmental impact as a bank is much

greater through the financing of business activities and

models, we remain dedicated to minimising our own

operational footprint as well.

The primary climate impact of our own operations

stems from energy use and business travel. We have set

a net-zero target for our own operations emissions in

2030. To achieve this, we measure, monitor and actively

work to reduce GHG emissions across our operations.

This year we renewed our Energy & Environmental

Policy Statement, outlining our actions on energy

efficiency and decarbonising the use of our buildings.

This includes increasing the energy efficiency of our

buildings to become Paris Proof by 2030, and transition

to 100% renewable energy consumption domestically

and internationally.

We are a member of Anders Reizen Coalition, a

collaboration between 70 large Dutch organisations

working to reduce emissions from commuting and

business travel. We have electrified our lease car fleet in

the Netherlands to decarbonise mobility. Internationally,

policies to ensure lease fleet electrification have been

implemented in Belgium and Germany and are being

drafted in France and Greece. The lack of sufficient

charging infrastructure across France and Greece

provides some challenges, but we are actively exploring

solutions to meet our target of a fully electric

international lease fleet by 2030. To decarbonise

business travel, ABN AMRO has been replacing short-

distance air travel with rail travel and has implemented

annual travel budget limits for each department. The

business travel emission reduction targets and

corresponding department budgets were updated in

2025, as the previous target was deemed not viable for

business. The target has been updated from

2.6 kilotonnes of CO2e to 5 kilotonnes of CO2e by 2030.

Although this target is less ambitious than what we

aimed for previously, we are still aiming to reduce our

business travel by 60% by 2030 compared with 2015.

We aim to reduce 91% of our base year emissions and

compensate the residual emissions with carbon removal

credits.

We are ISO 14001-certified for Environmental

Management Systems, which ensures continuous

monitoring, updates and the implementation of controls

to address climate risks and opportunities in our own

operations.

Refer to the section Climate Risk for the disclosure on

our emissions for scope 3 category 15. Details on the

scope and methodology can be found in the Definitions.

Energy consumption and mix


(in MWh)	31 December 2025	31 December 2024
Non-renewable
Fuel consumption from natural gas and other fossil sources	5,835	5,419
Consumption of purchased or acquired electricity from fossil sources	1,339	1,215
Consumption of purchased or acquired heat, steam, and cooling from fossil sources	6,641	12,391
Total fossil energy consumption	13,815	19,025
Share of fossil sources in total energy consumption (%)	27%	36%
Consumption from nuclear sources
Share of consumption from nuclear sources in total energy consumption (%)	0%	0%
Renewable
Fuel consumption from renewable sources, including biomass	14
Consumption of purchased or acquired electricity from renewable sources	32,856	33,235
Consumption of purchased or acquired heat, steam, and cooling from renewable sources	3,837	139
The consumption of self-generated non-fuel renewable energy (Solar PV)	1,335	1,158
Total renewable energy consumption	38,042	34,532
Share of renewable sources in total energy consumption (%)	73%	64%
Total energy consumption	51,857	53,557

Human-rights-related disclosures

‘Workers in the value chain’ was not deemed material in

the DMA conducted in 2025 and is therefore not

included in the Sustainability Statements. Our human

rights approach is based on the human rights due

diligence requirements as outlined in the United Nations

Guiding Principles on Business and Human Rights

(UNGPs) and the OECD Guidelines for Multinational

Enterprises (OECD) (due diligence steps 1-6). This

section contains the disclosure requirements in line with

the UNGPs, OECD Guidelines and Norwegian

Transparency Act and describes (among other

information) the outcome of the updates to the Human

Rights Saliency Assessment. Although there are

similarities, the methodology of the saliency assessment

may deviate from the DMA methodology and therefore

yield different outcomes.


ABN AMRO	Annual Report 2025	289


≡	Sustainability Statements	ESG Annex

Our dedication to human rights

In addition to the policy framework described in the

section Risk management of ESG matters, our

dedication to respecting human rights is embedded in

our Human Rights Statement, our Modern Slavery

Statement and our Supplier Code of Conduct.

The Human Rights Statement articulates our dedication

to respecting human rights and is aligned with

international frameworks such as the UNGPs and the

OECD Guidelines. It sets expectations for ABN AMRO

and our clients, investments and suppliers. It also

highlights the importance of identifying and addressing

salient human rights issues and outlines our governance

of human-rights-related issues.

Through our Modern Slavery Statement, we disclose

how we identify and address modern slavery risks,

including forced labour, human trafficking and

exploitation. In 2025, we strengthened our frameworks

for client and supplier engagement and expanded our

monitoring mechanisms. These enhancements reflect

our dedication to combating modern slavery and

fostering transparency across our operations.

Human rights due diligence in action

In 2025, we updated our Human Rights Saliency

Assessment for the role of Procurer. This assessment

identifies the most salient human rights issues across

our business activities, focusing on areas where

ABN AMRO's operations have the greatest potential

impact on people. Through stakeholder consultation,

we identified the most severe and likely human rights

impacts. Following desk research, a data analysis was

carried out that focused on refining the initial results.

These findings were then validated.

Addressing modern slavery and forced labour remains

an important focus of our work. In 2024, we began

closely monitoring press coverage of modern slavery,

even when this was not related to specific ABN AMRO

clients. This external intelligence analysis revealed a rise

in reports of labour exploitation in the Netherlands and

a global increase in human trafficking. Therefore, in

early 2025 we performed an investigation to deepen

our understanding of modern slavery practices,

evaluate the bank’s exposure to related risks and refine

our approach to combatting this pervasive issue. It also

enhanced our intelligence position, enabling us to

identify connections to financial economic crime-

related risks and initiate targeted actions to address

them. This effort reflects our dedication in 2025 to

proactively combating modern slavery and informed

the preparation of our annual Modern Slavery

Statement.

Additionally, in 2025 we enhanced our engagement

with clients on human rights, equipping coverage

bankers with guidance on key topics such as grievance

mechanisms, stakeholder engagement, child labour and

forced labour, human rights due diligence and free prior

and informed consent.

We continued integrating sustainability and human

rights considerations into our procurement practices,

ensuring alignment with international frameworks. One

of the key milestones in 2025 was the introduction of

the Sustainability Risk Procedure for suppliers, that

outlines our sustainability due diligence requirements

for the supply chain. This procedure is designed to

proactively assess and manage environmental, social

and governance risks associated with our suppliers,

addressing critical human rights topics and fostering

responsible business conduct throughout our supply

chain.

Collaboration approach on human rights topics

We understand that addressing human rights

challenges requires collective action. In 2025,

ABN AMRO continued its co-leadership in the UNEP-FI

Working Group on Decent Work, a partnership with

other banks and the International Labour Organization

to promote ethical labour practices globally. Together,

we developed a UNEP-FI guidance framework for

setting targets, taking action and monitoring progress

on decent work standards.

In relation to access to remedy, we hosted a conference

in May titled ‘How to Facilitate and Enable Access to

Remedy in Business-Related Human Rights Abuses’.

This event brought together NGOs, human rights

experts, companies and peers to explore the role of

financial institutions in addressing business-related

human rights abuses. Finally, 2025 marked the first year

of our Human Rights Remedy Mechanism (HRRM) pilot.

While three cases were reviewed during this phase,

none met the eligibility criteria. For more information,

please visit the dedicated website.


ABN AMRO	Annual Report 2025	290


≡	Sustainability Statements	ESG Annex

Engagement overview of ESG high-intensity engagements and focus list clients - Lending


Number	List	Product	Sector	Region	Engagement ¹	Issue
1	Focus	Lending	Construction	Europe	Ongoing	Environmental pollution, health impacts, Reputation
2	Focus	Lending	Global Transportation & Logistics	Europe	Ongoing	Defence activities, Human Rights
3	Focus	Lending	NR- Energy	Europe	Ongoing	ESG Risk Management, Reputational risks
4	Focus	Lending	NR - Energy	Europe	Ongoing	Human Rights, Reputational Risks
5	Focus	Lending	NR - Energy	Europe	Ongoing	Human Rights and Environmental Impacts
6	Focus	Lending	NR - Energy	Europe	Ongoing	ESG Risk Management Framework
7	Focus	Lending	Food & Retail	Europe	Ongoing	Animal welfare, ESG Risk Management Framework
8	Focus	Lending	Food & Retail	Europe	Ongoing	ESG Risk Management
9	HIE	Lending	NR - Energy	Europe	Ongoing	ESG Risk Management Framework
1. Ongoing = client was already included in 2025 engagement list, engagement is ongoing.

Engagement overview - Investment services


	Environmental	Social and ethical	Governance	Strategy, risk and communication
Companies engaged (total)	444	374	428	204
Companies engaged (objectives)	328	217	112	55
Companies engaged (in progress or completed)	223	124	66	38

Political influence and lobbying activities

Banking is a highly regulated sector, at both the national

level in ABN AMRO’s home market of the Netherlands,

and at the EU level. Since politicians and public

authorities set the rules and regulations for banks, it is

essential that ABN AMRO maintains a constructive and

ongoing dialogue with policymakers, individually and

collectively.

Our Public Affairs team coordinates this dialogue

through contacts with members of the Dutch

Parliament, Dutch government ministers and their

ministries, the European Parliament, the European

Commission and others. These exchanges focus on

developments directly or indirectly relevant to

ABN AMRO, as well as initiatives where we can

contribute.

Monitoring and influencing

The Public Affairs team consists of two in-house

lobbyists: one focused on The Hague and the other on

Brussels. They monitor key legislative, regulatory and

policy developments and report relevant insights to

senior management.

Our ABN AMRO Clearing subsidiary also employs

lobbyists in Brussels who specialise in clearing. These

experts help us anticipate political and legislative

changes so that we can adapt in time.

Another key activity is sharing information about

ABN AMRO with key stakeholders, helping them

consider our interests when drafting new regulations.

Supported by the Public Affairs team, Board members,

senior managers and experts share this information

formally and informally – through written

communication, one-on-one meetings, group

exchanges and both closed and public consultations.

ABN AMRO representatives also participate in various

banking, industry and business associations where

significant political and policy information is exchanged.

These associations often maintain their own contacts

with policymakers and indirectly represent ABN AMRO’s

interests.


ABN AMRO	Annual Report 2025	291


≡	Sustainability Statements	ESG Annex

Memberships of industry and business associations


Banking associations
Dutch Banking Association (Nederlandse Vereniging van Banken, NVB)		British Bankers' Association (UK Finance)
Belgian Financial Sector Federation (Febelfin)		American Bankers Association (ABA)
Association of German Banks (Bundesverband deutscher Banken, BdB)		Association of Banks in Singapore (ABS)
French Banking Federation (Fédération Bancaire Française, FBF)		Hong Kong Association of Banks (HKAB)
Industry, trade and business associations, thinktanks
Confederation of Netherlands Industry and Employers (VNO-NCW)		European Payments Council (EPC)
Dutch Association for Business and Operational Risk (DABOR)		European Venture Philanthropy Association (EVPA)
Dutch Association of Covered Bond Issuers (DACB)		Futures Industry Association (FIA)
Dutch Association of Investors for Sustainable Development (VBDO)		Global Credit Data (GCD)
Dutch Payments Association (DPA)		Institute of International Finance (IIF)
Dutch Securitisation Association (DSA)		International Association of Credit Portfolio Managers (IACPM)
American Chamber of Commerce in the Netherlands (AmCham NL)		International Capital Market Association (ICMA)
International Chamber of Commerce Netherlands (ICC Netherlands)		International Swaps and Derivatives Association (ISDA)
Eurofi		Loan Market Association (LMA)
European Capital Markets Institute (ECMI)		Roundtable on Sustainable Palm Oil (RSPO)
European Covered Bond Council (ECBC)		World Economic Forum (WEF)
European Money and Finance Forum (SUERF)

ABN AMRO’s focus in these exchanges spans payments,

lending, investments and capital markets, as well as

secure banking, corporate social responsibility, anti-

money laundering, banking supervision, capital

requirements and sector consolidation.

At the EU legislative level, key discussions in 2025

centred on the digital euro, the Payment Services

Regulation (particularly combatting and compensating

for online fraud) and retail payments. Policymakers

were urged to strengthen public-private collaboration,

ensure interoperability and support innovative European

solutions such as Wero to build a resilient and sovereign

payment landscape. At the Dutch legislative level,

ABN AMRO contributed to the public consultation on

the proposed National Investment Institution,

recommending a focus on financing major

infrastructure projects that support the energy

transition, circularity and security. The bank also

advocated exempting deferred debit cards from

CCD2’s stricter BNPL regulations, given their

fundamentally different nature.

ABN AMRO’s in-house lobbyists are registered in the

EU’s Transparency Register and operate in compliance

with the Dutch Banker’s Oath and the European Code of

Conduct for Interest Representatives. While ABN AMRO

works with external agencies active in the fields of

public affairs and advocacy, this cooperation is limited

to intelligence gathering regarding political and

legislative developments. ABN AMRO employs 3.3 FTE

in-house lobbyists, and no external lobbyists.

Total contributions

The table below shows ABN AMRO’s total contributions

related to political influence and lobbying activities.

ABN AMRO’s policy is clear: we do not make

contributions to individual politicians, political parties or

political campaigns anywhere in the world. As in 2024,

political contributions in 2025 were therefore nil.

Employees may make personal political contributions,

provided these contributions comply with locally

applicable laws.

Total contributions


(in thousands)	31 December 2025	31 December 2024
Spending on lobbyists	743	714
Large membership expenditures in industry and business associations	6,547	5,729
- of which, NVB	6,203	5,316
- of which, VNO-NCW	153	175
- of which, IIF	104	152
- of which, ISDA	87	86
Political contributions	0	0
Total contributions	7,290	6,443


ABN AMRO	Annual Report 2025	292


≡	Sustainability Statements	ESG Annex

ESG Ratings table


Rating Label	Annual Report title	Reference
Transparency on Lobbying and Political Expenses	ABN AMRO engagement in any lobbying and political finance activities	Sustainability Statements - ESG Annex - Political influence and lobbying activities
Transparency on Lobbying and Political Expenses	ABN AMRO breakdown of lobbying and political expenses per recipient/beneficiary and per country	Sustainability Statements - ESG Annex - Political influence and lobbying activities
Transparency on Lobbying and Political Expenses	ABN AMRO overall monetary value of lobbying and political expenses	Sustainability Statements - ESG Annex - Political influence and lobbying activities
Transparency on Lobbying and Political Expenses	ABN AMRO causes or themes it supports through lobbying and political finance activities	Sustainability Statements - ESG Annex - Political influence and lobbying activities
Transparency on Lobbying and Political Expenses	Expenditures and/or beneficiaries supported via ABN AMRO lobbying or political finance activities	Sustainability Statements - ESG Annex - Political influence and lobbying activities
Responsible Product Offering	ABN AMRO product and/or service quality	Sustainability Statements - Consumers and end-users - Suitability of products & services
Gender Pay Equality Programme	ABN AMRO monitoring and measurement of the Gender Pay Equality Programme	Leadership & governance - Remuneration report - Gender Equality & Equal Pay
Gender Pay Equality Programme	ABN AMRO quantitative targets and deadlines for the Gender Pay Equality Programme	Strategy & performance - Performance on our Strategy - Sustainability - Our diversity targets Leadership & governance - Remuneration report - Gender pay gap & Equal pay
Human Capital Development	ABN AMRO quantitative targets related to human capital development	Leadership & governance - Remuneration report
Human Capital Development	ABN AMRO human capital development metrics	Sustainability Statements - Own workforce - Our employees at a glance
Human Capital Development	ABN AMRO human capital risk assessment	Risk, funding & capital - Non-financial risk - HR risk
Gender Pay Disclosure	ABN AMRO global mean (average) raw gender pay gap	Strategy & performance - Performance on our Strategy - Sustainability - Our diversity targets Leadership & governance - Remuneration report - Gender pay gap & Equal pay
Gender Pay Disclosure	ABN AMRO ratio of basic salary and remuneration of women to men for specific employment categories (level or function)	Leadership & governance - Remuneration report - Gender pay gap & Equal pay Sustainability Statements - Own Workforce - Our employees at a glance
Systemic Risk Reporting	ABN AMRO management of changing risk environment	Risk chapter - Risk Management Framework
Systemic Risk Reporting	ABN AMRO capital planning	Risk chapter - Capital Management Strategy
Systemic Risk Reporting	ABN AMRO liquidity planning	Risk chapter - Liquidity Risk Management
Systemic Risk Reporting	ABN AMRO market risks	Risk chapter - Market risk
Systemic Risk Reporting	ABN AMRO credit risks	Risk chapter - Credit risk review
Risk Oversight	ABN AMRO risk mitigation measures for industry-specific risk	Risk chapter - Credit risk
Board Gender Representation Target	ABN AMRO gender representation	Sustainability Statements - Own workforce - Our employees at a glance
Board Gender Representation Target	ABN AMRO quantitative target for Board gender representation	Strategy & performance - Performance on our Strategy - Sustainability
Board Gender Representation Target	ABN AMRO Board gender representation quantitative targets, aligned with international standards	Strategy & performance - Performance on our Strategy - Sustainability
Board Gender Representation Target	ABN AMRO Board gender representation quantitative targets, tied to specific timelines	Strategy & performance - Performance on our Strategy - Sustainability
Accessible Finance Commitment	ABN AMRO initiatives directly related to providing microfinancing solutions targeting low-income households, disadvantaged groups and small businesses set up by these individuals/groups	Strategy & performance - Performance on our Strategy - Sustainability - Social
Accessible Finance Commitment	ABN AMRO initiatives directly related to providing financial education to disadvantaged or low-income individuals	Strategy & performance - Performance on our Strategy - Sustainability - Social
Accessible Finance Commitment	ABN AMRO partnerships with other financial institutions, communities, NGOs or governmental authorities to deliver microfinance solutions, in order to achieve its commitments	Strategy & performance - Performance on our Strategy - Sustainability - Social
Responsible Investment Programme	ABN AMRO responsible investment implementation and performance	Strategy & performance - Performance on our Strategy - Sustainability
Responsible Investment Programme	ABN AMRO objectives and targets related to responsible investment	Strategy & performance - Performance on our Strategy - Sustainability - Sustainability asset volume
Tax Disclosure	ABN AMRO taxes paid on a country-by-country basis for all of the countries in which it operates	Financial Statements - Note 11
Tax Disclosure	ABN AMRO reports on taxes paid by region, continent or using a mixed approach	Financial Statements - Note 11
GHG Reduction Programme	ABN AMRO GHG emissions monitoring and measurement	Sustainability Statements - Environment - Climate change - GHG monitoring ESG Annex - GHG emissions - own operations


ABN AMRO	Annual Report 2025	293


≡	Sustainability Statements	ESG Annex


Rating Label	Annual Report title	Reference
GHG Reduction Programme	ABN AMRO regular GHG audits or verification	Limited assurance report of the independent auditor
GHG Reduction Programme	ABN AMRO GHG reduction target	Sustainability Statements - Environment - Climate change ESG Annex - GHG emissions - own operations
GHG Reduction Programme	ABN AMRO emissions reduction coverage	Sustainability Statements - Environment - Climate change
GHG Reduction Programme	ABN AMRO Net-zero and Science Alignment	Sustainability Statements - Environment - Climate change
GHG Reduction Programme	ABN AMRO Interim targets	Sustainability Statements - Environment - Climate change Sustainability Statements - ESG Annex
GHG Reduction Programme	ABN AMRO initiatives in place to reduce emissions	Sustainability Statements - Environment - Climate change
GHG Reduction Programme	ABN AMRO's demonstration of how initiatives are put in place to close the emissions gap between current performance and the targeted emissions reduction	Sustainability Statements - Environment - Climate change
GHG Reduction Programme	ABN AMRO initiatives that are linked to wider TCFD reporting	Sustainability Statements - Environment - Climate change
GHG Reduction Programme	ABN AMRO adoption of key mitigation technologies	Risk chapter - Risk response
Verification of ESG Reporting	ABN AMRO external verification of ESG reporting	Limited assurance report of the independent auditor
ESG Risk Management (ESRM) Oversight	ABN AMRO Board-level engagement on climate-related risks	Sustainability Statements - Governance of Sustainability Matters
Practices	ABN AMRO employee training on consumer financial protection	Sustainability Statements - Social - Suitability of products and services
Practices	ABN AMRO financial education initiatives and stakeholder outreach	Strategy & performance - Performance on our strategy - Sustainability - Social Sustainability Statements - Consumers and end-users - Suitability of products
Talent Pipeline development strategy	ABN AMRO formal talent pipeline development strategy	Sustainability Statements - Own workforce - Training and skills development metrics
Talent Pipeline development strategy	ABN AMRO graduate traineeship/apprenticeship programme	See abnamro.com
Talent Pipeline development strategy	ABN AMRO collaboration with educational institutions to develop or deliver joint training programmes for staff	Sustainability Statements - Own workforce - Training and skills development metrics
Programs & Initiatives	ABN AMRO employee equity programmes - incl. coverage	Sustainability Statements - Own workforce
Programs & Initiatives	ABN AMRO workforce that is eligible for non-pay benefits	Governance - Composition of remuneration packages
Programs & Initiatives	ABN AMRO skills and knowledge development training	Sustainability Statements - Own workforce
Distribution and Outreach	ABN AMRO initiatives related to innovation in mobile/ online distribution channels for financial services	Strategy & performance - Performance on our strategy - Customer experience
Distribution and Outreach	ABN AMRO customer service locations	Strategy & performance - Performance on our strategy - Customer experience
Distribution and Outreach	ABN AMRO innovation in other alternative branchless distribution channels for financial services	Strategy & performance - Performance on our strategy - Customer experience
Workforce eligible for non-pay benefits	ABN AMRO workforce that is eligible for non-pay benefits	Leadership & governance - Remuneration report - Remuneration for all staff and identified staff
Practices - Operations	ABN AMRO responsibility for privacy and data security	Sustainability Statements - Consumers and end-users - Privacy of client data
Practices - Employees	ABN AMRO scope of employee training on privacy and data security	Sustainability Statements - Consumers and end-users - Privacy of client data
Climate Change	ABN AMRO gross global scope 1 emissions in metric tons of CO2e	Sustainability Statements - ESG Annex
Climate Change	ABN AMRO gross global scope 2 emissions in metric tons of CO2e	Sustainability Statements - ESG Annex
Climate Change	ABN AMRO gross global scope 3 emissions in metric tons of CO2e	Sustainability Statements - ESG Annex
Climate Change	ABN AMRO energy consumption totals (excluding feedstocks) in MWh	Sustainability Statements - ESG Annex
Climate Change	ABN AMRO financed emissions in the reporting year and in the base year	Sustainability Statements - Environment - Climate change
Climate Change	ABN AMRO breakdown of financed emissions and other portfolio carbon footprinting metrics	Sustainability Statements - Environment - Climate change
Climate Change	ABN AMRO financing or insuring activities that are aligned with, or could be eligible for, the sustainable finance taxonomy	Sustainability Statements - Environment - Climate change


ABN AMRO	Annual Report 2025	294

A nnual Financial

Statements 2025

Consolidated Annual Financial Statements 2025


Consolidated income statement	295
Consolidated statement of comprehensive income	296
Consolidated statement of financial position	297
Consolidated statement of changes in equity	298
Consolidated statement of cash flows	298
Notes to the Consolidated Annual Financial Statements	300
1 Accounting policies	300
2 Segment reporting	308
3 Overview of financial assets and liabilities by measurement base	315
4 Net interest income	316
5 Net fee and commission income	317
6 Net income from other operating activities	319
7 Net trading income	319
8 Net gains/(losses) on derecognition of financial assets measured at amortised cost	320
9 Personnel expenses	320
10 General and administrative expenses	320
11 Income tax expense, tax assets and tax liabilities	321
12 Earnings per share	327
13 Cash and balances at central banks	327
14 Financial assets and liabilities held for trading	327
15 Derivatives	328
16 Hedge accounting	330
17 Financial investments	336
18 Securities financing	338


19 Fair value of financial instruments carried at fair value	339
20 Loans and advances banks	345
21 Loans and advances customers	346
22 Fair value of financial instruments not carried at fair value	346
23 Group structure	349
24 Property and equipment, leases, goodwill and other intangible assets	354
25 Non-current assets and disposal groups held for sale	360
26 Other assets	361
27 Due to banks	361
28 Due to customers	362
29 Issued debt and subordinated liabilities	362
30 Provisions	364
31 Pension and other employee benefits	366
32 Other liabilities	369
33 Equity	369
34 Transferred, pledged, encumbered and restricted assets	371
35 Commitments and contingent liabilities	374
36 Remuneration of Executive Board and Supervisory Board	379
37 Share-based payment	381
38 Related parties	382
39 Capital management	384
40 Post balance sheet events	385
Authorisation of the Consolidated Annual Financial Statements	385
Company Annual Financial Statements of ABN AMRO Bank N.V.	386


ABN AMRO	Annual Report 2025	295


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Consolidated income statement


(in millions)	Note	2025	2024
Income
Interest income calculated using the effective interest method		14,205	16,757
Other interest and similar income		253	351
Interest expense calculated using the effective interest method		8,019	10,532
Other interest and similar expense		103	72
Net interest income	4	6,335	6,504
Fee and commission income		2,635	2,414
Fee and commission expense		502	504
Net fee and commission income	5	2,132	1,910
Income from other operating activities		101	311
Expenses from other operating activities		70	84
Net income from other operating activities	6	30	226
Net trading income	7	219	283
Share of result in equity-accounted investments		28	9
Net gains/(losses) on derecognition of financial assets measured at amortised cost	8	-29	-71
Operating income		8,716	8,861
Expenses
Personnel expenses	9	3,104	2,776
General and administrative expenses	10	2,326	2,531
Depreciation, amortisation and impairment losses of tangible and intangible assets	24	180	160
Operating expenses		5,610	5,467
Impairment charges on financial instruments		20	-21
Total expenses		5,630	5,446
Profit/(loss) before taxation		3,086	3,415
Income tax expense	11	834	1,013
Profit/(loss)		2,252	2,403
Attributable to:
Owners of the parent company		2,252	2,403
Earnings per share (in EUR)
Basic earnings per ordinary share (in EUR)¹	12	2.45	2.72
1. Earnings per share consist of profit for the period, excluding results attributable to non-controlling interests and payments to holders of AT1 instruments, divided by the average outstanding and paid-up ordinary shares (31 December 2025: 829,609,770; 31 December 2024: 840,546,121).


ABN AMRO	Annual Report 2025	296


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Consolidated statement of comprehensive income


(in millions)	2025		2024
Profit/(loss) for the period		2,252		2,403
Other comprehensive income:
Items that will not be reclassified to the income statement
Remeasurement gains/(losses) on defined benefit plans		5		-7
Gains/(losses) on liability own credit risk		-1		2
Items that will not be reclassified to the income statement before taxation		4		-5
Income tax relating to items that will not be reclassified to the income statement		1		-1
Items that will not be reclassified to the income statement after taxation		3		-4
Items that may be reclassified to the income statement
Net gains/(losses) currency translation reserve	-185		61
Net gains/(losses) currency translation reserve through OCI		-185		61
Net gains/(losses) fair value reserve through OCI		610		-521
Net gains/(losses) cash flow hedge reserve	92		129
Less: Reclassification cash flow hedge reserve through the income statement	-204		-194
Net gains/(losses) cash flow hedge reserve through OCI		295		323
Share of other comprehensive income of associates		0		-3
Items that may be reclassified to the income statement before taxation		720		-140
Income tax relating to items that may be reclassified to the income statement		234		-50
Items that may be reclassified to the income statement after taxation		486		-90
Total comprehensive income/(expense) for the period after taxation		2,741		2,308
Attributable to:
Owners of the parent company		2,741		2,308


ABN AMRO	Annual Report 2025	297


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Consolidated statement of financial position


(in millions)	Note	31 December 2025	31 December 2024
Assets
Cash and balances at central banks	13	49,486	44,464
Financial assets held for trading	14	2,044	2,503
Derivatives	15	3,933	4,347
Financial investments	17	50,231	47,173
Securities financing	18	40,173	26,989
Loans and advances banks	20	2,170	2,049
Loans and advances customers	21	255,760	248,782
Equity-accounted investments	23	233	244
Property and equipment	24	1,221	1,068
Goodwill and other intangible assets	24	356	253
Assets held for sale	25	2,466	1,330
Tax assets	11	143	326
Other assets	26	4,993	5,518
Total assets		413,210	385,047
Liabilities
Financial liabilities held for trading	14	1,631	1,163
Derivatives	15	1,967	2,499
Securities financing	18	15,320	10,352
Due to banks	27	4,320	2,329
Due to customers	28	279,126	256,186
Issued debt	29	74,072	74,542
Subordinated liabilities	29	4,946	6,613
Provisions	30	666	612
Liabilities held for sale	25	20	0
Tax liabilities	11	183	395
Other liabilities	32	3,918	4,247
Total liabilities		386,167	358,939
Equity
Share capital		823	833
Share premium		11,745	11,849
Other reserves (incl. retained earnings/profit for the period)		11,159	10,358
Accumulated other comprehensive income		80	-409
AT1 capital securities		3,233	3,475
Equity attributable to owners of the parent company		27,040	26,105
Equity attributable to non-controlling interests		3	3
Total equity	33	27,043	26,108
Total liabilities and equity		413,210	385,047


ABN AMRO	Annual Report 2025	298


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Consolidated statement of changes in equity


(in millions)	Share capital	Share premium	Other reserves including retained earnings	Accumulated other com- prehensive income³	Net profit/(loss) attributable to owners of the parent company	AT1 capital securities	Equity attributable to the owners of the parent company	Non- controlling interests	Total equity
Balance as at 1 January 2024	866	12,192	6,739	-315	2,697	1,987	24,165	3	24,168
Total comprehensive income				-94	2,403		2,308	0	2,308
Transfer			2,697		-2,697		0		0
Dividend			-1,244				-1,244	0	-1,244
Increase of capital	0	0				1,488	1,488		1,488
Share buyback	-33	-343	-124				-500		-500
Paid interest on AT1 capital securities			-120				-120		-120
Other changes in equity¹	0	0	7	0	0	0	7	0	7
Balance as at 31 December 2024	833	11,849	7,955	-409	2,403	3,475	26,105	3	26,108
Total comprehensive income				489	2,252		2,741	0	2,741
Transfer			2,403		-2,403		0		0
Dividend			-1,074				-1,074		-1,074
Increase of capital						751	751		751
Decrease of capital²						-1,000	-1,000		-1,000
Share buyback³	-10	-104	-136				-250		-250
Paid interest on AT1 capital securities			-217				-217		-217
Other changes in equity ^{2, 3}			-24			7	-17		-17
Balance as at 31 December 2025	823	11,745	8,907	80	2,252	3,233	27,040	3	27,043
1. Reclassification of fair value reserve to retained earnings following the sale of Neuflize Vie.
2. On 22 September 2025, ABN AMRO Bank N.V. called AT1 Capital Securities of EUR 1.0 billion. Upon repayment, the related discount of EUR 7 million was released through retained earnings.
3. On 6 August 2025, ABN AMRO Bank N.V. announced a share buyback program of EUR 250 million. The withholding tax related to this share buyback amounted to EUR 17 million. For more information on the share buyback, please refer to Note 33 Equity.

Consolidated statement of cash flows


(in millions)	Note	2025	2024
Profit/(loss) for the period		2,252	2,403
Adjustments on non-cash items included in profit/(loss)
(Un)realised gains/(losses)		2,229	-1,946
Share of result in equity-accounted investments		-30	-9
Depreciation, amortisation and impairment losses of tangible and intangible assets	24	180	160
Impairment charges on financial instruments		20	-21
Income tax expense	11	834	1,013
Tax movements other than taxes paid & income taxes		4	133
Other non-cash adjustments		683	750
Operating activities
Changes in:
- Assets held for trading		462	-1,125
- Derivatives - assets		841	-176
- Securities financing - assets		-13,896	-4,511
- Loans and advances banks		200	-81
- Loans and advances customers		-9,249	-1,818
- Other assets		395	-114
- Liabilities held for trading		459	240
- Derivatives - liabilities		-644	-77
- Securities financing - liabilities		6,211	-1,909
- Due to banks		1,713	-2,557
- Due to customers		11,105	1,365
Net changes in all other operational assets and liabilities		-466	-1,802
Dividend received from associates and private equity investments		12	23
Income tax paid		-1,079	-737
Cash flow from operating activities		2,235	-10,795


ABN AMRO	Annual Report 2025	299


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


(in millions)	Note	2025	2024
Investing activities
Purchases of financial investments		-37,352	-49,211
Proceeds from sales and redemptions of financial investments		36,240	44,645
Acquisition of subsidiaries (net of cash acquired), associates and joint ventures	23	5,955	-25
Divestments of subsidiaries (net of cash sold), associates and joint ventures	23	45	183
Purchases of property and equipment		-294	-312
Proceeds from sales of property and equipment		70	48
Purchases of intangible assets		-98	-140
Cash flow from investing activities		4,565	-4,811
Financing activities
Proceeds from the issuance of debt	29	49,649	42,885
Repayment of issued debt	29	-48,161	-36,980
Proceeds from subordinated liabilities issued	29	21	767
Repayment of subordinated liabilities issued	29	-1,342	-21
Proceeds/(repayment) from other borrowing		-249	1,488
Proceeds/(repayment) from capital securities		-17	0
Purchase of treasury shares		-250	-500
Dividends paid to the owners of the parent company	33	-1,085	-1,244
Interest paid AT1 capital securities		-217	-120
Payment of lease liabilities		-121	-112
Cash flow from financing activities		-1,772	6,162

Net increase/(decrease) of cash and cash equivalents		5,028	-9,444
Cash and cash equivalents as at 1 January		45,629	55,054
Effect of exchange rate differences on cash and cash equivalents		-39	19
Cash and cash equivalents as at 31 December		50,618	45,629

Supplementary disclosure of operating cash flow information
Interest paid		8,019	10,419
Interest received		14,457	17,016
Dividend received excluding associates		9	9


(in millions)	31 December 2025	31 December 2024
Cash and balances at central banks	49,486	44,464
Loans and advances banks (less than 3 months) ¹	1,132	1,165
Total cash and cash equivalents¹	50,618	45,629
1. Loans and advances banks with an original maturity of 3 months or more is included in loans and advances banks.


ABN AMRO	Annual Report 2025	300


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Notes to the Consolidated

Annual Financial Statements

1 Accounting policies

The notes to the Consolidated Annual Financial Statements, including the audited information in the Risk, funding & capital

chapter, are an integral part of these Annual Financial Statements. This section describes ABN AMRO Bank’s material

accounting policies and critical accounting estimates or judgements relating to the Annual Financial Statements. If

an accounting policy or a critical accounting estimate relates to a specific note, it is included in the relevant note.

Corporate information

ABN AMRO Bank N.V. (referred to as ABN AMRO Bank, ABN AMRO, the bank or the parent company) and its consolidated

entities provide financial services in the Netherlands and abroad (together referred to as the group). ABN AMRO Bank is

a public limited liability company, incorporated under Dutch law on 9 April 2009 in the Netherlands, and registered at

Gustav Mahlerlaan 10, 1082 PP Amsterdam, the Netherlands (Chamber of Commerce number 34334259).

At 31 December 2025, all shares in the capital of ABN AMRO Bank N.V. were held by two foundations: NLFI and

STAK AAB. NLFI was holding 27.5% in ABN AMRO Bank N.V., of which 25.2% were held directly via ordinary shares

and 2.3% were held indirectly via depositary receipts for shares in ABN AMRO Bank N.V. STAK AAB was holding 72.5%

of the shares in the issued capital of ABN AMRO Bank N.V. Both foundations have issued depositary receipts for shares

in ABN AMRO Bank N.V. Only STAK AAB’s depositary receipts are issued with the cooperation of ABN AMRO Bank N.V.

and traded on Euronext Amsterdam.

ABN AMRO provides a broad range of financial services to retail, private and corporate banking clients. These activities

are conducted primarily in the Netherlands and selectively abroad.

The Consolidated Annual Financial Statements of ABN AMRO Bank for the year ended 31 December 2025 incorporate

financial information of ABN AMRO Bank N.V., as well as that of the bank's controlled entities, interests in associates

and joint ventures. The Annual Financial Statements were prepared by the Executive Board and authorised for issue by

the Supervisory Board and Executive Board on 10 March 2026.

Statement of compliance

The Consolidated Annual Financial Statements have been prepared in accordance with International Financial

Reporting Standards (IFRS), as endorsed by the European Union (EU). They also comply with the financial reporting

requirements set out in Title 9 of Book 2 of the Dutch Civil Code, where applicable.

Basis of preparation

The Consolidated Annual Financial Statements have been prepared on a historical cost basis, except for certain items that

are measured at fair value. Derivative financial instruments, financial assets and liabilities held for trading or designated

as measured at fair value through profit or loss, financial instruments not held in a 'hold to collect' business model, debt

instruments that do not meet the solely payments of principal and interest (SPPI) test, and equity investments

in associates or joint ventures for which the venture capital exemption is applied, are measured at fair value through

profit or loss. Certain interest-earning financial investments are valued at fair value through other comprehensive income

(FVOCI). As these instruments do not meet the requirements regarding frequency of sales, they are not classified

in a 'hold to collect' business model. The carrying values of recognised assets and liabilities included in fair value hedges

and otherwise carried at amortised cost are adjusted to record changes in fair value attributable to the risks that are

being hedged. Associates and joint ventures are accounted for using the equity method.

The Annual Financial Statements are presented in euros, which is the presentation currency of ABN AMRO, rounded

to the nearest million (unless otherwise stated).


ABN AMRO	Annual Report 2025	301


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

The financial statements are prepared on a going concern basis.

Changes in accounting policies

Amendments to existing standards

The International Accounting Standards Board (IASB) issued a number of amendments to existing standards (and

endorsed by the EU), which became effective for the reporting period beginning 1 January 2025. The standard

amended is:

• IAS 21 The Effects of Changes in Foreign Exchange Rates: Lack of Exchangeability

The impact of this amendment on the consolidated financial statements is insignificant for ABN AMRO and has not

resulted in major changes to ABN AMRO’s accounting policies.

New standards, amendments and interpretations not yet effective

The IASB has issued the following new standards. These new standards will become effective on 1 January 2027 if

they are endorsed by the EU. ABN AMRO will not early adopt these standards.

IFRS 18 Presentation and Disclosure in Financial statements

In April 2024 the IASB issued IFRS 18, which is set to replace IAS 1 Presentation and Disclosures in Financial

Statements. The main changes introduced by IFRS 18 relate to three areas:

• Presentation of two new defined subtotals in the statement of profit or loss and consistent classification of income

and expenses in categories. The standard identifies five categories - operating, investing, financing, income taxes

and discontinued operations.

• Disclosure of information about management-defined performance measures in the notes to the financial

statements.

• Enhanced requirement for grouping (aggregation and disaggregation) of information. These changes are focused on

the statement of profit or loss and relate solely to presentation and disclosure requirements.

The expected impact of these changes on the consolidated financial statements of ABN AMRO is being finalised.

The main changes are on the face of the consolidated income statement, where classification of certain income and

expenses will change and new subtotal(s) will be introduced. At Capital Markets Day, the bank introduced a new

subtotal that it will use in it's communications: Commercial Net Interest Income. This subtotal qualifies as a

management-defined performance measure under IFRS 18 and will be treated as such upon application of the

standard. The standard will not affect reported profit or equity.

IFRS 19 Subsidiaries without Public Accountability

In May 2024 the IASB issued IFRS 19, which specifies disclosure requirements that certain entities are allowed to apply

instead of the disclosure requirements in other IFRS. Given that ABN AMRO is not an entity that can apply IFRS 19, this

new standard does not impact ABN AMRO.

Amendments to existing standards not yet effective

The IASB has issued amendments to several standards, some of which have not yet been endorsed by the EU.

ABN AMRO will not early adopt the amendments that have been endorsed by the EU. These amendments are to take

effect on or later than 1 January 2026. The standards amended are:

• IFRS 9 and IFRS 7 Classification and Measurement of Financial Instruments;

• Annual Improvements Volume 11;

• Contracts Referencing Nature-dependent Electricity – Amendments to IFRS 9 and IFRS 7; and

• IFRS 19 Subsidiaries without Public Accountability.

ABN AMRO is still investigating the impact of these amendments but preliminary results show that no significant

impact is expected.

Changes in presentation

In 2025, ABN AMRO updated the presentation of the consolidated statement of financial position to simplify the

structure, reduce duplication and provide more relevant information. First, all loans and advances to customers are

aggregated in one line item in the consolidated statement of financial position, as are all due to customers.


ABN AMRO	Annual Report 2025	302


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Disaggregated information continues to be provided in the notes. This change has subsequently resulted in changes to

the line items reported under the assets and liabilities per segment in the segment reporting note and changes to the

adjustments in the operating section of the consolidated statement of cash flows to allow for comparability. Second,

committed credit facilities and guarantees and other commitments are no longer presented on the face of the

consolidated statement of financial position. All relevant information on these two items continues to be disclosed in

the notes. Comparative figures have been updated accordingly.

Critical accounting estimates and judgements

In preparing the financial statements, management needs to exercise its judgement in the process of applying

ABN AMRO’s accounting policies and make estimates and assumptions concerning the future. Actual results may differ

from those estimates and assumptions. Accounting policies for the most significant areas that require management

to make judgements and estimates affecting reported amounts and disclosures are made in the following sections:

• Impairment losses on financial assets measured at amortised costs - Risk, funding & capital chapter and Note 1

• Income tax expense, tax assets and tax liabilities - Note 11

• Impairment of instruments measured at FVOCI - Note 17

• Fair value of financial instruments - Note 19

• Impairment of ROU assets and goodwill - Note 24

• Provisions - Note 30

Assessment of risks, rewards and control

Whenever ABN AMRO is required to assess risks, rewards and control, as well as when considering the recognition and

derecognition of assets or liabilities and the consolidation or deconsolidation of subsidiaries, the use of judgement

may sometimes be required. Although management uses its best knowledge of current events and actions in making

such assessments, the actual risks, rewards and control may ultimately differ.

Material accounting policies

Basis of consolidation

The Consolidated Annual Financial Statements of ABN AMRO Bank N.V. include the financial statements of the parent

company and the entities it controls, thus incorporating the assets, liabilities, revenues and expenses of

ABN AMRO Bank N.V. and its subsidiaries. Non-controlling interests (held by third parties) in the equity and results

of group companies are presented separately in the Consolidated Annual Financial Statements.

Subsidiaries are included using the same reporting period and consistent accounting policies. Intercompany balances

and transactions, as well as any related unrealised gains and losses, are eliminated in preparing the

Consolidated Financial Statements.

Foreign currency

ABN AMRO applies IAS 21 The Effects of Changes in Foreign Exchange Rates. Transactions in foreign currencies are

translated into euros at the rate prevailing on the transaction date. Foreign currency balances of monetary items are

translated into euros at period-end exchange rates. Exchange gains and losses on such balances are recognised

in the income statement.

The Consolidated Annual Financial Statements are stated in euros, which is the presentation and functional currency

of ABN AMRO. The bank’s foreign operations may have different functional currencies. The functional currency is

the currency that best reflects the economic substance of the underlying event and circumstances relevant to that

entity. Prior to consolidation (or equity accounting), the assets and liabilities of non-euro operations are translated into

euros at the closing rate, and items in the income statement and other comprehensive income are translated at

the rate prevailing on the transaction dates. Exchange differences arising on the translation of foreign operations are

included in the currency translation reserve within equity. These amounts are transferred to the income statement

when the bank loses control, joint control or significant influence over the foreign operation.

Financial assets and liabilities

Classification and measurement of financial assets

ABN AMRO classifies financial assets based on the business model in which they are held in accordance with IFRS 9.

The business model is determined at portfolio level. Portfolios are based on how ABN AMRO manages financial assets


ABN AMRO	Annual Report 2025	303


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

in order to achieve a particular business objective. The business model assessment is based on the level of sales, risk

management, performance evaluation and management compensation. Derecognition is used as a condition

to determine whether a transaction results in a sale.

Three business models are distinguished:

• ‘Hold to collect’ business model, in which cash flows are primarily generated by collecting contractual cash flows

until maturity of the financial instrument. Sales can occur, as long as they are incidental, infrequent and insignificant.

The assessment of the frequency and significance of sales is determined for each underlying portfolio. Sales that

result from increases in the credit risk of the counterparty or take place close to maturity do not contradict the ‘hold

to collect’ business model.

• ‘Hold to collect and sell’ business model, in which the selling of financial assets is integral to achieving the business

objective. In this business model, sales take place more frequently and have a greater value than in a 'hold to collect'

business model.

• Other business models not meeting the criteria of the business models mentioned above, for example business

models in which financial assets are managed with the objective of generating cash flows from sales (trading book),

are measured at FVTPL.

After the business model has been determined, the contractual cash flows of financial assets are assessed.

Debt instruments can be classified at amortised cost or FVOCI only when the contractual cash flows are solely

payments of principal and interest (SPPI). Contractual cash flows that are SPPI are consistent with a basic lending

arrangement in which consideration for the time value of money and credit risk are typically the most significant

interest elements. Debt instruments that do not meet the SPPI requirements are mandatorily measured at FVTPL.

Financial assets are assessed in their entirety, including any embedded derivatives that are not separated from the host

contract.

Based on the business model determined and the SPPI assessment, the following measurement categories are

identified under IFRS 9:

• Amortised cost – Financial instruments measured at amortised cost are debt instruments within a ‘hold to collect’

business model with fixed or determinable payments which meet the SPPI criteria. These instruments are initially

measured at fair value (including transaction costs) and subsequently measured at amortised cost using the effective

interest rate method. Financial instruments measured at amortised cost are presented net of credit loss allowances

in the statement of financial position.

• FVTPL – Financial instruments measured at FVTPL include instruments held for trading, derivatives, equity

instruments for which the FVOCI option has not been elected and instruments whose cash flows do not meet

the SPPI requirements. Changes in the fair value of these instruments are directly recognised in the income

statement.

• FVOCI – Financial instruments measured at FVOCI are debt instruments which are held in a ‘hold to collect and sell’

business model and which meet the SPPI criteria. They are initially measured at fair value, with subsequent

unrealised changes recognised in other comprehensive income. Equity instruments for which the fair value option is

elected are also measured at FVOCI.

Reclassifications of financial assets are expected to be very infrequent and occur only when ABN AMRO changes its

business model for a certain portfolio of financial assets.

Measuring allowances for expected credit losses

ABN AMRO recognises loss allowances based on the Expected Credit Loss model (ECL) of IFRS 9, which is designed to

be forward-looking. The amount of ECL is based on the probability-weighted present value of all expected cash

shortfalls over the remaining life of the financial instrument for both on- and off-balance sheet exposures. ABN AMRO

distinguishes between two types of calculation methods for credit loss allowances:

• Individual Lifetime ECL (LECL) for credit impaired (stage 3) financial instruments with exposures above

EUR 5 million;

• Collective 12-month ECL (stage 1) and LECL (stage 2 and 3) for financial instruments that have similar credit risk

characteristics (e.g. residential mortgages, consumer loans and SME loans); these are clustered in portfolios and

collectively assessed for impairment losses. A collective impairment calculation approach based on individual

parameters is also applied to stage 3 exposures below EUR 5 million. ABN AMRO has models to quantify the


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Probability of Loss (PL), Loss Given Loss (LGL) and Exposure at Loss (EAL) for the purpose of calculating the collective

12-month ECL and LECL for these financial instruments.

The IFRS 9 impairment requirements are applicable to financial assets measured at amortised cost or fair value

through other comprehensive income (FVOCI), loan commitments, lease receivables and contract assets and financial

guarantee contracts. At each reporting date, these financial instruments are classified into one of three risk stages,

depending on current credit quality, or as purchased or originated credit impaired (POCI).

POCI assets, which are credit impaired at initial recognition, are accounted for at fair value (i.e. net of the initial lifetime

ECLs) and do not carry an impairment allowance. Instead, a credit-adjusted effective interest rate (EIR), which is

calculated using expected cash flows including initial lifetime ECLs, is applied to the amortised cost. Subsequently, the

cumulative changes in lifetime ECLs since initial recognition, which are discounted at the credit-adjusted effective

interest rate, are recognised in the profit or loss statement as an impairment gain or loss, and presented under

impairment charges on financial instruments. Once a financial asset is classified as POCI, it retains that classification

until it is derecognised.

Risk staging

We use quantitative and qualitative stage triggers to determine whether a financial instrument should be classified as

stage 1 or stage 2. A transfer to stage 3 will always be the result of the default of a financial instrument.

Quantitative stage triggers

The key quantitative metric that determines when a financial instrument is transferred from stage 1 to stage 2 is the

deterioration in the lifetime probability of default (LPD) from the date of origination to the reporting date, based on

internal data. The LPD represents the likelihood that a counterparty will default during the lifetime of the financial

instrument and depends on credit risk drivers such as:

• product characteristics (e.g. repayment and interest terms, term of the product);

• the financial condition of the borrower;

• the number of days past due;

• expected developments in the economy.

The lifetime PD deterioration (LPDD) measures the relative difference between the remaining lifetime PD at reporting

(LPDR) and the remaining lifetime PD at origination (LPDO) as LPDD = LPDR/LPDO. If the LPD deterioration of an

exposure is above a predefined threshold, the LPD is considered to be significantly deteriorated. The exposure is then

transferred to stage 2 and impairment allowances equal to the lifetime expected credit loss are recognised. If the LPD

deterioration subsequently reduces and falls below the threshold, the balance is transferred back to stage 1. When

determining the thresholds, ABN AMRO distinguishes between various portfolios within consumer lending, residential

mortgages and corporate loans. A specific threshold is calculated for each portfolio, based on a statistical method.

Qualitative stage triggers

The bank transfers a financial instrument from stage 1 to stage 2 if the instrument meets any of the following

qualitative triggers:

• Forborne status of a borrower;

• Watch status of a borrower. ABN AMRO assigns the watch status to counterparties with an increased credit risk. This

process comprises intensive monitoring, early detection of deterioration in the credit portfolio and appropriate

follow up measures;

• A delinquency-based regulatory backstop is in place, such that the credit risk of financial assets that are more than

30 days past due will be assumed to have significantly increased.

Reclassification to stage 1

As a general rule, favourable changes in credit risk are recognised consistently with unfavourable changes, and a

financial instrument is transferred back to stage 1 if quantitative or qualitative triggers are no longer met. In some

cases, a probation period applies:

• Forborne financial instruments are transferred back from stage 2 to stage 1 only after a probation period of at least

two years has ended, in line with the ABN AMRO forbearance policy. Stage 3 forborne instruments transfer back to

stage 2 after a cure period of at least one year;


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• For financial instruments that are 30 days past due, a three-month probation period is applied for transfers from

stage 2 to stage 1.

Classification in stage 3

A transfer to stage 3 will always be the result of the default of a financial instrument. The definition of default for

IFRS 9 is aligned with the regulatory capital definition. A default is deemed to have occurred when:

• the counterparty is past due by more than 90 days on any material financial credit obligation to the bank; or

• the bank considers the borrower to be unlikely to meet its contractual obligations (unlikely to pay, or UTP).

The materiality of a financial obligation past due is assessed against an absolute and a relative threshold, in line with

regulatory standards. To determine unlikeliness to pay, the bank has specified mandatory default triggers (always

resulting in the assignment of a default status, whereby no additional expert judgement is allowed) and judgemental

triggers (requiring an assessment by credit risk managers to determine whether the UTP indications should result in a

default classification).

The mandatory triggers include the reporting of a forborne exposure under probation as non-performing for being

30 days past due or owing to an additional forbearance measure being applied. As a result, the definitions of non-

performing and default are materially aligned.

Reclassification to stage 2

The default classification for non-forborne exposures ends when the default triggers no longer apply and a probation

or cure period of at least three months has passed since the default trigger was last applied. For forborne exposures, a

twelve-month cure period starts from the moment the last forbearance measure or default trigger was applied. After

the cure period, an assessment is performed to establish whether the improvement in the credit quality is factual and

permanent (including, for example, no remaining past due amounts).

Lifetime expected credit loss

ABN AMRO defines the lifetime of credit as the maximum contractual period during which the bank is exposed to

credit risk; we do not apply a longer period, even if that longer period is consistent with business practice. For some

contracts, such as overdraft facilities or credit cards, no end date is specified or amounts can be contractually

withdrawn by the lender at short notice. In these cases, ABN AMRO uses behavioural maturity models that rely on

historical client behaviour to determine future expected exposures.

Forward-looking information

For expected credit loss calculations, ABN AMRO uses three different scenarios of future economic developments: a

baseline (or most likely) scenario, a negative scenario and a positive scenario. The three scenarios are incorporated into

the expected credit loss calculation and risk stage determination in a probability-weighted manner. In order to

incorporate the latest economic outlook, the scenarios and their weights are reviewed each quarter and adjusted if

necessary. Details of the scenarios and their weights used in the reporting period can be found in the Credit risk review

section. The baseline scenario entails our Group Economics analysts’ current macroeconomic base scenario, which

usually covers the current year and subsequent year. For the purpose of scenario analysis under IFRS 9, this baseline is

extended by three or four additional calendar years, after which it is assumed that macroeconomic variables (MEVs)

gradually move to their potential or equilibrium values. At least once every quarter, Group Economics compares its

forecasts with those of institutions like the Netherlands Bureau for Economic Policy Analysis (CPB), the Dutch central

bank (DNB), ECB, IMF or OECD in order to determine possible differences and to analyse whether it can underpin

them. This external benchmarking exercise is a standard input to the Scenario Booklet that is presented to the bank’s

Scenario and Stress Testing Committee for approval. Group Economics also develops a negative and a positive

scenario. These scenarios are designed to give an impression of the bandwidth within which the economy, interest and

FX rates, and other relevant variables are likely to move in the next four to five years, with a probability of around 85%

(roughly corresponding to a standard deviation of plus and minus one and a half). Hence, these scenarios produce

upper and lower boundaries, with a resulting bandwidth between the outcomes of the negative (‘bad weather’ in

terms of financial results of the bank) and positive (‘good weather’) scenarios. To determine these boundaries, Group

Economics may look at historical developments, medium-term (non-baseline) scenarios made by the above

institutions and other relevant developments.


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Management overlays and other adjustments

Where necessary to reflect credit risk dynamics not captured by our models, management judgement is applied via a

management overlay or other IFRS 9 adjustment. A management overlay is a temporary adjustment in a loss

allowance until a long-term solution (e.g. model adjustment) is effective, and must be an amount commensurate to

the model limitation. All overlays require a decision by the Impairment and Provision Committee (IPC). The main types

of management overlays that ABN AMRO distinguishes are: post-model adjustments (adjustments to model

outcomes), adjustments in the weightings of macroeconomic scenarios and stage overrides. Other adjustments such

as adjustments to model parameters or input data are not considered management overlays, but follow the same

internal approval process.

Cured financial assets

When a credit impaired financial asset cures, the interest that was previously unrecognised is reported as an

impairment release in the impairment charge rather than as a credit to the interest income calculated using the

effective interest method.

Write-off

Under IFRS 9, ‘write-off’ refers to the process of recognising that a financial asset, or a portion of it, is uncollectible and

should be removed from an entity’s balance sheet. This typically happens when there is no reasonable expectation of

recovering the asset, indicating that the entity has exhausted all practical recovery efforts.

• For non-programme lending, a loan must be written off if all possible means of recovery have been exhausted and it

has become clear that there is a low probability of recovering the debt, either in part or full.

• Most of the programme lending facilities are automatically written off after 1,080 days in default.

Such loans are written off after all the necessary procedures have been completed and the amount of the loss has

been determined. Subsequent recoveries of amounts previously written off are credited to impairment charges on

financial instruments in the income statement.

Credit enhancements

Financial guarantees held are included in the ECL calculations of a financial asset when they are an integral element of

the contractual terms of the financial asset. Financial guarantees that do not form an integral element of the

contractual terms of a financial asset are accounted for as a separate asset.

Classification of assets and liabilities held for trading

A financial asset or financial liability is classified as 'held for trading' if it is:

• acquired or incurred principally for the purpose of selling or repurchasing it in the near term

• part of a portfolio of identified financial instruments that are managed together and for which there is evidence

of a recent actual pattern of short-term profit making, or

• a trading derivative (except for a derivative that is a designated and effective hedging instrument).

Classification and measurement of financial liabilities

Financial liabilities are initially recognised at their fair value minus transaction costs that are directly attributable

to the acquisition or issue of the financial liability. Under IFRS 9, financial liabilities are classified as subsequently

measured at amortised cost, except for the following instruments:

• financial liabilities held for trading are measured at fair value through profit or loss

• financial liabilities that ABN AMRO has irrevocably designated as held at fair value through profit or loss at initial

recognition, which are held to reduce an accounting mismatch, are managed on the basis of their fair value or

include terms that have derivative characteristics by nature.

Under IFRS 9, the changes in fair value attributable to changes in the credit risk of financial liabilities designated at

FVTPL are presented in other comprehensive income. The cumulative amount of changes in fair value attributable

to credit risk of such liabilities is presented as liability own credit risk reserve in equity.

Financial liabilities are never reclassified after initial recognition.


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Recognition and derecognition

Traded instruments are recognised on the trade date, which is defined as the date on which ABN AMRO commits

to purchase or sell the underlying instrument. If the settlement terms are non-standard, the commitment is accounted

for as a derivative between the trade and settlement dates. Loans and advances are recognised when they are

acquired or funded by ABN AMRO and derecognised when settled. Issued debt is recognised when issued, and

deposits are recognised when the cash is deposited with ABN AMRO. Other financial assets and liabilities, including

derivatives, are recognised when ABN AMRO becomes a party to the contractual provisions of the asset or liability.

Financial assets are derecognised when ABN AMRO loses control and the ability to obtain benefits from

the contractual rights that comprise that asset. This occurs when the rights are realised or expire, or when substantially

all risks and rewards are transferred. Financial assets are also derecognised if the bank has neither transferred nor

retained substantially all risks and rewards of ownership, but control has passed to the transferee. Financial assets

continue to be recognised in the balance sheet, and a liability recognised for the proceeds of any related funding

transaction, unless a fully proportional share of all or specifically identified cash flows are transferred to the lender

without material delay and the lender’s claim is limited to those cash flows, and substantially all the risks, rewards and

control associated with the financial instruments, that have been transferred, in which case that proportion of the asset

is derecognised.

When the terms and conditions of a financial asset have been renegotiated or otherwise modified to the extent that,

substantially, it becomes a new financial asset, ABN AMRO derecognises the financial asset, with the difference

recognised in the income statement, to the extent that an impairment loss has not already been recorded. The newly

recognised financial asset is classified as stage 1 for ECL measurement purposes. ABN AMRO assesses, in both

qualitative and quantitative terms, whether such modifications are substantial. Generally, a 10% change in the net

present value of the cash flows between the initial and new contract results in a derecognition. With regard

to substantial modifications, e.g. due to forbearance measures, the derecognition gains or losses are recognised in net

gains/(losses) on derecognition of financial assets measured at amortised cost and disclosed separately, if material.

If the modification of the financial asset does not result in derecognition, the gross carrying amount of the financial

asset is recalculated, based on the net present value of the new contractual cash flows, and discounted at the financial

asset’s original effective interest rate. The effect is recognised and disclosed as a modification gain or loss

in the income statement. Credit related modification gains or losses (i.e. due to forbearance measures) are recognised

in the income statement and presented under impairment charges on financial instruments. Non-credit related

modification gains or losses are recognised in the income statement and presented under interest income calculated

using the effective interest method.

Financial liabilities are derecognised when the liability has been settled, has expired or has been extinguished.

An exchange of an existing financial liability for a new liability with the same lender on substantially different terms,

qualitatively and quantitatively (a 10% difference in the present value of the cash flows), is accounted for as

an extinguishment of the original financial liability and recognition of a new financial liability. The difference between

the former amortised cost and the consideration paid is recognised in the income statement.

Client clearing

As a general clearing member, ABN AMRO provides clearing and settlement services to its clients for, among other

things, exchange-traded derivatives.

In its capacity as a clearing member, ABN AMRO guarantees the fulfilment of obligations towards central counterparty

clearing houses (CCPs) of clients’ transactions. ABN AMRO is not liable to clients for the non-performance of the CCP.

In the event of a client defaulting, ABN AMRO has the legal obligation to settle all the client’s positions with

the relevant CCPs, possibly at a loss. Possible losses arising from this guarantee might relate not only to a client’s

current positions, but also to the client's future trades. ABN AMRO receives and collects (cash) margins from clients,

and remits these margins to the relevant CCP in whole or in part. Given the stringent margin requirements set by

the CCPs, possible future outflows of resources for new clearing transactions are considered close to zero.


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ABN AMRO does not reflect the exchange-traded derivatives cleared on behalf of clients in its financial statements.

Under normal circumstances, the guarantee has no fair value and is not recognised in the financial statements. Any

loss recognised in the event of non-performance of a client is in line with our contingent liabilities policy.

Offsetting financial assets and liabilities

Financial assets and liabilities are offset, and the net amount is reported on the statement of financial position, if there

is a legally enforceable right to offset the recognised amounts and there is an intention either to settle on a net basis or

to realise the asset and settle the liability simultaneously. The bank applies netting to debtor and creditor balances

such as current accounts where offsetting is justified by formal agreement with the client, provided the balances meet

the applicable criteria.

Enforceable master netting arrangements are agreements in which the bank has a legally enforceable right to offset in

the event of default, but no ability and/or intention to realise the asset and settle the liability simultaneously in the

normal course of business. As a result, the criteria to offset are not met. These arrangements include derivative

clearing agreements, global master repurchase agreements and global master securities lending agreements.

Statement of cash flows

For the purposes of the statement of cash flows, cash and cash equivalents comprise cash in hand, freely available

balances with central banks and other banks, and net balances on current accounts with other banks with a maturity

of less than three months from the date of acquisition. The statement of cash flows, based on the indirect method

of calculating operating cash flows, gives details of the source of cash and cash equivalents which became available

during the year and the application of these cash and cash equivalents over the course of the year. The cash flows are

categorised into cash flows from operations, including banking activities, investment activities and financing activities.

Movements in loans and advances and interbank deposits are included in the cash flow from operating activities.

Investment activities are comprised of acquisitions, sales and redemptions in respect of financial investments, as well

as investments in, and sales of, subsidiaries and associates, property and equipment. The issuing of shares and

the borrowing and repayment of long-term funds are treated as financing activities. Cash flows arising from foreign

currency transactions are translated into euros using the exchange rates at the date of the cash flows.

Government grants

Government grants are recognised in the income statement on a systematic basis over the periods that the related

expenses, which the grants are intended to compensate, are recognised. In the case of an income-related grant,

the grant is deducted from the related expense.

Levies and other regulatory charges

ABN AMRO recognises a liability arising from levies and similar charges when it becomes legally enforceable (i.e. when

the obligating event arises).

2 Segment reporting



	Accounting policy for segment reporting ABN AMRO’s segment reporting is in accordance with IFRS 8 Operating Segments and consistent with the internal reporting provided to its Executive Board, which is responsible for allocating resources and assessing performance and has been identified as the chief operating decision-maker. All transactions between segments are eliminated as intersegment revenues and expenses in Group Functions. Geographical data are presented according to the management view.

	Segment assets, liabilities, income and results are measured based on our accounting policies and include items directly attributable to a segment, as well as those that can be allocated on a reasonable basis. Transactions between segments are conducted on an arm’s length basis. Interest income is reported as net interest income (NII) because management relies primarily on net, rather than gross, interest income and expenses as a performance measure.


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Personal & Business Banking

This client unit serves consumer and business clients with banking and partner offerings, providing the convenience

of digital interactions and access to expertise when it matters most.

Wealth Management

The Wealth Management client unit delivers outstanding expertise with tailored value propositions for wealthy clients,

focusing on investment advisory, financial planning and real estate financing.

Corporate Banking

This expertise-driven client unit delivers tailored financing, capital structuring and transaction banking solutions for

medium sized and large corporate clients and financial institutions. Corporate Banking also offers Entrepreneur &

Enterprise as a bank-wide service concept for business and wealthy clients, in close collaboration with Wealth

Management.

Group Functions

Group Functions consists of the following support function departments: Finance, Risk Management, Innovation &

Technology, Group Economics, Human Resources, Group Audit, Legal & Corporate Office, Brand Marketing &

Communications, Strategy & Transformation and a Sustainability Centre of Excellence. Group Functions is not a client

unit, but part of the reconciliation. The majority of Group Functions’ costs are allocated to the client units.

Segment income statement for the year 2025


					2025
(in millions)	Personal & Business Banking	Wealth Management	Corporate Banking	Group Functions	Total
Income
Net interest income	3,231	900	2,117	88	6,335
Net fee and commission income	655	771	730	-23	2,132
Net income from other operating activities	-20	27	89	-66	30
Net trading income	-1		220		219
Share of result in equity-accounted investments	9	-2	19	2	28
Net gains/(losses) on derecognition of financial assets measured at amortised cost	-2	-3	-14	-10	-29
Operating income	3,873	1,693	3,160	-9	8,716
Expenses
Personnel expenses	510	555	690	1,350	3,104
General and administrative expenses	430	237	327	1,332	2,326
Depreciation, amortisation and impairment losses of tangible and intangible assets	5	49	22	104	180
Intersegment revenues/expenses	1,459	460	738	-2,657
Operating expenses	2,404	1,302	1,776	128	5,610
Impairment charges on financial instruments	-81	10	92	-1	20
Total expenses	2,323	1,312	1,868	127	5,630
Profit/(loss) before taxation	1,549	381	1,292	-136	3,086
Income tax expense	410	113	304	6	834
Profit/(loss)	1,139	267	989	-143	2,252
Attributable to:
Owners of the parent company	1,139	267	989	-143	2,252


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Segment income statement for the year 2024


					2024
(in millions)	Personal & Business Banking	Wealth Management	Corporate Banking	Group Functions	Total
Income
Net interest income	3,262	932	2,281	29	6,504
Net fee and commission income	603	632	699	-24	1,910
Net income from other operating activities	59	-9	141	34	226
Net trading income	-2		285		283
Share of result in equity-accounted investments	18	13	-19	-3	9
Net gains/(losses) on derecognition of financial assets measured at amortised cost	-8		-30	-33	-71
Operating income	3,932	1,568	3,358	4	8,861
Expenses
Personnel expenses	500	438	645	1,192	2,776
General and administrative expenses	462	208	396	1,464	2,531
Depreciation, amortisation and impairment losses of tangible and intangible assets	4	27	22	108	160
Intersegment revenues/expenses	1,485	419	738	-2,642
Operating expenses	2,451	1,092	1,802	122	5,467
Impairment charges on financial instruments	-108	14	74	-2	-21
Total expenses	2,343	1,106	1,877	121	5,446
Profit/(loss) before taxation	1,589	462	1,481	-117	3,415
Income tax expense	419	137	382	74	1,013
Profit/(loss)	1,169	325	1,099	-191	2,403
Attributable to:
Owners of the parent company	1,169	325	1,099	-191	2,403

For the explanation and further details of large incidentals used in the section below, please refer to the Financial

performance section in the Strategy & performance chapter.

Total bank

Net interest income decreased by EUR 169 million to EUR 6,335 million in 2025, (2024: EUR 6,504 million). Excluding

large incidentals, NII decreased by EUR 166 million, with declines observed across all client units. The decrease was

largely attributable to margin pressure on deposits due to changes in the interest rate environment, as well as,

continued margin pressure on corporate loans and declining margins on mortgages. Margin pressure was only

partially offset by strong volume growth in deposits and mortgages. A limited offset also came from improved

Treasury results and the positive impact of the integration of Hauck Aufhäuser Lampe (HAL).

Net fee and commission income increased by EUR 222 million to EUR 2,132 million in 2025. This increase was mainly

attributable to higher fee income at Wealth Management, reflecting the integration of HAL and higher asset

management and securities services fees. In addition, Personal & Business Banking benefited from higher payment

services fees due to increased pricing of payment packages and higher transaction volumes. Clearing also recorded

higher fee income, reflecting increased transaction volumes driven by elevated market volatility.

Net income from other operating activities amounted to EUR 30 million in 2025, compared with EUR 226 million

in 2024, reflecting a decrease of EUR 196 million. This decrease was mainly attributable to less favourable Treasury

and Personal & Business Banking results (fair value revaluations on loans). Next to that, a decrease in

Corporate Banking was mainly driven by lower revaluations of equities and the wind-down of the ABF portfolio, partly

offset by higher Clearing results. This was partly offset by improved Wealth Management results, mostly reflecting the

integration of HAL and the large incidental in 2024.

Net trading income decreased by EUR 64 million to EUR 219 million in 2025, compared with EUR 283 million

in 2024, reflecting lower Clearing and Global Markets results at Corporate Banking.


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Share of result in equity-accounted investments improved by EUR 19 million to EUR 28 million in 2025. The increase

was mainly driven by more favourable revaluations at Corporate Banking, partly offset by lower results at Wealth

Management, primarily due to the sale of the joint venture Neuflize Vie in 2024.

Net gains/(losses) on derecognition of financial assets increased by EUR 42 million, resulting in a net loss of

EUR 29 million in 2025, compared with a net loss of EUR 71 million in 2024. This increase was mainly driven by lower

derecognition losses at Corporate Banking and Group Functions.

Personnel expenses increased by EUR 328 million to EUR 3,104 million in 2025. This increase was attributable to a

higher number of internal employees, largely reflecting the integration of HAL, as well as the impact of the Dutch CLA

and higher restructuring provisions (including large incidentals).

General and administrative expenses decreased by EUR 205 million to EUR 2,326 million in 2025, compared with

EUR 2,531 million in 2024. Excluding large incidentals, general and administrative expenses decreased by

EUR 193 million. The decrease was mainly driven by lower external staffing costs and non-recurring VAT rebates in

2025, partly offset by higher IT-related expenses, mainly related to the integration of HAL.

Depreciation and amortisation increased by EUR 20 million to EUR 180 million in 2025, compared with

EUR 160 million in 2024, largely reflecting the integration of HAL.

Impairment charges amounted to EUR 20 million for 2025 (2024: release of EUR 21 million) and were primarily

related to individual-based net additions for corporate loans at Corporate Banking, partially offset by net releases at

Personal & Business Banking. The resulting cost of risk was 1bp positive compared with 2bps negative in 2024.

Personal & Business Banking

Net interest income decreased by EUR 31 million to EUR 3,231 million in 2025, compared with EUR 3,262 million

in 2024. Excluding large incidentals, net interest income decreased by EUR 47 million mainly due to lower margins on

deposits and mortgages, partly offset by volume growth in deposits and mortgages.

Net fee and commission income increased by EUR 52 million to EUR 655 million in 2025, largely driven by higher

payment services fees resulting from increased payment package pricing and higher transaction volumes.

Net income from other operating activities amounted to a loss of EUR 20 million in 2025, compared with a gain of

EUR 59 million in 2024, reflecting a decrease of EUR 79 million. The decrease was mainly driven by negative fair value

revaluations on loans versus positive revaluations in the previous year.

Personnel expenses increased by EUR 10 million to EUR 510 million in 2025, mainly driven by the impact of the

Dutch CLA, partly offset by lower restructuring provisions and a slightly lower number of internal employees,

reflecting our limited hiring of staff.

General and administrative expenses decreased by EUR 32 million to EUR 430 million in 2025, mainly due to lower

external staffing costs, reflecting our cost discipline.

Impairment charges recorded a release of EUR 81 million for 2025 (2024: release of EUR 108 million), driven by

releases in all 3 stages.

Wealth Management

Net interest income decreased by EUR 32 million to EUR 900 million in 2025, compared with EUR 932 million

in 2024. The decrease was mainly driven by lower deposit margins, partly offset by higher volumes and the positive

impact of the integration of HAL.

Net fee and commission income increased by EUR 139 million to EUR 771 million in 2025, driven mainly by the

integration of HAL and higher other fee income, particularly from asset management and securities services.


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Net income from other operating activities increased by EUR 36 million to EUR 27 million in 2025 (2024: loss of

EUR 9 million), mainly reflecting the integration of HAL and the large incidental in 2024.

Share of result in equity-accounted investments decreased by EUR 15 million to a loss of EUR 2 million in 2025

(2024: EUR 13 million), largely due to the absence of results from the joint venture Neuflize Vie following its sale in

2024.

Personnel expenses increased by EUR 117 million to EUR 555 million in 2025, compared with EUR 438 million

in 2024. The increase was attributable to an increase in the number of internal employees, reflecting the integration of

HAL, as well as the impact of the Dutch CLA and higher restructuring provisions.

General and administrative expenses increased by EUR 29 million to EUR 237 million in 2025, largely driven by the

integration of HAL, partly offset by lower external staffing costs, reflecting our cost discipline.

Depreciation and amortisation increased by EUR 22 million to EUR 49 million in 2025, compared with EUR 27 million

in 2024, mainly reflecting the integration of HAL and higher impairments of intangible assets.

Impairment charges recorded an addition of EUR 10 million for 2025 (2024: addition of EUR 14 million), reflecting

stage 1 and stage 3 charges, partly offset by stage 2 releases.

Corporate Banking

Net interest income decreased by EUR 164 million to EUR 2,117 million in 2025, compared with EUR 2,281 million

in 2024. The decrease was mainly driven by lower margins on liabilities, lower corporate loan volumes and lower

Clearing NII.

Net fee and commission income increased by EUR 31 million to EUR 730 million in 2025, mainly due to higher results

at Clearing, which benefitted from increased market volatility, partly offset by the wind-down of the ABF portfolio.

Net income from other operating activities amounted to EUR 89 million in 2025, compared with EUR 141 million

in 2024, reflecting a decrease of EUR 52 million. The decrease was mainly related to lower revaluations of equities and

the wind-down of the ABF portfolio, partly offset by higher Clearing results.

Net trading income decreased by EUR 65 million to EUR 220 million in 2025, due to lower Clearing and Global

Markets results.

Share of result in equity-accounted investments amounted to EUR 19 million in 2025 (2024: loss of EUR 19 million),

due to more favourable revaluations.

Net gains/(losses) on derecognition of financial assets totalled a loss of EUR 14 million in 2025 (2024: loss of

EUR 30 million). The 2025 results mainly reflect derecognition losses due to the risk transfer of an infrastructure

portfolio.

Personnel expenses increased by EUR 45 million to EUR 690 million in 2025. Excluding large incidentals, personnel

expenses increased by EUR 67 million. This increase was mainly driven by the impact of the Dutch CLA, higher

restructuring provisions and the integration of HAL, partly offset by a slight decrease in the number of internal

employees, reflecting our limited hiring of staff.

General and administrative expenses decreased by EUR 69 million, amounting to EUR 327 million in 2025. Excluding

large incidentals, the decrease was EUR 76 million, mainly due to lower external staffing costs, reflecting our cost

discipline and non-recurring VAT rebates in 2025.

Impairment charges recorded an addition of EUR 92 million for 2025 (2024: addition of EUR 74 million), reflecting

stage 3 charges, partly offset by stage 1 and 2 releases.


ABN AMRO	Annual Report 2025	313


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Group Functions

Net interest income increased by EUR 59 million to EUR 88 million in 2025, compared with EUR 29 million in 2024.

Excluding large incidentals, net interest income increased by EUR 78 million, mainly reflecting improved Treasury

results.

Net income from other operating activities amounted to a loss of EUR 66 million in 2025, compared with a gain of

EUR 34 million in 2024, reflecting a decrease of EUR 100 million. The decrease was mainly driven by less favourable

asset and liability management results at Treasury.

Net gains/(losses) on derecognition of financial assets improved by EUR 23 million, totalling a loss of EUR 10 million

in 2025 (2024: loss of EUR 33 million). The increase mainly reflects lower derecognition losses related to smaller

portfolio sales.

Personnel expenses increased by EUR 158 million to EUR 1,350 million in 2025, mainly due to a higher number of

internal employees, the impact of the Dutch CLA and higher restructuring provisions. The additional employees mainly

reflect internalisation activities, which reduced external staffing costs.

General and administrative expenses decreased by EUR 132 million to EUR 1,332 million in 2025. Excluding large

incidentals, general and administrative expenses decreased by EUR 114 million, mainly reflecting lower external

staffing costs.

Selected assets and liabilities per segment


					31 December 2025
(in millions)	Personal & Business Banking	Wealth Management	Corporate Banking	Group Functions	Total
Assets
Financial assets held for trading			2,044		2,044
Derivatives		166	3,475	293	3,933
Securities financing		1,296	7,787	31,090	40,173
Loans and advances customers	169,987	19,299	71,684	-5,208	255,760
Other	4,906	10,718	6,326	89,348	111,298
Total assets	174,893	31,478	91,316	115,523	413,210
Liabilities
Financial liabilities held for trading			1,631		1,631
Derivatives	6	86	1,466	409	1,967
Securities financing				15,319	15,320
Due to customers	135,764	85,846	51,573	5,944	279,126
Other	39,122	-54,454	36,646	66,808	88,123
Total liabilities	174,893	31,478	91,316	88,480	386,167


					31 December 2024
(in millions)	Personal & Business Banking	Wealth Management	Corporate Banking	Group Functions	Total
Assets
Financial assets held for trading			2,503		2,503
Derivatives		1	3,892	454	4,347
Securities financing			8,773	18,216	26,989
Loans and advances customers	161,189	16,215	75,620	-4,242	248,782
Other	2,397	1,610	8,374	90,045	102,426
Total assets	163,586	17,826	99,162	104,473	385,047
Liabilities
Financial liabilities held for trading			1,163		1,163
Derivatives	7	2	2,118	371	2,499
Securities financing			18	10,334	10,352
Due to customers	126,626	66,652	55,801	7,108	256,186
Other	36,953	-48,828	40,062	60,552	88,739
Total liabilities	163,586	17,826	99,162	78,365	358,939


ABN AMRO	Annual Report 2025	314


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Geographical segments


					2025
(in millions)	The Netherlands	Rest of Europe	USA	Asia	Rest of the world	Total
Income
Net interest income	5,754	387	102	57	35	6,335
Net fee and commission income	1,403	447	145	131	7	2,132
Net income from other operating activities	37	-12	9	1	-5	30
Net trading income	225	3			-9	219
Share of result in equity-accounted investments	31	-4				28
Net gains/ (losses) on derecognition of financial assets measured at amortised cost	-36	6			1	-29
Operating income	7,416	827	256	188	30	8,716
Expenses
Personnel expenses	2,514	494	55	23	17	3,104
General and administrative expenses	2,062	212	26	15	11	2,326
Depreciation and amortisation of tangible and intangible assets	124	48	3	3	1	180
Intersegment revenues/expenses	9	2	4	2	-17
Operating expenses	4,710	756	88	43	12	5,610
Impairment charges on financial instruments	-14	34				20
Total expenses	4,696	790	88	43	12	5,630
Profit/(loss) before taxation	2,720	37	167	145	17	3,086
Income tax expense	758	20	28	22	6	834
Profit/(loss)	1,962	17	140	123	11	2,252
Attributable to:
Owners of the parent company	1,961	17	140	123	11	2,252


						2024
(in millions)	The Netherlands	Rest of Europe	USA	Asia	Rest of the world	Total
Income
Net interest income	5,936	359	124	62	23	6,504
Net fee and commission income	1,326	338	136	103	7	1,910
Net income from other operating activities	231	18	7	2	-32	226
Net trading income	255				29	283
Share of result in equity-accounted investments	-4	13				9
Net gains/ (losses) on derecognition of financial assets measured at amortised cost	-73	1			1	-71
Operating income	7,671	728	267	167	28	8,861
Expenses
Personnel expenses	2,283	399	57	21	15	2,776
General and administrative expenses	2,311	170	27	14	9	2,531
Depreciation and amortisation of tangible and intangible assets	125	28	3	3	1	160
Intersegment revenues/expenses	12	3	2	-5	-13
Operating expenses	4,731	600	90	33	13	5,467
Impairment charges on financial instruments	-47	26				-21
Total expenses	4,685	626	90	33	13	5,446
Profit/(loss) before taxation	2,986	102	178	134	15	3,415
Income tax expense	862	59	70	17	5	1,013
Profit/(loss)	2,124	43	108	118	10	2,403
Attributable to:
Owners of the parent company	2,124	43	108	118	10	2,403


ABN AMRO	Annual Report 2025	315


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

3 Overview of financial assets and liabilities by measurement base


				31 December 2025
(in millions)	Amortised cost	Fair value through profit or loss - trading	Fair value through profit or loss - other	Fair value through other comprehensive income	Total
Financial assets
Cash and balances at central banks	49,486				49,486
Financial assets held for trading		2,044			2,044
Derivatives		3,474	460		3,933
Financial investments			1,310	48,921	50,231
Securities financing	40,173				40,173
Loans and advances banks	2,170				2,170
Loans and advances customers	255,247		514		255,760
Assets held for sale	2,384		82		2,466
Other financial assets	3,829				3,829
Total financial assets	353,289	5,518	2,365	48,921	410,093
Financial liabilities
Financial liabilities held for trading		1,631			1,631
Derivatives		1,472	495		1,967
Securities financing	15,320				15,320
Due to banks	4,320				4,320
Due to customers	279,126				279,126
Issued debt	73,913		159		74,072
Subordinated liabilities	4,946				4,946
Liabilities held for sale	1				1
Other financial liabilities	1,935				1,935
Total financial liabilities	379,561	3,103	654		383,318


				31 December 2024
(in millions)	Amortised cost	Fair value through profit or loss - trading	Fair value through profit or loss - other	Fair value through other comprehensive income	Total
Financial assets
Cash and balances at central banks	44,464				44,464
Financial assets held for trading		2,503			2,503
Derivatives		3,891	455		4,347
Financial investments			977	46,196	47,173
Securities financing	26,989				26,989
Loans and advances banks	2,049				2,049
Loans and advances customers	248,152		630		248,782
Assets held for sale	1,329				1,329
Other financial assets	4,557				4,557
Total financial assets	327,540	6,394	2,063	46,196	382,193
Financial liabilities
Financial liabilities held for trading		1,163			1,163
Derivatives		2,125	374		2,499
Securities financing	10,352				10,352
Due to banks	2,329				2,329
Due to customers	256,186				256,186
Issued debt	74,337		205		74,542
Subordinated liabilities	6,613				6,613
Other financial liabilities	1,758				1,758
Total financial liabilities	351,576	3,288	579		355,443


ABN AMRO	Annual Report 2025	316


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

4 Net interest income



	Accounting policy for net interest income Interest income and expenses on financial instruments are recognised in the income statement on an accrual basis using the effective interest rate method, except where financial instruments are measured at fair value through profit or loss. The effective interest rate method allocates interest, amortisation of any discount or premium or other differences, including transaction costs and qualifying fees and commissions, over the expected lives of the assets and liabilities. The effective interest rate is the rate that exactly discounts estimated future cash flows to the net carrying amount of the asset. As a result, this method requires ABN AMRO to estimate future cash flows, in some cases based on its experience with client behaviour, considering all contractual terms of the financial instrument, as well as the expected lives of the assets and liabilities. Interest on loans and advances measured at fair value through profit or loss is also included in net interest income and recognised using the contractual interest rate. Interest income and expenses on trading balances are included in net trading income. Interest paid on assets with a negative interest yield is classified as interest expense. Interest received from liabilities with a negative interest yield is classified as interest income.


(in millions)		2025		2024
Interest income calculated using the effective interest method	14,205		16,757
Other interest and similar income	253		351
Interest income		14,457		17,108
Interest expense calculated using the effective interest method	8,019		10,532
Other interest and similar expense	103		72
Interest expense		8,122		10,604
Net interest income		6,335		6,504

Interest income


(in millions)	2025	2024
Interest income from:
Financial investments at fair value through other comprehensive income	1,136	1,028
Securities financing	1,455	1,495
Loans and advances banks	1,268	1,917
Loans and advances customers	8,840	9,528
Non-trading derivatives - hedge accounting - Cash flow hedges	274	208
Non-trading derivatives - hedge accounting - Fair value hedges	1,073	2,369
Other	159	213
Interest income calculated using the effective interest method	14,205	16,757
Financial assets at fair value through profit or loss	32	34
Non-trading derivatives - no hedge accounting	95	55
Other	126	262
Other interest and similar income	253	351
Total interest income	14,457	17,108


ABN AMRO	Annual Report 2025	317


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Interest expense


(in millions)	2025	2024
Interest expenses from:
Securities financing	696	896
Due to banks	244	333
Due to customers	4,199	5,260
Issued debt	2,242	2,139
Subordinated liabilities	281	297
Non-trading derivatives - hedge accounting - Cash flow hedges	288	654
Non-trading derivatives - hedge accounting - Fair value hedges	517	1,283
Other	-449	-330
Interest expense calculated using the effective interest method	8,019	10,532
Financial liabilities at fair value through profit or loss	10	9
Non-trading derivatives - no hedge accounting	72	43
Other	21	20
Other interest and similar expense	103	72
Total interest expense	8,122	10,604

5 Net fee and commission income



	Accounting policy for net fee and commission income ABN AMRO applies IFRS 15 when recognising revenue from contracts with clients, all of which is included in net fee and commission income. After identifying contracts and their performance obligations, revenue is recognised as an amount that reflects the consideration to which the bank expects to be entitled in exchange for transferring promised services to clients. The transaction price is allocated to each performance obligation. Revenue is measured at the fair value of the consideration received, taking into account discounts and rebates. The amount of revenue recognised is discounted to the present value of the consideration due, if payment extends beyond normal credit terms. Revenue is recognised when a promised service is transferred to the client. Fees and commission income are recognised either: • at a certain point in time: the fee is a reward for a service provided at a moment in time, or • over time (amortised): the fee relates to services on an ongoing basis.

ABN AMRO engages in transactions where more than one party is involved in providing services to a client. In the case

of these transactions, ABN AMRO assesses whether it is a principal or an agent in the transaction by evaluating the

nature of its promise to the client.

The bank is a principal if it controls the promised goods or services before they are transferred to a client. The bank

acts as an agent of another party if its service entails transferring goods or services to a client on behalf of that other

party and, as a result, the bank does not control the specified goods or services. Control of goods and services refers to

the ability to direct the use of, and obtain substantially all the remaining benefits from, the goods and services.

If the bank is assessed to be a principal in the transaction, it recognises as revenue the gross amount of the

consideration to which it expects to be entitled in exchange for the specified goods or services transferred. If, however,

the bank acts as an agent, it recognises as revenue the amount of the fee or commission to which it expects to be

entitled in exchange for transferring the specified goods or services provided by the other party. The fee or

commission may be the net amount of consideration that the bank retains after paying the other party the

consideration received in exchange for the goods or services provided by that party.


(in millions)	2025	2024
Fee and commission income	2,635	2,414
Fee and commission expense	502	504
Net fee and commission income	2,132	1,910


ABN AMRO	Annual Report 2025	318


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Fee and commission income


					2025
(in millions)	Personal & Business Banking	Wealth Management	Corporate Banking	Group Functions	Total
Fee and commission income from:
Securities and custodian services	17	125	617	2	761
Payment services	677	59	132	1	868
Portfolio management and trust fees	54	595	6		654
Guarantees and commitment fees	44	8	57	1	110
Insurance and investment fees	42	50			92
Other service fees	32	26	90	1	150
Total fee and commission income	865	863	902	5	2,635
Timing fee and commission income
Recognised at a point in time	393	446	864	4	1,707
Recognised over time	472	417	38	1	927
Total fee and commission income	865	863	902	5	2,635


					2024
(in millions)	Personal & Business Banking	Wealth Management	Corporate Banking	Group Functions	Total
Fee and commission income from:
Securities and custodian services	15	54	577	3	649
Payment services	642	39	147		827
Portfolio management and trust fees	48	556	4		608
Guarantees and commitment fees	36	7	56	1	101
Insurance and investment fees	39	45			84
Other service fees	33	18	93		145
Total fee and commission income	813	719	877	5	2,414
Timing fee and commission income
Recognised at a point in time	372	371	843	4	1,590
Recognised over time	440	348	35	1	823
Total fee and commission income	813	719	877	5	2,414

Fee and commission expense


(in millions)	2025	2024
Fee and commission expenses from:
Securities and custodian services	170	159
Payment services	201	218
Portfolio management and trust fees	56	63
Guarantees and commitment fees	41	29
Insurance and investment fees	20	21
Other service fees	15	14
Total fee and commission expense	502	504


ABN AMRO	Annual Report 2025	319


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

6 Net income from other operating activities



	Accounting policy for other operating income Other operating income includes all other banking activities such as operating lease activities as lessor and results on the disposal of assets. It also includes the change in fair value of derivatives used for risk management purposes that do not meet the requirements for hedge accounting, ineffectiveness of hedging programmes, fair value changes relating to assets and liabilities measured at fair value through profit or loss, and changes in the value of derivatives related to such instruments. Dividend income from non-trading equity investments is recognised when entitlement is established. Income from operating lease activities is presented separately from the depreciation expense of the related assets.


(in millions)	2025	2024
Income from lease activities	87	101
Disposal of operating activities and equity-accounted investments	1	-22
Result from financial transactions	2	211
Other	10	20
Income from other operating activities	101	311


(in millions)	2025	2024
Expenses from lease activities	70	84
Expenses from other operating activities	70	84

7 Net trading income



	Accounting policy for net trading income In accordance with IFRS 9, trading positions are held at fair value, and net trading income includes gains and losses arising from changes in the fair value of such financial assets and liabilities. The latter comprises gains and losses from trading financial assets and liabilities, interest income and expenses related to trading financial assets and liabilities, and dividends received from trading instruments. Dividend income and dividends from trading instruments are recognised at the dividend announcement date. Net trading income also includes changes in fair value arising from changes in counterparty credit spreads (CVA) and changes in own credit spreads (DVA) where these affect the value of our trading assets and liabilities. The funding valuation adjustment (FVA) incorporates the incremental cost of funding into the valuation of uncollateralised and partly collateralised derivatives.


(in millions)	2025	2024
Interest instruments trading	118	133
Equity and commodity trading	-12
Foreign exchange transaction results	113	151
Total net trading income	219	283


ABN AMRO	Annual Report 2025	320


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

8 Net gains/(losses) on derecognition of financial assets measured at amortised cost



	Accounting policy derecognition of financial assets The net gains/(losses) on derecognition of financial assets measured at amortised cost includes gains and losses recognised on the sale or derecognition of these financial assets, calculated as the difference between the carrying amount (which is the amortised cost adjusted for the loss allowance) and the proceeds received.

The net losses on derecognition of financial assets measured at amortised cost comprise EUR 17 million in gains and

EUR 45 million in losses, and relate to several smaller portfolio sales.

9 Personnel expenses



	Accounting policy for personnel expenses Salaries and wages, social security charges and other salary-related costs are recognised over the period in which the employees provide the services to which the payments relate. The accounting policies for pensions and other post-employment benefits are included in Note 31 - Pension and other employee benefits.


(in millions)	2025	2024
Salaries and wages	2,264	1,996
Social security charges	339	286
Expenses relating to Defined post employment benefit plans	6	7
Defined contribution plan expenses	328	366
Other	168	120
Total personnel expenses	3,104	2,776

10 General and administrative expenses



	Accounting policy for general and administrative expenses Costs are recognised in the period in which services have been provided and to which the payment relates.


(in millions)	2025	2024
Agency staff, contractors and consultancy costs	590	760
Staff-related costs	62	74
Information technology costs	1,047	1,023
Housing	111	97
Post, telephone and transport	23	28
Marketing and public relations costs	96	89
Regulatory charges	179	189
Other	218	270
Total general and administrative expenses	2,326	2,531

In 2025, the bank paid two fines, which are recorded in Other general and administrative expenses. One fine was

imposed by the Netherlands Public Prosecution Service (NPPS) for involvement in transactions connected, according

to the NPPS, to the filing of intentionally incorrect tax returns by a Dutch subsidiary of a foreign financial institution in

the period 2010-2013. For this imposed penalty order, ABN AMRO paid a fine of EUR 14 million. The other fine was

imposed by the Dutch Central Bank (DNB) for violations of the bonus prohibition in the period from 2016 to 2024.

ABN AMRO paid an administrative fine of EUR 15 million.


ABN AMRO	Annual Report 2025	321


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


(in millions)	2025	2024
Banking tax	123	118
Deposit Guarantee Scheme	7	34
Single Resolution Fund	15	2
Other regulatory levies	34	35
Total regulatory charges	179	189

Auditor's fees for EY’s services are included under agency staff, contractors and consultancy costs. The fees stated for

the audit of the financial statements are based on the total fees for the audit of the financial statements, regardless

of whether the audit activities were performed before the year-end. These are specified in the following table.


(in millions)	2025	2024
Financial statements audit fees	16	17
Audit-related fees	2	2
Total auditor's fee	18	19

Financial statement audit fees relating to the audit of activities in the Netherlands amounted to EUR 14 million in 2025

(2024: EUR 15 million). Audit-related fees for activities in the Netherlands amounted to EUR 1 million in 2025

(2024: EUR 1 million).

Audit-related fees comprise services relating to regulatory reporting, comfort letters and consent letters, assurance

engagements on segregation of assets, assurance on service organisation reports and procedures agreed for

supervisory purposes.

11 Income tax expense, tax assets and tax liabilities



	Accounting policy for income tax expense, tax assets and tax liabilities
	Income tax expense consists of current and deferred tax. Income tax is recognised in the income statement and in the statement of other comprehensive income in the period in which profits arise. Withholding taxes are included in income tax when these taxes become payable by a subsidiary, associate or joint arrangement on distributions to ABN AMRO. Income tax recoverable on tax-allowable losses is recognised as a current tax asset only to the extent that it is regarded as recoverable by offsetting against taxable profits arising in the current or prior period. Current tax is measured using tax rates prevailing at the balance sheet date.

	Deferred tax is recognised for qualifying temporary differences. Temporary differences represent the difference between the carrying amounts of assets and liabilities for financial reporting purposes and the amounts used for taxation purposes. The amount of deferred tax provided is based on the expected manner of realisation or settlement of the carrying amount of assets and liabilities, using tax rates prevailing at the balance sheet date.

	A deferred tax asset is recognised only to the extent that it is probable that future taxable profits will allow the deferred tax asset to be recovered. Deferred tax assets and liabilities are offset only when there is both a legal right to offset and an intention to settle on a net basis.


ABN AMRO	Annual Report 2025	322


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


(in millions)	2025	2024
Recognised in income statement:
Current tax expenses for the current period	819	947
Pillar Two tax expense	3	5
Adjustments recognised in the period for current tax of prior periods	-3	9
Total current tax expense	819	961
Deferred tax arising from the current period	28	43
Impact of changes in tax rates on deferred taxes	1
Deferred tax arising from the write-down or reversal of a write-down of a deferred tax asset	-4	21
Deferred tax prior period	1	-6
Previously unrecognised tax losses, tax credits and temporary differences reducing deferred tax expense	-11	-6
Total deferred tax expense	15	52
Total income tax expense	834	1,013

Reconciliation of the total tax charge

The effective tax rate based on the consolidated income statement differs from the theoretical rate that would arise

using the statutory tax rate of the Netherlands. This difference is explained in the following table.


(in millions)	2025	Effective tax rate	2024	Effective tax rate
Profit/(loss) before taxation	3,086		3,415
Applicable tax rate	25.8%		25.8%
Expected income tax expense	796		881
International tax rate difference	-13	-0.4%	-10	-0.3%
Adjustment previous years	-2	-0.1%	3	0.1%
Change in tax rates	1	0.0%		-0.0%
Banking tax	32	1.0%	31	0.9%
Non-taxable income	-7	-0.2%	-9	-0.3%
Non-deductible expenses	47	1.5%	96	2.8%
Tax exempted result (participation exemption)	-17	-0.6%	-13	-0.4%
Losses not benefited	-11	-0.4%	-6	-0.2%
Change recognition of deferred tax assets	-4	-0.1%	21	0.6%
Pillar Two tax expense	3	0.1%	5	0.1%
Other tax effects	10	0.3%	13	0.4%
Actual income tax expense	834	27.0%	1,013	29.6%

The income tax expense decreased by EUR 179 million to EUR 834 million in 2025. The effective tax rate was 27.0%

in 2025, compared with the standard Dutch rate of 25.8%. This is caused mainly by the annual banking tax which is

not deductible and non-deductible interest due to the Dutch “thin capitalisation” rules for banks.

Tax assets and liabilities

The most significant temporary differences arose from the revaluation of certain financial assets and liabilities,

including derivative contracts, allowances for loan impairment and investments. The following table summarises the

tax position.


	31 December 2025		31 December 2024
(in millions)	Assets	Liabilities	Assets	Liabilities
Current tax	29	118	51	395
Deferred tax	114	65	275
Total tax assets and liabilities	143	183	326	395


ABN AMRO	Annual Report 2025	323


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

The significant components and annual movements in deferred tax assets and deferred tax liabilities are shown in the

following tables.


(in millions)	As at 31 December 2024	Income statement	OCI	Equity	Other	As at 31 December 2025	- of which deferred tax asset	- of which deferred tax liability
Assets and liabilities held for trading, derivatives and financial investments	159		-234		-1	-76	289	365
Property and equipment (excluding leases) and intangible assets	-1	-37			-10	-48	19	67
Loans	10	-1			9	17	19	2
Leases	28	1			-4	26	100	75
Pensions and other (post-)employment benefits	9				1	9	9
Provisions	29	-7			-1	20	20
Tax losses carried forward	50	11			26	87	87
Other	-8	18			3	13	52	39
Deferred tax assets (+) and liabilities (-)	275	-15	-235		24	49	596	547
Offsetting deferred tax assets and liabilities							482	482
Net deferred tax assets (+) and liabilities (-)							114	65


(in millions)	As at 31 December 2023	Income statement	OCI	Equity	Other	As at 31 December 2024	- of which deferred tax asset	- of which deferred tax liability
Assets and liabilities held for trading, derivatives and financial investments	115	-6	51			159	175	16
Property and equipment (excluding leases) and intangible assets	25	-20			-5	-1	20	21
Loans	12	-1				10	11	1
Leases	32	-4				28	93	65
Pensions and other (post-)employment benefits	8		1			9	9
Provisions	23	4	1		1	29	29
Tax losses carried forward	88	-42			3	50	50
Other	-25	19			-1	-8	57	65
Deferred tax assets (+) and liabilities (-)	278	-52	51		-2	275	442	167
Offsetting deferred tax assets and liabilities							167	167
Net deferred tax assets (+) and liabilities (-)							275

Deferred tax assets and liabilities

Deferred tax assets are recognised to the extent that it is probable that future taxable profits will allow the deferred

tax asset to be recovered. Recognition is based on estimates of taxable income by jurisdiction in which ABN AMRO

operates and the period over which the deferred tax assets will be recoverable. In the event that actual results differ

from these estimates in future periods, changes to the recognition of deferred tax assets could be required and these

could impact our financial position and net profit.

Undistributed earnings of ABN AMRO’s subsidiaries, branches and interests in joint ventures may give rise to taxable

temporary differences and therefore to deferred tax liabilities. No deferred tax liabilities have been recognised in

respect of such undistributed earnings.

Unrecognised tax assets

Certain amounts of deferred tax assets are not recognised because future taxable profits are not considered probable.

Deferred tax assets for an amount of EUR 23 million (31 December 2024: EUR 29 million) have not been recognised in

respect of deductible temporary differences of EUR 91 million (31 December 2024: EUR 112 million). In addition,

deferred tax assets for an amount of EUR 51 million (31 December 2024: EUR 46 million) have not been recognised in

respect of tax losses of EUR 254 million (31 December 2024: EUR 233 million).

Tax credits and unrecognised tax credits

ABN AMRO did not have any carry-forward tax credits on 31 December 2025.


ABN AMRO	Annual Report 2025	324


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Loss carry-forward by year of expiration


(in millions)	2025	2026	2027	2028	2029	2030	After 5 years	No expiration	Total
2025
Loss carry-forward recognised								521	521
Loss carry-forward not recognised							1	254	254
Total tax losses carry-forward (gross)							1	775	775
2024
Loss carry-forward recognised								418	418
Loss carry-forward not recognised								233	233
Total tax losses carry-forward (gross)								651	651

Of the total amount of recognised net deferred tax assets, EUR 18 million (31 December 2024: EUR 6 million) was

related to entities that suffered a loss in either the current or preceding year. The recognition of these deferred tax

assets is based on a projection of future taxable income.

Tax related to equity

Tax related to components of other comprehensive income and tax related to equity and movements in equity can be

found in the Consolidated statement of comprehensive income and the Consolidated statement of changes in equity.

Income tax consequences of dividend

Dividends are, in principle, subject to a 15% withholding tax in the Netherlands. In 2025, ABN AMRO withheld

EUR 120 million of dividend withholding tax on dividends paid to its shareholders.


ABN AMRO	Annual Report 2025	325


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Country-by-country reporting


							31 December 2025
Country of activity	Principal subsidiary	Main activities	Non-banking activities	Total assets (in millions)	Total operating income (in millions)	Average number of FTEs	Operating profit/ (loss) before taxation (in millions)	Income tax expense (in millions)	Income tax paid (in millions)
The Netherlands¹	ABN AMRO Bank N.V.	Corporate Banking, Wealth Management, Equity Investment, Real Estate Investment	Research & Development, Insurance	367,990	7,415	19,212	2,716	758	1,018
France	ABN AMRO Bank N.V. Paris Branch	Wealth Management, Corporate Banking, Equity Investment, Real Estate Investment	Research & Development, Procurement	4,237	320	879	41	15	10
Germany	ABN AMRO Bank N.V. Frankfurt Branch	Wealth Management, Corporate Banking, Equity Investment, Real Estate Investment	Insurance	13,115	288	978	-29	-6	14
Belgium	ABN AMRO Bank N.V. Belgium Branch	Wealth Management, Corporate Banking		768	88	387	-21
United Kingdom	ABN AMRO Bank N.V. UK Branch	Corporate Banking, Equity Investment, Equity	Non-regulated Financial Services	108	29	298	6	6	4
Luxembourg	Hauck Aufhäuser Lampe Privatbank AG, Niederlassung Luxemburg	Wealth Management		424	67	352	13	3
Norway	ABN AMRO Bank N.V. Oslo Branch NUF	Corporate Banking		1,494	36	18	29	1	17
United States	ABN AMRO Clearing USA LLC	Corporate Banking, Treasury, Equity Investment	Insurance	21,278	256	248	167	28	-7
Brazil	Banco ABN AMRO Clearing S.A.	Corporate Banking		178	16	40	15	5	4
Singapore	ABN AMRO Clearing Bank N.V. Singapore Branch	Corporate Banking, Treasury		2,892	89	91	72	11	9
Hong Kong	ABN AMRO Clearing Hong Kong Limited	Corporate Banking, Equity Investment		523	80	39	68	10	5
Japan	ABN AMRO Clearing Tokyo Co. Ltd.	Corporate Banking		6	19	35	5	1	4
Australia	ABN AMRO Clearing Australia Pty Ltd.	Corporate Banking, Equity Investment		190	14	77	3	1	2
Spain	ABN AMRO Mahler Assets Spain SL	Real Estate Investment		3			-1
Romania	AAC IT Services Romania S.R.L.	IT Services		1		22
Total				413,210	8,716	22,676	3,086	834	1,079
1. Following new country-by-country regulation, ABN AMRO has presented all countries individually and any consolidation effects have been reclassified to the Netherlands. Comparative figures have been adjusted accordingly.


ABN AMRO	Annual Report 2025	326


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


							31 December 2024
Country of activity	Principal subsidiary	Main activities	Non-banking activities	Total assets (in millions)	Total operating income (in millions)	Average number of FTEs	Operating profit/ (loss) before taxation (in millions)	Income tax expense (in millions)	Income tax paid (in millions)
The Netherlands¹	ABN AMRO Bank N.V.	Corporate Banking, Wealth Management, Equity Investment, Real Estate Investment	Research & Development, Insurance	351,558	7,672	18,295	2,986	862	643
France	ABN AMRO Bank N.V. Paris Branch	Wealth Management, Corporate Banking, Equity Investment, Real Estate Investment	Research & Development, Procurement	4,054	317	878	51	20	24
Germany	ABN AMRO Bank N.V. Frankfurt Branch	Wealth Management, Corporate Banking, Equity Investment, Real Estate Investment	Insurance	2,337	198	775	3	6	3
Belgium	ABN AMRO Bank N.V. Belgium Branch	Wealth Management, Corporate Banking		724	89	378	-30
United Kingdom	ABN AMRO Bank N.V. UK Branch	Corporate Banking, Equity Investment, Equity	Non-regulated Financial Services	1,242	74	354	35	8	8
Norway	ABN AMRO Bank N.V. Oslo Branch NUF	Corporate Banking		1,897	47	18	42	25
United States	ABN AMRO Clearing USA LLC	Corporate Banking, Treasury, Equity Investment	Insurance	19,607	267	252	178	70	45
Brazil	Banco ABN AMRO Clearing S.A.	Corporate Banking		259	13	29	12	4	3
Singapore	ABN AMRO Clearing Bank N.V. Singapore Branch	Corporate Banking, Treasury		2,462	76	82	68	10	6
Hong Kong	ABN AMRO Clearing Hong Kong Limited	Corporate Banking, Equity Investment		461	70	36	58	4	1
Japan	ABN AMRO Clearing Tokyo Co. Ltd.	Corporate Banking		131	22	30	9	3	2
Australia	ABN AMRO Clearing Australia Pty Ltd.	Corporate Banking, Equity Investment		309	15	74	3	1	1
Spain	ABN AMRO Mahler Assets Spain SL	Real Estate Investment		4
Romania	AAC IT Services Romania S.R.L.	IT Services				1
Total				385,047	8,861	21,199	3,415	1,013	737
1. Following new country-by-country regulation, ABN AMRO has presented all countries individually and any consolidation effects have been reclassified to the Netherlands. Comparative figures have been adjusted accordingly.


ABN AMRO	Annual Report 2025	327


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

12 Earnings per share

The following table shows the composition of basic earnings per share as at 31 December.


	2025			2024
(in millions)	Profit/(loss) for the period¹	Average number of shares	Earnings per share (in EUR)	Profit/(loss) for the period¹	Average number of shares	Earnings per share (in EUR)
Basic earnings	2,035	830	2.45	2,283	841	2.72
1. Earnings consist of profit excluding results attributable to non-controlling interests and payments to holders of AT1 instruments.

Given that ABN AMRO Bank N.V. does not have any dilutive potential ordinary shares, only basic earnings per ordinary

share is disclosed. Basic earnings per ordinary share is calculated by dividing the profit attributable to the owners of

the parent company by the weighted average number of ordinary shares outstanding. During 2025, a final dividend of

EUR 0.75 per share for 2024, amounting to EUR 625 million, and an interim dividend of EUR 0.54 per share for 2025,

amounting to EUR 449 million, were distributed. For the year 2025, a final dividend of EUR 0.70 per share has been

proposed.

During the second half of 2025, ABN AMRO Bank N.V. conducted a EUR 250 million buyback programme.

The buyback programme resulted in the purchase of 9.8 million ordinary shares throughout the second half of

the year. As a result, the weighted average number of ordinary shares was 830 million.

13 Cash and balances at central banks



	Accounting policy for cash and balances at central banks Cash and balances at central banks are held at amortised cost. This item includes cash on hand and available demand deposits with central banks in countries in which the bank has a presence. Mandatory reserve deposits are disclosed in Note 20 - Loans and advances banks.


(in millions)	31 December 2025	31 December 2024
Cash on hand and other cash equivalents	479	414
Balances with central banks readily convertible in cash other than mandatory reserve deposits	49,007	44,050
Total cash and balances at central banks	49,486	44,464

14 Financial assets and liabilities held for trading



	Accounting policy for financial assets and liabilities held for trading In accordance with IFRS 9, all assets and liabilities held for trading are measured at fair value through profit or loss, with gains and losses in the changes of the fair value taken to net trading income in the income statement.

Financial assets and liabilities held for trading relates mainly to client-facilitating activities carried out by the Global

Markets business. These contracts are managed on a combined basis and are therefore assessed on a total portfolio

basis rather than as stand-alone asset and liability classes.

Financial assets held for trading


(in millions)	31 December 2025	31 December 2024
Trading securities
Government bonds	606	1,169
Corporate debt securities	1,438	1,246
Equity securities		2
Total trading securities	2,044	2,416
Other trading assets		87
Total financial assets held for trading	2,044	2,503


ABN AMRO	Annual Report 2025	328


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Financial liabilities held for trading


(in millions)	31 December 2025	31 December 2024
Bonds	1,515	1,040
Equity securities	1
Total short security positions	1,516	1,040
Other liabilities held for trading	114	123
Total financial liabilities held for trading	1,631	1,163

15 Derivatives



	Accounting policy for derivatives A derivative is a financial instrument or other contract within the scope of IFRS 9 with all three of the following characteristics: • its value changes in response to the change in a specified interest rate, financial instrument price, commodity price, foreign exchange rate, index of prices or rates, credit rating or credit index, or other variable, provided in the case of a non-financial variable that the variable is not specific to a party to the contract (sometimes called the ‘underlying’) • it requires no initial net investment or an initial net investment that is smaller than would be required for other types of contracts that would be expected to have a similar response to changes in market factors • it is settled at a future date Derivatives are recorded at fair value.
	Derivative assets and liabilities subject to master netting arrangements are presented net only when they satisfy the eligibility requirements for netting under IAS 32. ABN AMRO did not have any netted derivative positions in the statement of financial position in either 2025 or 2024.

Derivatives comprise derivatives held for trading and derivatives held for risk management purposes. Derivatives held

for trading are closely related to facilitating the needs of our clients. A significant part of the derivatives in the trading

portfolio is related to serving clients in their risk management to hedge, for example, currency or interest rate

exposures. ABN AMRO also provides products traded on the financial markets to institutional and individual clients and

governments.

Derivatives held for risk management purposes include derivatives qualifying for hedge accounting and those used for

economic hedges. A hedging instrument, for hedge accounting purposes, is a designated derivative whose fair value

or cash flows are expected to offset changes in the fair value or cash flows of a designated hedged item.

As derivative transactions and the related cash collateral held at a CCP are settled on a daily basis, the carrying

amount of these positions in the statement of financial position is nil.

From a risk perspective, most of the banks derivative trading activities relate to deals with customers that

are normally offset by transactions with other counterparties. The bank may also take positions with the

expectation of profiting from favourable movements in prices, rates or indices.


ABN AMRO	Annual Report 2025	329


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


							31 December 2025
	Derivatives held for trading			Economic hedges			Hedge accounting	Total derivatives
(in millions)	Interest rate	Currency	Other	Interest rate	Currency	Other	Interest rate
Exchange traded
Fair value assets	5							6
Fair value liabilities	4		23					27
Notionals	1,037	16	198					1,251
Over-the-counter
Fair value assets	2,851	615	2	149	288		23	3,928
Fair value liabilities	1,032	413		67	199		229	1,940
Notionals¹	2,118,161	63,249	460	4,759	37,629		169,816	2,394,075
Total
Fair value assets	2,857	616	2	149	288		23	3,933
Fair value liabilities	1,036	413	23	67	199		229	1,967
Notionals	2,119,198	63,266	658	4,759	37,629		169,816	2,395,326
1. Prior to 30 June 2025, the notional amounts on Over-the-counter derivatives were split in Central counterparties and other bilateral derivatives. As of 30 June 2025, these lines have been combined.


							31 December 2024
	Derivatives held for trading			Economic hedges			Hedge accounting	Total derivatives
(in millions)	Interest rate	Currency	Other	Interest rate	Currency	Other	Interest rate
Exchange traded
Fair value assets	5							5
Fair value liabilities	3							3
Notionals	429	22						451
Over-the-counter
Fair value assets	3,056	829	1	33	376		46	4,342
Fair value liabilities	1,427	690	4	37	113		224	2,495
Notionals¹	2,054,564	62,798	477	938	31,636		179,884	2,330,297
Total
Fair value assets	3,061	829	1	33	376		46	4,347
Fair value liabilities	1,430	690	4	37	113		224	2,499
Notionals	2,054,992	62,820	477	938	31,636		179,884	2,330,749
1. Prior to 30 June 2025, the notional amounts on Over-the-counter derivatives were split in Central counterparties and other bilateral derivatives. As of 30 June 2025, these lines have been combined.


ABN AMRO	Annual Report 2025	330


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

16 Hedge accounting



	Accounting policy for hedge accounting ABN AMRO enters into various derivative and non-derivative instrument transactions with external parties to hedge risks on assets, liabilities, highly probable forecasted transactions and net investments. The accounting treatment of the hedged item and the hedging instrument depends on whether the hedge relationship qualifies for hedge accounting. Qualifying hedges may be designated as fair value hedges, cash flow hedges or hedges of net investments. A non-derivative financial asset or liability may be designated as a hedging instrument for hedge accounting purposes only if it hedges the risk of changes in foreign currency exchange rates. The hedged item can be an asset, a liability, or a net investment in a foreign operation that (a) exposes the entity to the risk of changes in fair value or future cash flows, and (b) is designated as being hedged. The hedged risks are typically changes in interest rates or foreign currency rates. ABN AMRO’s market risk management strategy, which includes interest rate risk and foreign currency risk in the banking book, is described in more detail in the Risk, funding & capital chapter. Both at the inception of the hedge and on an ongoing basis, ABN AMRO assesses whether the derivatives designated in each hedging relationship are expected to be and have been highly effective in offsetting changes in the fair value or cash flows of the hedged item. These prospective and retrospective effectiveness tests are performed by using a regression analysis. ABN AMRO applies the following criteria to assess whether the hedging relationship is effective: • a regression co-efficient (R squared), which measures the correlation between the variables in the regression, and • a slope of the regression line is within a range of 0.80-1.25 Hedge ineffectiveness and gains and losses on components of a derivative that are excluded from the assessment of hedge effectiveness are recorded directly in the result from financial transactions as part of other operating income. ABN AMRO discontinues hedge accounting when the hedge relationship has ceased to be effective or is no longer expected to be effective, or when the derivative or hedged item is sold or otherwise terminated.

	Application of IAS 39 as endorsed by the European Union As permitted by IFRS 9 paragraph 7.2.21, ABN AMRO has elected to continue applying the requirements of IAS 39 as endorsed by the European Union instead of applying the hedge accounting requirements of IFRS 9. The EU‑endorsed version of IAS 39 provides relief from certain hedge accounting requirements when compared to the full hedge accounting text of IAS 39. One of these reliefs is that negative credit spreads can be excluded from hedge relationships. ABN AMRO applies this to several micro fair value hedge relationships. Another relief is that the impact of changes in the estimates of the repricing dates is considered ineffective only if it leads to over‑hedging. This relief is applied in the macro fair value hedge. Fair value hedges ABN AMRO applies fair value hedge accounting on individual hedged items (micro fair value hedging), as well as on a portfolio of hedged items (macro fair value hedging). Where a derivative financial instrument hedges the exposure to changes in the fair value of the hedged item, the hedged item is adjusted in relation to the risk being hedged. Gains or losses on remeasurement of both the hedging instrument and the hedged item are recognised in the income statement as result from financial transactions, which is part of the line item Other operating income. Hedge effectiveness for fair value hedges is measured as the amount by which the changes in the fair value of the hedging instrument are different from the changes in the fair value of the hedged item. When a fair value hedge of interest rate risk is terminated, any value adjustment to the carrying amount of the hedged item is amortised to profit or loss over the original designated hedging period, or taken directly to income if the hedged item is derecognised.


ABN AMRO	Annual Report 2025	331


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025



	Micro fair value hedge accounting Hedging instruments designated in individual fair value hedge relationships principally consist of interest rate swaps and interest rate options that are used to protect against changes in the fair value of fixed-rate assets and fixed-rate liabilities due to changes in market interest rates. The main sources of hedge ineffectiveness in micro fair value hedges are: • the effect of the counterparty and the bank’s own credit risk on the fair value of the interest rate swap that is not reflected in the fair value of the hedged item, which is only attributable to the change in the interest rate • the difference in discounting between the hedged item and the hedging instrument • potential differences in maturities and interest conditions of the hedged item and the hedging instrument Macro fair value hedge accounting ABN AMRO manages the interest rate risk arising from fixed-rate mortgages by entering into interest rate swaps. The exposure from this portfolio changes frequently due to new loans originated, contractual repayments and changes in expected future prepayments. To ensure an effective matching of hedged items and hedging instruments, ABN AMRO applies a dynamic strategy in which hedged items are de-designated and re‑designated on a monthly basis. The hedge accounting relationship is reviewed and re-designated on a monthly basis. The hedged item consists of a volume of mortgages that have a fixed interest rate and are accounted for at amortised cost. At each designation, the mortgage cash flows are allocated to monthly time buckets, based on the expected maturity dates. ABN AMRO models the expected interest maturity dates of mortgages, taking into account the modelled prepayments applied to the contractual cash flows and the maturity dates of the mortgage portfolio. If the interest rate swap notional exceeds the expected mortgage notional in any given month, taking into account the uncertainty of the expected mortgage notional by applying a haircut, mortgages that mature in adjacent buckets are designated to the interest rate swaps. Changes in the fair value of the mortgages that are attributable to the hedged interest rate risk are recognised as fair value adjustments from hedge accounting in the income statement and adjust the carrying amount of the mortgages. The recognised fair value changes in the mortgages partially offset the changes in fair value of the interest rate swaps and therefore reduce the profit or loss volatility that would otherwise arise from changes in the fair value of the interest rate swaps alone. At the start of the hedge relationships and at each monthly re-designation, the difference between the fair value attributable to the hedged interest rate risk and the carrying amount of the hedged mortgages is amortised over the remaining life of the hedged item. In addition to the sources of ineffectiveness described for micro fair value hedges, the sources of ineffectiveness specifically for macro hedges are: • the difference between the expected and actual volume of prepayments for the mortgage portfolio to the extent that the difference would lead to over-hedging; and • the difference in payment frequency between the fixed leg of the hedging instrument and the payment frequency of the hedged item (mortgages). Cash flow hedges ABN AMRO applies cash flow hedge accounting to a portfolio of future cash flows on banking book assets and liabilities – the hedged items – and a portfolio of interest rate swaps – the hedging instruments. The hedge relationship is reviewed on a monthly basis and the hedging instruments and hedged items are de-designated or re-designated, if necessary, to maintain an effective hedge accounting relationship. When a derivative financial instrument hedges the exposure to variability in the cash flows from a hedged item, the effective part of any gain or loss on remeasurement of the hedging instrument is recognised directly in other comprehensive income. Hedge effectiveness for the macro cash flow hedge is measured as the amount by which the changes in the fair value of the interest rate swaps are in excess of changes in the fair value of the expected cash flows in the hedge relationship. Any ineffective part of the cash flow hedge is immediately recognised


ABN AMRO	Annual Report 2025	332


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025



	in other operating income. When a cash flow hedging instrument or hedge relationship is terminated but the hedged transaction is still expected to occur, the accumulated gains or losses continue to be recognised in other comprehensive income and are transferred to the income statement when the hedged transaction affects profit or loss. The gains or losses are included in the same line item as the hedged transaction. In the exceptional case that the hedged transaction is no longer expected to occur, the accumulated gains or losses recognised in other comprehensive income are recognised in the income statement immediately.

	The main sources of hedge ineffectiveness for cash flow hedges are: • the effect of the counterparty and the bank’s own credit risk on the fair value of the interest rate swap that is not reflected in the fair value of the hedged item, which is only attributable to the change in the interest rate, and • potential differences in maturities and interest conditions of the hedged item and the hedging instrument The hedged items in the macro cash flow hedge are future cash flows, which are derived from the projected balance sheet. This projected balance sheet takes the contractual terms and conditions of financial assets and liabilities and combines these with estimated prepayments, volume growth rates and interest scenarios. Within the projected balance sheet, assets and liabilities are grouped on the basis of the specific interest rate index on which they reprice (e.g. one month, three months, six months, twelve months). For each repricing index, all assets and liabilities are allocated on a gross basis to monthly buckets in which they reprice until their maturity. The notional amounts of the interest rate swaps, which can be either pay or receive floating interest, are also grouped by interest rate index and allocated to monthly repricing buckets until their maturity. The hedge relationship is established by designating the interest rate swap cash flows per bucket to the corresponding bucket of cash flows projected for the hedged items. The hedged risk identified is the benchmark rate that applies to the buckets. If no projected cash flows are available in the corresponding bucket with the applicable benchmark rate, the interest rate swap cash flows are designated to projected cash flows in a bucket with a different benchmark. The availability of projected cash flows in the buckets is not constant over time and is therefore evaluated on a monthly basis. Changes in cash flow projections may lead to a revision of the designation. Back-testing is performed on the interest rate risk models. Historical data are used to review the assumptions applied. Hedges of net investments in foreign operations ABN AMRO may enter into foreign currency derivatives and currency borrowings to hedge various net investments in foreign operations. For such hedges, currency translation differences arising on translation of the currency of these instruments to euros are recognised directly in the currency translation reserve in other comprehensive income, insofar as they are effective. The accumulated gains or losses recognised in other comprehensive income are transferred to the income statement on the disposal of the foreign operation. In previous years, ABN AMRO hedged its currency exposure to certain investments in foreign operations by hedging its net investment in these foreign operations with forward contracts. ABN AMRO currently still holds some currency translation reserve for these respective positions, but no longer applies net investment hedge accounting. Hedges not qualifying for hedge accounting The fair value changes of derivative transactions used to hedge against economic risk exposures that do not qualify for hedge accounting, or for which it is not cost-beneficial to apply hedge accounting, are recognised directly in profit or loss.


ABN AMRO	Annual Report 2025	333


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Effect on financial position and performance - hedging instruments


					31 December 2025
	Notional amount	Carrying amount		Line item in the statement of financial position	Changes in fair value used for calculation hedge ineffectiveness for the year
(in millions)		Assets	Liabilities
Cash flow hedges - macro
Interest rate	23,842			Derivatives	105
Fair value hedges - macro
Interest rate	36,832			Derivatives	1,137
Fair value hedges - micro
Interest rate	109,157	23	229	Derivatives	111
Economic hedges
Total economic hedges	42,388	437	266	Derivatives	n/a


					31 December 2024
	Notional amount	Carrying amount		Line item in the statement of financial position	Changes in fair value used for calculation hedge ineffectiveness for the year
(in millions)		Assets	Liabilities
Cash flow hedges - macro
Interest rate	36,102			Derivatives	133
Fair value hedges - macro
Interest rate	39,088			Derivatives	-975
Fair value hedges - micro
Interest rate	104,695	46	224	Derivatives	314
Economic hedges
Total economic hedges	32,575	409	150	Derivatives	n/a

The deltas in the hedge accounting numbers are largely caused by interest rate developments in 2025. Please refer

to Note 6 - Net income from other operating activities where hedge ineffectiveness is included.

Effect on financial position and performance - hedged item


							31 December 2025
	Carrying amount of the hedged item		Accumulated amount of fair value hedge adjustments on the hedged item		Line item in the statement of financial position	Change in value used for calculating hedge ineffectiveness for the year	Cash flow hedge reserve/ Foreign currency translation reserve
	Assets	Liabilities	Assets	Liabilities			Continuing hedges	Discontinued hedges
(in millions)	active and discontinued	active and discontinued	active and discontinued	active and discontinued
Cash flow hedges - macro
Interest rate						-92	1,114	-833
Fair value hedges - macro
Interest rate - Financial assets at AC	31,355		-5,477		Residential mortgages	-1,130
Fair value hedges - micro
Interest rate - Financial assets at FVOCI	44,603		-1,588		Financial investments	-607
Interest rate - Financial assets at AC	408		43		Corporate & other loans	-61
Interest rate - Financial liabilities at AC		58,503		-3,605	Issued debt & subordinated liabilities	568
Net investment hedges
Currency								-41


ABN AMRO	Annual Report 2025	334


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


							31 December 2024
	Carrying amount of the hedged item		Accumulated amount of fair value hedge adjustments on the hedged item		Line item in the statement of financial position	Change in value used for calculating hedge ineffectiveness for the year	Cash flow hedge reserve/ Foreign currency translation reserve
	Assets	Liabilities	Assets	Liabilities			Continuing hedges	Discontinued hedges
(in millions)	active and discontinued	active and discontinued	active and discontinued	active and discontinued
Cash flow hedges - macro
Interest rate						-129	1,032	-1,046
Fair value hedges - macro
Interest rate - Financial assets at AC	34,402		-4,686		Residential mortgages	951
Fair value hedges - micro
Interest rate - Financial assets at FVOCI	41,425		-981		Financial investments	668
Interest rate - Financial assets at AC	478		102		Corporate & other loans	5
Interest rate - Financial liabilities at AC		58,685		-3,076	Issued debt & subordinated liabilities	-963
Net investment hedges
Currency								-41

The accumulated amount of fair value hedge adjustments remaining in the statement of financial position for hedged

items that have ceased to be adjusted for hedging gains and losses amounted to EUR 1.3 billion negative as at

31 December 2025 (31 December 2024: EUR 1.3 billion negative).


ABN AMRO	Annual Report 2025	335


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Effect on financial position and performance - hedge ineffectiveness and hedging gains or losses


							31 December 2025
(in millions)	Changes in fair value used for calculation hedge ineffectiveness for the year - hedged item	Changes in value used for calculating hedge ineffectiveness for the year - hedging instrument	Hedge ineffectiveness recognised in profit or loss	Line item in profit or loss (that includes hedge ineffectiveness)	Changes in the value of the hedging instrument recognised in OCI¹	Amount reclassified from the cash flow hedge reserve to profit or loss - hedges item affected profit or loss²	Amount reclassified from the foreign currency translation reserve to profit or loss	Line item affected in profit or loss because of the reclassification
Cash flow hedges - macro
Interest rate	-92	105	13	Other operating income	92	204		Net interest income
Fair value hedges - macro
Interest rate	-1,130	1,137	6	Other operating income
Fair value hedges - micro
Interest rate	-100	111	11	Other operating income

							31 December 2024
(in millions)	Changes in fair value used for calculation hedge ineffectiveness for the year - hedged item	Changes in value used for calculating hedge ineffectiveness for the year - hedging instrument	Hedge ineffectiveness recognised in profit or loss	Line item in profit or loss (that includes hedge ineffectiveness)	Changes in the value of the hedging instrument recognised in OCI¹	Amount reclassified from the cash flow hedge reserve to profit or loss - hedges item affected profit or loss²	Amount reclassified from the foreign currency translation reserve to profit or loss	Line item affected in profit or loss because of the reclassification
Cash flow hedges - macro
Interest rate	-129	133	4	Other operating income	129	194		Net interest income
Fair value hedges - macro
Interest rate	951	-975	-24	Other operating income
Fair value hedges - micro
Interest rate	-291	314	23	Other operating income
1. The amount reconciles to 'Net gains/(losses)' in the 'Consolidated statement of comprehensive income'.
2. The amount reconciles to 'Less: Reclassification through the income statement' in the 'Consolidated statement of comprehensive income'.

Amount, timing and uncertainty of future cash flows - hedging instruments


					31 December 2025
(in millions, nominal amounts)	Within 3 months	More than 3 months but within 1 year	More than 1 year but within 5 years	More than 5 years but within 10 years	More than 10 years	Total
Fair value hedges - micro
Payers - Interest rate	1,666	2,804	17,258	15,819	5,912	43,459
Receivers - Interest rate	2,862	5,451	26,786	20,489	10,111	65,698

					31 December 2024
(in millions, nominal amounts)	Within 3 months	More than 3 months but within 1 year	More than 1 year but within 5 years	More than 5 years but within 10 years	More than 10 years	Total
Fair value hedges - micro
Payers - Interest rate	1,360	3,117	18,566	14,067	6,060	43,170
Receivers - Interest rate	602	7,740	21,530	19,391	12,262	61,524


ABN AMRO	Annual Report 2025	336


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

The weighted average fixed rate of the interest rate swaps included in micro hedge relationships varied between 2.3%

and 2.6% as at 31 December 2025 (2.0% and 2.5% as at 31 December 2024), depending on the origination date,

currency, product type and original maturity.

17 Financial investments



	Accounting policy for financial investments
	Financial investments include financial instruments measured at fair value through other comprehensive income (FVOCI) and financial instruments measured at fair value through profit or loss (FVTPL).

	Accounting policy for financial instruments measured at fair value through other comprehensive income
	Unrealised gains and losses on FVOCI assets are recognised directly in other comprehensive income, net of applicable taxes. Interest earned, premiums, discounts and qualifying transaction costs of interest-earning FVOCI assets are amortised to income on an effective interest rate basis. When FVOCI debt instruments are sold, the cumulative gain or loss recognised in other comprehensive income is transferred to other operating income in the income statement. The impairment loss resulting from the ECL on FVOCI debt instruments is recognised in the impairment charges on financial instruments in the income statement. The related loss allowance is recognised in other comprehensive income and does not reduce the carrying amount of the FVOCI debt instruments. ABN AMRO’s impairment assessment and measurement approach for FVOCI debt instruments is set out in the Credit risk management section of the Risk, funding & capital management chapter and Note 1 Accounting Policies. Fair value changes in equity instruments that are irrevocably designated as FVOCI upon initial recognition are recognised in other comprehensive income and not subsequently reclassified to the income statement.

	Accounting policy for financial instruments measured at fair value through profit and loss
	Financial investments can be designated at FVTPL if doing so eliminates or significantly reduces a measurement or recognition inconsistency (an accounting mismatch). ABN AMRO also has financial instruments that are mandatorily measured at fair value because they do not meet the SPPI test.


(in millions)	31 December 2025	31 December 2024
Financial investments
Debt securities held at fair value through other comprehensive income	48,921	46,196
Held at fair value through profit or loss	1,310	977
Total financial investments	50,231	47,173

Debt securities held at fair value through other comprehensive income consist mainly of government bonds.

Financial investments measured at fair value through other comprehensive income


(in millions)	31 December 2025	31 December 2024
Interest-earning securities
Dutch government	3,399	3,261
US Treasury and US government	7,300	7,140
Other OECD government	18,851	19,143
Non-OECD government	190	170
International bonds issued by the European Union	3,529	3,319
European Stability Mechanism	2,566	2,441
Mortgage- and other asset-backed securities	5,400	5,288
Financial institutions	7,624	5,404
Non-financial institutions	63	29
Total investments held at fair value through other comprehensive income	48,921	46,196


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≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Government bonds by country of origin


		31 December 2025			31 December 2024
(in millions)	Accumulated unrealised gains/(losses) and fair value hedges gains/(losses)	Impairments	Fair value	Accumulated unrealised gains/(losses) and fair value hedges gains/(losses)	Impairments	Fair value
Dutch national government	-155		3,399	-61	-1	3,261
USA national government	-18		7,300	-267		7,140
German national government	-157		5,280	-118		5,315
French national government	-45	-1	1,677	-61		2,025
Belgian national government	-153		2,808	-152		2,791
Austrian national government	-71		1,745	-34		1,658
Finnish national government	-60		1,823	-50		1,496
Luxembourg national government	-18		345	-19		305
Canadian national government	-41		1,112	-45		1,186
Japanese national government			1,692	-1		2,426
Polish national government	32		329	34		330
Spanish national government			707	4		615
United Kingdom national government	-10		162	-11		170
Danish national government	-22		322	-22		341
Italian national government	-12		503	-29		382
Irish national government	-9		159	2		92
Portuguese national government	-1		85			10
Czech national government			28
Slovenian national government	-1		29
Slovak national government			25
Estonian national government			6
Icelandic national government			4
Lithuanian national government	-1		9
Brazilian national government			115			100
Singapore national government			66			70
Croatian national government			9
European Union bonds (excl. European Financial Stability Facility)	-614		3,529	-523		3,319
Total government bonds	-1,356	-1	33,269	-1,354	-1	33,034

Critical accounting estimates and judgements

Interest-bearing debt securities classified as FVOCI investments are assessed at each reporting date to establish

whether there are any expected credit losses. ABN AMRO has developed models to determine such credit losses.

These are explained in more detail in the Risk, funding & capital chapter and Note 1 Accounting Policies. Impairment

charges on FVOCI instruments are recorded in (un)realised gains/(losses) fair value through OCI in the statement of

comprehensive income.

Financial investments measured at fair value through profit or loss


(in millions)	31 December 2025	31 December 2024
Investments designated held at fair value through profit or loss	289
Private equities and venture capital	670	680
Equity securities	350	297
Total investments held at fair value through profit or loss	1,310	977


ABN AMRO	Annual Report 2025	338


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

18 Securities financing



	Accounting policy for securities financing Securities financing is measured at amortised cost. Securities financing consists of securities borrowing and lending and sale and repurchase transactions. Securities borrowing and securities lending transactions are generally entered into on a collateralised basis, with securities usually advanced or received as collateral. The transfer of the securities themselves is not reflected in the statement of financial position unless the risks and rewards of ownership are also transferred. If cash is advanced or received, securities borrowing and lending activities are recorded at the amount of cash advanced (included in loans and advances) or received (due to banks or customers). The market value of the securities borrowed or lent is monitored on a daily basis, and the collateral levels are adjusted in accordance with the underlying transactions. Fees and interest received or paid are recognised on an effective interest rate basis and recorded as interest income or interest expense. Sale and repurchase transactions involve purchases (or sales) of investments with agreements to resell (or repurchase) substantially identical investments at a certain date in the future at a fixed price. Investments purchased subject to commitments to resell them at future dates are not recognised. The amounts paid are recognised in loans and advances to either banks or customers and are shown as collateralised by the underlying security. Investments sold under repurchase agreements continue to be recognised in the statement of financial position. Proceeds from the sale of the investments are reported as liabilities to either banks or customers. The difference between the sale and repurchase price is recognised over the period of the transaction and recorded as interest income or interest expense, using the effective interest rate method. If borrowed securities are sold to third parties, the proceeds from the sale and a liability for the obligation to return the collateral are recorded at fair value.


		31 December 2025			31 December 2024
(in millions)	Banks	Customers	Total	Banks	Customers	Total
Assets
Reverse repurchase agreements	5,432	24,525	29,958	3,890	16,099	19,988
Securities borrowing transactions	6,667	3,548	10,215	2,834	4,167	7,001
Total	12,099	28,074	40,173	6,723	20,266	26,989
Liabilities
Repurchase agreements	791	14,502	15,292	769	9,545	10,315
Securities lending transactions	27		27	37		37
Total	818	14,502	15,320	807	9,545	10,352

Securities financing transactions include balances relating to reverse repurchase activities and cash collateral on

securities borrowed. ABN AMRO controls the credit risk associated with these activities by monitoring counterparty

credit exposure and collateral values on a daily basis and requiring additional collateral to be deposited with

ABN AMRO when deemed necessary.


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19 Fair value of financial instruments carried at fair value



	Accounting policy for fair value of financial instruments The fair value is defined as the price that would be received when selling an asset or paid when transferring a liability in an orderly transaction between market participants at the measurement date. For financial instruments that are actively traded and for which quoted market prices or market parameters are readily available, the fair value is determined in a highly objective manner. However, when observable market prices and parameters do not exist, management judgement is necessary to estimate fair value. For financial instruments where no active liquid market exists, or quoted prices are unobtainable, recent market transactions are used or the fair value is estimated using a variety of valuation techniques – including reference to similar instruments for which market prices do exist, or to valuation techniques such as discounted cash flow models or option pricing models (e.g. Black Scholes). When portfolios of financial assets and liabilities are measured on the basis of the net exposure to the credit risk of a particular counterparty, any existing arrangements that mitigate the credit risk exposure (e.g. master netting agreements with the counterparty) are taken into account. Unobservable inputs are estimated using a combination of management judgement, historical data, market practice and benchmarking to other relevant observable market data. The difference between the transaction price and the internal valuation at inception, calculated using a model, is reserved and amortised to profit or loss at appropriate points over the life of the instrument, typically taking account of the ability to obtain reliable external data, the passage of time and the use of offsetting transactions. Where inputs to the valuation of a new transaction cannot be reliably determined, the transaction is initially recognised at its transaction price. Subsequent changes in fair value as calculated by the valuation model are reported as profit or loss or in equity. In order to determine a reliable fair value, where appropriate, management applies valuation adjustments to the pricing information derived from the above sources. These adjustments reflect management’s assessment of factors that market participants would consider in setting a price, to the extent that these factors have not already been included in the information from the above sources. The main valuation adjustments required to arrive at a fair value are as follows: • Bid-ask adjustments. If the model calculates a mid-market price, it is adjusted to take into account the relevant bid-offer spread. • Credit and debit valuation adjustments. In addition to credit valuation for loans measured at fair value through profit or loss, credit valuation adjustments and debit valuation adjustments are incorporated into derivative valuations to reflect the impact on fair value of counterparty credit risk and how counterparties consider ABN AMRO’s creditworthiness respectively. • Liquidity adjustments. ABN AMRO uses different techniques to determine the price or input parameters of the pricing model dependent on the liquidity in the market. • Funding valuation adjustment. The funding valuation adjustment incorporates the incremental cost of funding into the valuation of uncollateralised and partially collateralised derivatives. • Own credit adjustment. An own credit risk adjustment is applied to financial liabilities where it is believed that counterparties will consider ABN AMRO’s creditworthiness when pricing such instruments. • Model valuation adjustments for any known limitations. Management assesses the appropriateness of any model used on an ongoing basis. To the extent that the price provided by internal models does not represent the fair value of the instrument, for instance in highly stressed market conditions, management makes adjustments to the model valuation to calibrate to other available pricing sources. We believe our estimates of the fair value are adequate. However, the use of different models or assumptions could result in changes to our reported results.


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Valuation control framework

ABN AMRO has in place designated controls and processes to determine the fair value of financial instruments. A

process has been designed to ensure there are formalised review protocols to independently review and validate fair

values, separately from the business departments entering into the transactions. This includes specific controls to

ensure consistent pricing policies and procedures, incorporating disciplined price verification for both market and

counterparty risk trades.

The business department entering into the transaction is responsible for the initial determination and recording of the

fair value of the transaction. Controls of the profit or loss are recorded on a daily basis by trading and treasury front-

office staff. The independent price-verification process, a key element of the control environment, is segregated from

the recording of the transaction’s valuation. Valuations are first calculated by the department. Such valuations may be

current bid or offer prices in an active market, or may be derived using a model and variable model inputs. These

valuations are reviewed and, if necessary, amended by the independent price-verification process. This process

involves a team that operates independently from the team trading the financial instruments and performs a review of

valuations in light of available pricing evidence. Independent price verification is frequently performed by matching

the business valuations with independent data sources. The reviews are performed at least once a month, both for

trading positions and non-trading positions. The independent price-verification control includes formalised reporting

and escalation to management of any valuation differences in breach of the defined thresholds. When models are

used to value products, these models are subject to a model review process. This process requires different levels of

model documentation, testing and review, depending on the complexity of the model and the size of our exposure to

the model.

Valuation techniques

A number of methodologies are used to determine the fair value of financial instruments for which observable prices

in active markets for identical instruments are not available. Values between and beyond available data points are

obtained by interpolation and/or extrapolation. When valuation techniques are used, the fair value can be significantly

impacted by the choice of the valuation model and the underlying assumptions made for factors such as the amount

and timing of cash flows, discount rates and credit risk.

Interest rate derivatives

This category includes interest rate swaps, cross-currency swaps, options and forward rate agreements. These

products are valued by estimating future cash flows and discounting these cash flows, using appropriate interest rate

curves. The exception is interest option contracts, which are valued using market standard option pricing models. The

inputs for the discounting cash flow models are principally observable benchmark interest rates in active markets such

as interbank rates and quoted interest rates in the swap, bond and futures markets. The inputs for credit spreads –

where available – are derived from prices of credit default swaps or other credit-based instruments, such as debt

securities. In other cases, credit spreads are obtained from pricing services. The additional inputs for the option pricing

models are price volatilities and correlations, which are obtained from broker quotations or pricing services or derived

from option prices. Because of the observability of the inputs used in the valuation models, the majority of the interest

rate derivative contracts are classified as level 2. If adjustments to interest rate curves, credit spreads, correlations or

volatilities are based on significant unobservable inputs, the contracts are classified as level 3. Exchange traded

options and futures are valued using quoted market prices and are hence classified as level 1.

Foreign exchange contracts

Foreign exchange contracts include foreign exchange forward contracts, foreign exchange options and foreign

exchange swaps. The majority of the foreign exchange contracts at ABN AMRO are traded as over-the-counter

derivatives. These instruments are valued using foreign currency exchange rates. There are observable markets for

spot and forward contracts as well as for futures in the world’s major currencies. The over-the-counter foreign

exchange contracts are therefore classified as level 2.

Government debt securities

Government debt securities consist of government bonds and bills with fixed or floating rate interest payments issued

by sovereign governments. As these instruments are generally traded in active markets and prices can be derived

directly from those markets, they are classified as level 1. Highly liquid bonds are valued using exchange traded prices.

Less liquid bonds are valued using observable market prices, which are sourced from broker quotes, inter-dealer

prices or other reliable pricing services. For a minority of the government debt securities, active market prices are not


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available. In these cases ABN AMRO uses discounted cash flow valuation techniques that incorporate observable

market data for similar government instruments. The main inputs are interest rate curves, liquidity spreads and credit

spreads. The instruments for which this method is applied are classified as level 2. If adjustments to any of the main

inputs are made based on significant unobservable inputs, the instrument is classified as level 3.

Corporate debt securities

Corporate debt securities consist primarily of corporate bonds and other debt securities issued by corporate entities.

Most of these instruments are standard fixed or floating rate securities. Corporate debt securities are generally valued

using observable market prices, which are sourced from broker quotes, inter-dealer prices or other reliable pricing

services. These instruments are classified as level 1. If observable market prices are not available, ABN AMRO uses

discounted cash flow valuation techniques, based on inputs derived from comparable instruments and credit default

swap data of the issuer, to estimate credit spreads. These instruments are classified as level 2. If adjustments are made

to any of the main inputs based on significant unobservable inputs, the instrument is classified as level 3.

Equity instruments

Equity instruments that are actively traded on public stock exchanges are valued using readily available quoted prices

and are therefore classified as level 1. Equity investments for which fair value is determined using valuation techniques

based predominantly on observable market inputs are classified as Level 2. Investments in private equity funds are

initially recognised at their transaction price and remeasured to the extent reliable information is available on a case-

by-case basis, and are classified as level 3.

Loans and advances at fair value through profit or loss

Loans and advances at fair value through profit or loss consist primarily of contracts with corporate clients where the

contractual cash flows do not meet the SPPI requirements or are held in a business model with the objective of

generating cash flows from sales. The return on the contracts with embedded derivatives is based on the price of

underlying commodity contracts or loans with a floating interest rate. Discounted cash flow models are used to value

these contracts. The main inputs are interest rate curves, quoted commodity prices, liquidity spreads and credit

spreads. The instruments are classified as level 2. If adjustments to interest rate curves, liquidity spreads and credit

spreads are based on significant unobservable inputs, the instruments are classified as level 3.

Issued debt

Issued debt securities are valued using discounted cash flow models, based on current interest rate curves that

incorporate observable inputs. These instruments are classified as level 2. When there are no, or only limited, publicly

quoted prices available for these instruments and unobservable inputs have a significant effect on the fair value

calculation, these instruments are classified as level 3. ABN AMRO refines and modifies its valuation techniques as

markets and products develop and as prices for individual products becomes more or less readily available. While ABN

AMRO believes its valuation techniques are appropriate and consistent with other market participants, the use of

different methodologies or assumptions could result in different estimates of the fair value at the reporting date.

Fair value hierarchy

ABN AMRO analyses financial instruments held at fair value in the three categories described below.

Level 1 financial instruments are those that are valued using unadjusted prices quoted in active markets for identical

financial instruments.

Level 2 financial instruments are those valued using techniques based primarily on observable market data.

Instruments in this category are valued using prices quoted for similar instruments or identical instruments in markets

that are not considered to be active, or using valuation techniques where all inputs that have a significant effect on the

valuation are directly or indirectly based on observable market data.

Level 3 financial instruments are those valued using a valuation technique where at least one input with a significant

effect on the instrument’s valuation is not based on observable market data. The effect of fair value adjustments on the

instrument’s valuation is included in the assessment.

ABN AMRO recognises transfers between levels of the fair value hierarchy at the end of the reporting period during

which the change occurred.


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The following table presents the valuation methods used for determining the fair values of financial instruments

carried at fair value.


			31 December 2025				31 December 2024
(in millions)	Quoted market prices in active markets	Valuation techniques - observable inputs	Valuation techniques - significant unobservable inputs	Total fair value	Quoted market prices in active markets	Valuation techniques - observable inputs	Valuation techniques - significant unobservable inputs	Total fair value
Assets
Government debt securities	606			606	1,119	51		1,169
Corporate debt securities	961	477		1,438	743	503		1,246
Equity securities					2			2
Other financial assets held for trading						87		87
Financial assets held for trading	1,568	477		2,044	1,863	640		2,503
Interest rate derivatives	5	3,017	6	3,028	5	3,116	20	3,140
Foreign exchange contracts		897	7	904		1,203	2	1,206
Other derivatives		2		2		1		1
Derivatives	6	3,915	13	3,933	5	4,320	22	4,347
Government debt securities	122			122
Equity instruments	133	40	848	1,020	133	47	797	977
Other	10		158	167
Financial investments at fair value through profit or loss	265	40	1,006	1,310	133	47	797	977
Government debt securities	35,412	94	329	35,835	35,145		330	35,475
Corporate debt securities	7,518	168		7,686	5,432			5,432
Other debt securities	5,400			5,400	5,288			5,288
Financial assets held at fair value through other comprehensive income	48,330	262	329	48,921	45,866		330	46,196
Loans and advances at fair value through profit or loss		28	486	514		30	600	630
Total financial assets	50,167	4,722	1,833	56,723	47,866	5,037	1,750	54,653
Liabilities
Short positions in government debt securities	822			822	346	172		518
Corporate debt securities	404	289		693	313	208		522
Equity securities	1			1
Other financial liabilities held for trading		114		114		123		123
Financial liabilities held for trading	1,227	403		1,631	660	503		1,163
Interest rate derivatives	4	1,322	6	1,332	3	1,688	1	1,692
Foreign exchange contracts		612		612		803		803
Other derivatives	23			23		4		4
Derivatives	27	1,934	6	1,967	3	2,495	1	2,499
Issued debt		159		159		205		205
Total financial liabilities	1,255	2,496	6	3,757	663	3,203	1	3,867

Transfers between fair value hierarchies

There were no material transfers between the fair value hierarchies.


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Movements in level 3 financial instruments measured at fair value

The following table shows a reconciliation of the opening and closing amounts of level 3 financial assets that are

recorded at fair value.


	Assets				Liabilities
(in millions)	Derivatives	Financial investments at fair value through profit or loss	Financial assets held at fair value through other comprehensive income	Loans and advances at fair value through profit or loss	Derivatives
Balance as at 1 January 2024	26	656	330	676
Purchases		86
Sales		-3		-35
Issuance				42
Redemptions		-14		-157
Gains/(losses) recorded in profit and loss ¹			1	-5
Unrealised gains/(losses) ²	-3	89	-1	59
Transfer between levels	-2				1
Other movements		-17		19
Balance as at 31 December 2024	22	797	330	600	1
Acquisitions/divestments of subsidiaries		204
Purchases		89
Sales
Issuance				60
Redemptions		-1		-38
Gains/(losses) recorded in profit and loss¹		2	1
Unrealised gains/(losses)²	-5	46	-2	-43
Transfer between levels	-4				5
Other movements		-132		-93
Balance as at 31 December 2025	13	1,006	329	486	6
1. Included in other operating income.
2. Unrealised gains/(losses) on derivatives held for trading are included in net trading income, on instruments measured at FVTPL in other operating income and on instruments measured at FVOCI in other comprehensive income.

Level 3 sensitivity information

Interest-earning securities - government bonds

ABN AMRO has a position in a Polish bond, denominated in euros (see Note 17 - Financial investments, and part of

Other OECD governments), for which the market is relatively illiquid. This bond is valued using a discounted cash flow

model. The main inputs are the interest rate curve, liquidity spread and credit spread. The valuation spread is

determined using an internal model. The sensitivity analysis is performed using a range of reasonable valuation

spreads.

Equity shares - preferred shares

Equities measured at fair value through profit and loss and classified as level 3 mainly comprise private equity

investments. Private equity shares are measured at fair value, applying two calculation techniques:

• Using comparable pricing in accordance with the European Private Equity and Venture Capitalist Association (EVCA)

guidelines. This valuation technique is based on earnings multiples of comparable listed and unlisted companies.

The fair value calculation of an investment is strongly linked to movements on public equity markets.

• Net Asset Value (NAV) for fund investments and asset-backed investments. This is determined by using audited and

unaudited company financial statements and any other information available, publicly or otherwise. As a

consequence, the NAV calculation of an investment is strongly linked to movements in the quarterly performance of

the company and can be used as an indicator of fair value.

New investments are initially valued at fair value. Subsequently, the fair value technique - either the EVCA technique or

NAV calculation - is applied for direct investments.


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The sensitivity for using comparable pricing is determined by stressing the earnings multiples in a positive and

negative market scenario, whereas sensitivity testing cannot be applied for the NAV calculation based on the quarterly

performance.

Derivatives

ABN AMRO applies a credit valuation adjustment (CVA) that reflects counterparty credit risk in the fair value

measurement of uncollateralised and partially collateralised OTC derivatives. For counterparties that do not have an

observable credit spread, ABN AMRO applies a proxied credit spread extracted from counterparties of comparable

credit quality that do have an observable credit spread. ABN AMRO performs a probability of default assessment for

each counterparty and allocates an appropriate internal credit risk measure known as a Uniform Counterparty Rating

(UCR). This UCR, which is significant to the entire fair value measurement of the derivative contracts included in the

following table of level 3 sensitivity information, is generated internally and is therefore an unobservable input.

Loans and advances – Equity release mortgages

ABN AMRO offers equity release mortgages which provide a way to liquidate home equity and are designed for senior

homeowners. These loans are valued using a discounted cash flow model for which the assumed prepayment rate is

the most relevant input parameter. The prepayment rate is based on mortality rates and historical prepayment rates

observed for equity release mortgages. The sensitivity range is based on the historical bandwidth observed for

prepayment rates.

Loans and advances - Other

ABN AMRO offers personal loans that feature a waiver on a portion of the outstanding debt upon the decease of the

client. The loans are valued using a discounted cash flow model, in which expected future cashflows are discounted

against actual interest rates, in combination with an adjustment for expected credit losses. The sensitivity range is

based on a bandwidth for expected credit losses.


						31 December 2025
	Valuation technique	Unobservable data	Carrying value	Possible alternative assumptions		Unobservable data range		Unobservable data base
(in millions)				Applying minimum	Applying maximum	Applying minimum	Applying maximum
Equity shares	Private equity valuation	EBITDA multiples	161	-16	16
Equity shares	Private equity valuation	Net asset value	845	-84	84
Interest-earning securities - Government bonds	Discounted cash flow	Liquidity and credit spread	329	-10	14	10bps	108bps	67bps
Loans and advances - Equity release mortgages	Discounted cash flow	Prepayment rate	486	-4	6	3.1%	4.1%	3.6%
Loans and advances - Other	Discounted cash flow	Credit spread
Derivatives held for trading - Assets/liabilities (net)	Discounted cash flow	Probability of default	7				100.0%	41.5%


						31 December 2024
	Valuation technique	Unobservable data	Carrying value	Possible alternative assumptions		Unobservable data range		Unobservable data base
(in millions)				Applying minimum	Applying maximum	Applying minimum	Applying maximum
Equity shares	Private equity valuation	EBITDA multiples	141	-14	14
Equity shares	Private equity valuation	Net asset value	657	-66	66
Interest-earning securities - Government bonds	Discounted cash flow	Liquidity and credit spread	330	-13	19	38bps	157bps	110bps
Loans and advances - Equity release mortgages	Discounted cash flow	Prepayment rate	458	-6	9	2.4%	4.9%	3.6%
Loans and advances - Other	Discounted cash flow	Credit spread	142	-4	7
Derivatives held for trading - Assets/liabilities (net)	Discounted cash flow	Probability of default	22	-2	6		100.0%	24.0%


ABN AMRO	Annual Report 2025	345


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

20 Loans and advances banks



	Accounting policy for loans and advances banks and customers Loans and advances banks, and loans and advances customers, are held in a ‘hold to collect’ business model. Loans and advances for which the contractual cash flows are solely payments of principal and interest (SPPI) are measured at amortised cost, i.e. fair value at initial recognition, adjusted for repayment and amortisation of coupon, fees and expenses to represent the effective interest rate of the asset. Loans and advances that do not pass the SPPI test are measured at fair value through profit or loss. Please refer to Note 1 Accounting policies in the Consolidated Annual Financial Statements.


(in millions)	31 December 2025	31 December 2024
Interest-bearing deposits	1,137	1,169
Loans and advances	708	707
Mandatory reserve deposits with central banks	301	166
Other loans and advances banks	28	12
Subtotal	2,174	2,053
Less: loan impairment allowances	4	4
Total loans and advances banks	2,170	2,049

Mandatory reserve deposits are held with local central banks in accordance with statutory requirements. The most

relevant for the bank are the minimum reserve requirements determined by the ECB. The ECB prescribes how

the minimum reserve amount should be calculated during pre-defined reserve periods. During such a period,

the balances are available for use by ABN AMRO. The bank manages and monitors deposits to ensure that it meets

the minimum reserve requirements for the period.


ABN AMRO	Annual Report 2025	346


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

21 Loans and advances customers



	Accounting policy for loans and advances customers The accounting policy for loans and advances customers is included in Note 20 - Loans and advances banks. Please refer to Note 1 - Accounting policies in the Consolidated Annual Financial Statements.


(in millions)	31 December 2025	31 December 2024
Residential mortgages (excluding fair value adjustment)	163,185	156,209
Fair value adjustment from hedge accounting on residential mortgages	-5,477	-4,686
Residential mortgages, gross	157,708	151,523
Less: loan impairment allowances - residential mortgage loans	120	133
Residential mortgages	157,588	151,390
Consumer loans at amortised cost, gross	6,266	7,575
Less: loan impairment allowances - consumer loans	74	130
Consumer loans at amortised cost	6,192	7,445
Consumer loans at fair value through P&L	486	600
Corporate loans (excluding fair value adjustment)¹	82,535	78,072
Fair value adjustment from hedge accounting on corporate loans	42	102
Financial lease receivables¹	1,891	2,430
Factoring	2,090	3,326
Corporate loans at amortised cost, gross	86,559	83,929
Less: loan impairment allowances - corporate loans	1,026	1,100
Corporate loans at amortised cost	85,532	82,829
Corporate loans at fair value through P&L	28	30
Government and official institutions	342	298
Other loans	5,594	6,191
Fair value adjustment from hedge accounting on other loans	1
Other loans and advances customers, gross	5,936	6,489
Less: loan impairment allowances - other	1	2
Other loans and advances customers	5,935	6,487
Total loans and advances customers	255,760	248,782
1. ABN AMRO performed a review on the classification of loan-to-book value facilities. This resulted in a reclassification from Financial lease receivables to Corporate loans for comparative purposes of EUR 1.4 billion for 2024.

For information on loan impairment allowances, please refer to the Credit risk review section in the Risk, funding &

capital chapter.

22 Fair value of financial instruments not carried at fair value



	Accounting policy for fair value of financial instruments not carried at fair value The categorisation and valuation of financial instruments not carried at fair value is determined in accordance with the accounting policies set out in Note 19 - Fair value of financial instruments carried at fair value.

Valuation methodologies

The methods and assumptions described below have been applied to estimate the fair value of financial instruments

not carried at fair value. These fair values were calculated for disclosure purposes only. Note that the fair value can be

significantly impacted by the choice of valuation model and underlying assumptions concerning factors such as the

amount and timing of cash flows, discount rates, credit risk and liquidity risk.

Short-term financial instruments

The carrying amounts (net of impairment allowances) of financial instruments maturing within a period of less than

three months or that have no contractual maturity are assumed to be a reasonable approximation of their fair value.

For certain instruments, behavioural maturities are applied.


ABN AMRO	Annual Report 2025	347


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Short-term financial instruments are classified as level 2 as unobservable inputs (such as inputs to determine credit

risk, prepayment risk and liquidity risk) do not have a significant influence on the determination of the fair value.

Cash and balances at central banks

Cash and balances at central banks are classified as level 1 as these instruments have a short-term nature, prices from

an active market are available and no fair value adjustments are made to the carrying amounts.

Securities financing

Securities financing includes repurchase and reverse repurchase agreements and securities borrowing and lending

transactions. Due to the short-term characteristics of these instruments and the value and liquidity of available

collateral, their carrying amounts (net of impairment allowances) are considered an approximation of the fair value.

Securities financing amounts are classified as level 2.

Loans and advances banks and customers

The fair value of loans and advances – banks and customers is estimated by a discounted cash flow model based on

contractual cash flows, using actual yields and discounting by risk-free interest rates. Adjustments to reflect changes in

liquidity spreads are applied and prepayment options are included in the estimated fair value. The calculations are

adjusted for credit risk by incorporating the expected credit losses over the estimated lifetime of the loan, based on

parameters including probability of default, loss given default and exposure at default. The loans and advances are

classified as level 3 on the basis that unobservable inputs significantly influence the approximated fair values. The

loans and advances for which unobservable inputs do not significantly influence the approximated fair values are

classified as level 2. Behavioural maturities instead of contractual maturities are used to determine the level

classification of a small part of the portfolio.

Cash collateral paid to counterparties in relation to Credit Support Annexes (CSA) is included in loans and advances –

banks and customers. Due to the short-term characteristics of these instruments, their carrying amounts are

considered an approximation of the fair value. The related amounts are classified as level 2.

Due to banks and customers

The fair value of instruments such as deposits and borrowings included in amounts due to banks and customers is

estimated by a discounted cash flow model based on risk-free interest rates. Adjustments to reflect changes in

liquidity spreads are applied. Amounts due to banks and customers are classified as level 3 on the basis that

unobservable inputs significantly influence the approximated fair values. The financial instruments for which

unobservable inputs do not significantly influence the approximated fair values are classified as level 2. For the

majority of the portfolio, behavioural maturities are used to determine the level classification.

Cash collateral liabilities in relation to Credit Support Annexes (CSA) are included in due to banks and customers.

Due to the short-term characteristics of these instruments, their carrying amounts are considered an approximation of

the fair value. The related amounts are classified as level 2.

Issued debt and subordinated liabilities

The fair value of issued debt securities and subordinated liabilities is based on quoted prices. If these are not available,

the fair value is based on a market approach in which independent quotes from market participants are used for the

debt issuance spreads above the average interbank offered rates (over a range of tenors) that the market would

demand when purchasing new senior or subordinated debt from ABN AMRO. Where necessary, these quotes are

interpolated, using a curve shape derived from CDS prices.


ABN AMRO	Annual Report 2025	348


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


					31 December 2025
	Carrying value				Total fair value	Difference
(in millions)		Quoted market prices in active markets	Valuation techniques - observable inputs	Valuation techniques - significant unobservable inputs
Assets
Cash and balances at central banks	49,486	49,486			49,486
Securities financing	40,173		40,174		40,173
Loans and advances banks	2,170		2,163	12	2,174	4
Loans and advances customers	255,247		28,608	227,367	255,975	728
Total	347,076	49,486	70,944	227,378	347,808	732
Liabilities
Securities financing	15,320		15,320		15,320
Due to banks	4,320		3,666	661	4,328	8
Due to customers	279,126		264,454	14,709	279,163	36
Issued debt	73,913	56,431	17,827		74,258	345
Subordinated liabilities	4,946	1,654	3,461		5,115	169
Total	377,625	58,085	304,728	15,370	378,183	558


					31 December 2024
	Carrying value				Total fair value	Difference
(in millions)		Quoted market prices in active markets	Valuation techniques - observable inputs	Valuation techniques - significant unobservable inputs
Assets
Cash and balances at central banks	44,464	44,464			44,464
Securities financing	26,989		26,989		26,989
Loans and advances banks	2,049		2,051	2	2,053	4
Loans and advances customers	248,152		28,151	218,379	246,529	-1,622
Total	321,654	44,464	57,190	218,381	320,035	-1,619
Liabilities
Securities financing	10,352		10,352		10,352
Due to banks	2,329		2,038	287	2,325	-5
Due to customers	256,186		241,469	15,305	256,774	587
Issued debt	74,337	50,488	23,618		74,106	-231
Subordinated liabilities	6,613	2,684	4,116		6,800	187
Total	349,818	53,172	281,593	15,592	350,357	539


ABN AMRO	Annual Report 2025	349


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

23 Group structure



	Accounting policy for business combinations
	ABN AMRO accounts for business combinations using the acquisition method when control is transferred to the bank. All items of consideration, including contingent consideration, transferred by ABN AMRO are measured and recognised at fair value at the acquisition date. Transaction costs incurred by ABN AMRO in connection with the business combination, other than those associated with the issuance of debt and equity securities, do not form part of the cost of the business combination transaction but are expensed as incurred. The amount of the purchase consideration in excess of ABN AMRO’s share of the fair value of the identifiable net assets acquired (including certain contingent liabilities) is recorded as goodwill.

	ABN AMRO measures the identifiable assets acquired and the liabilities assumed at the fair value at the acquisition date. In a step acquisition, where a business combination occurs in stages and control of the business is obtained in stages, the identifiable assets and liabilities of the acquiree are recognised at fair value when control is obtained. A gain or loss is recognised in profit or loss as the difference between the fair value of the previously held equity interest in the acquiree and its carrying amount. Changes in interests in subsidiaries that do not result in a change of control are treated as transactions between equity holders and are reported in equity.

	Accounting policy for subsidiaries
	ABN AMRO’s subsidiaries are those entities which it directly or indirectly controls. Control over an entity is evidenced by ABN AMRO’s ability to exercise its power in order to affect the variable returns that it is exposed to through its involvement in the entity. The existence and effect of potential voting rights that are currently exercisable are taken into account when assessing whether control exists.
	The assessment of control takes into account all facts and circumstances. The bank reassesses whether it controls an investee if facts and circumstances indicate that there are changes to one or more of the three elements of control (power, exposure to variability in returns, and a link between the two).
	ABN AMRO sponsors entities, including certain special purpose entities which may or may not be directly owned, for the purpose of asset securitisation transactions and other specific and well-defined objectives. Particularly in the case of securitisations, these entities may acquire assets from ABN AMRO's subsidiaries. Some of these entities hold assets that are not available to meet claims of ABN AMRO's creditors or subsidiaries. These entities are consolidated in ABN AMRO’s financial statements when the substance of the relationship between ABN AMRO and the entity indicates that control is held by ABN AMRO.
	ABN AMRO is mainly involved in securitisations of own originated assets, such as various consumer and commercial financial assets. This process generally necessitates a sale of these assets to a special purpose entity (SPE), which in turn issues securities to investors. ABN AMRO’s interests in securitised assets may be retained in the form of senior or subordinated tranches, issued guarantees, interest-only strips or other residual interests, together referred to as retained interests. In many cases, these retained interests convey control, as a result of which the SPE is consolidated and the securitised assets continue to be recognised in the consolidated statement of financial position.
	The financial statements of subsidiaries and special purpose entities are included in the Consolidated Annual Financial Statements from the date on which control commences until the date on which control ceases.
	Accounting policy for associates and joint ventures
	Associates are those entities in which ABN AMRO has significant influence on, but no control or joint control over, the operating and financial policies. Significant influence is generally presumed when ABN AMRO holds between 20% and 50% of the voting rights. Potential voting rights that are currently exercisable are considered in assessing whether ABN AMRO has significant influence. Among other factors, representation on the board of directors, participation in the policy-making process and material transactions between the entity and the investee are considered when determining significant influence.


ABN AMRO	Annual Report 2025	350


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


	A joint venture is an investment in which two or more parties have contractually agreed to share control over the investment. Joint control exists only when decisions about the relevant activities require the unanimous consent of the parties sharing control. The activities conducted through joint ventures include cash transfers, insurance, finance and leasing.

	Investments in associates and joint ventures, including strategic investments, are accounted for using the equity method. Under this method, the investment is initially recorded at cost and subsequently increased (or decreased) for post-acquisition net income (or loss), other movements affecting the equity of the investee and any adjustments required for impairment. ABN AMRO’s share of the profit or loss of the investee is recognised in the share of result in equity accounted investments. If ABN AMRO’s share of losses exceeds the carrying amount of the investment, the carrying amount is reduced to zero, including any other unsecured receivables, and recognition of further losses is discontinued, except if ABN AMRO has incurred obligations or made payments on behalf of the investee.
	Unrealised gains arising from transactions with associates and jointly controlled entities are eliminated to the extent of ABN AMRO’s interest in the entities. Unrealised losses are also eliminated unless the transaction provides evidence of impairment in the asset transferred.

Assets and liabilities of acquisitions and divestments

The following table provides details of the assets and liabilities resulting from the acquisition or disposal of subsidiaries

and equity accounted investments at the date of acquisition or disposal.


	31 December 2025		31 December 2024
(in millions)	Acquisitions ^{1, 2}	Divestments¹	Acquisitions³	Divestments³
Cash and balances at central banks	6,471
Derivatives	300
Financial investments	3,170
Securities financing	1,281
Loans and advances banks	571		3
Loans and advances customers	1,916
Equity-accounted investments	14	-44	4	-205
Property and equipment	117
Goodwill and other intangible assets	36		26
Other assets	383		2
Derivatives	-222
Due to banks	-297
Due to customers	-12,320		-1
Provisions	-64
Tax liabilities	-20		-6
Other liabilities	-618		-1
Net assets acquired/(divested)	718	-45	29	-205
Bargain purchase gain	9
Result on divestments, gross		1		-22
Net acquisition/(disposal) result	9	1		-22
Cash received from divestments/(used for acquisitions)
Total Proceeds from sale/(purchase consideration)	-709	46	-29	183
Cash and cash equivalents acquired/(divested)	6,673
Non-cash consideration			-44
Net cash received from divestments/(used for acquisitions)	5,964	46	-73	183
1. In 2025 ABN AMRO acquired 100% of the shares in Hauck Aufhauser Lampe AG (HAL).
2. The acquisitions column includes EUR 4 million capital increases in equity accounted investments in other entities.
3. In 2024 ABN AMRO acquired 100% of the shares in BUX B.V. and BUX Technology B.V and sold the Joint Venture Neuflize Vie S.A.


ABN AMRO	Annual Report 2025	351


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Acquisitions and Divestments

Acquisitions in 2025

On 1 July 2025, ABN AMRO obtained control through the purchase of 100% of the shares in Hauck Aufhauser Lampe

AG (HAL) in a single transaction. HAL, together with Bethmann Bank, will be a major player in the German wealth

management market and the acquisition strengthens ABN AMRO’s corporate and institutional banking activities in

Germany. The total consideration paid in cash was EUR 705 million. Acquisition-related costs of EUR 8 million were

expensed in 2025 and recognised in ‘Other Operating expenses’. No part of these costs has been included in the

consideration transferred. With this acquisition, ABN AMRO increased its assets under management by

EUR 26.4 billion.

A Purchase Price Allocation process was performed, resulting in fair values as included in the table above. This has

resulted in a bargain purchase gain. Before recognising this gain, ABN AMRO has reassessed whether all assets

acquired and liabilities assumed had been identified and whether their measurement and the consideration

transferred had been appropriately determined. The bargain purchase gain of EUR 9 million (non-taxable, net of

deferred tax liability) is recorded in Other operating income. The gain is mainly the result of a customer relationship

intangible asset of EUR 18 million that was not recognised by the seller. This intangible will be amortised over a 5 year

period.

In 2026, it is planned that HAL will merge with Bethmann Bank, which is expected to result in synergies for the

combined entity. At acquisition date, HAL had loans and advances customers with a fair value of EUR 1,916 million,

gross contractual amounts of EUR 1,987 million and estimated cash flows not expected to be collected of

EUR 47 million. For loans and advances banks, the fair value was EUR 571 million, which equals the contractual

amounts. As part of the loans and advances customers, ABN AMRO acquired a portfolio of purchased or credit-

impaired loans for an amount of EUR 81 million.

From 1 July 2025, HAL contributed to the consolidated financial statements. During this period, an amount of

EUR 65 million was recognised as interest income, EUR 108 million as net fee and commission income, and the profit

for this period was EUR 22 million.

If the acquisition had occurred on 1 January 2025, ABN AMRO’s consolidated net interest income would have been

EUR 6,396 million, net fee and commission income would have been EUR 2,238 million and profit for the year would

have been EUR 2,281 million.

Divestments in 2025

The change in divestments in 2025 was impacted by the sale of equity-accounted investments.

Acquisitions in 2024

On 1 July 2024, ABN AMRO acquired 100% of the shares in BUX B.V. and BUX Technology B.V. The acquisition of BUX

brings advanced financial technology and a user-friendly and intuitive platform that will enhance ABN AMRO’s digital

offerings. The purchase consideration of EUR 68 million was paid in cash. The goodwill that ABN AMRO recognises on

this transaction amounts to EUR 44 million and is attributable to future new business and client relationships, as well

as future improvements in operating efficiency and technology. In addition to goodwill, ABN AMRO recognises

EUR 9 million in net acquired assets, EUR 21 million in intangible assets and EUR 6 million in deferred tax liabilities.

Divestments in 2024

The change in divestments in 2024 was impacted by the sale of the joint venture Neuflize Vie S.A.


ABN AMRO	Annual Report 2025	352


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Equity accounted investments

The following table provides an overview of the most significant investments in associates and joint ventures at equity

method.


			31 December 2025		31 December 2024
(in millions)	Principal place of business	Business line	Carrying amount	Equity interest	Carrying amount	Equity interest
Joint ventures
Other joint ventures			25		25
Associates
Nationale-Nederlanden ABN AMRO Verzekeringen Holding B.V.	The Netherlands	Personal & Business Banking	86	49%	79	49%
Other equity associates			121		140
Total equity associates and joint ventures			233		244

Other investments in equity associates and joint ventures at equity method comprise a large number of equity

associates and joint ventures with individual carrying amounts of less than EUR 75 million.

The following tables provide an overview of the summarised financial information of the most significant investments

in associates and joint ventures at equity method.


31 December 2025	31 December 2024
	Associate	Associate
(in millions)	Nationale-Nederlanden ABN AMRO Verzekeringen Holding B.V.	Nationale-Nederlanden ABN AMRO Verzekeringen Holding B.V.
Assets
Cash and balances at central banks	15	9
Property and equipment	1	2
Other assets	82	94
Total assets	97	105
Liabilities
Other liabilities	21	28
Total liabilities	21	28
Equity
Total equity	76	77
Total liabilities and equity	97	105

Bank's share of equity	86	79
Carrying amount	86	79

Assets related to equity associates are mainly held by Nationale-Nederlanden ABN AMRO Verzekeringen Holding B.V.

The 2025 amounts presented for Nationale-Nederlanden ABN AMRO Verzekeringen Holding are based on the latest

approved annual accounts of Nationale-Nederlanden ABN AMRO Verzekeringen Holding (annual financial

statements 2024). The 2024 amounts presented for Nationale-Nederlanden ABN AMRO Verzekeringen Holding are

based on the latest approved annual accounts of Nationale-Nederlanden ABN AMRO Verzekeringen Holding (annual

financial statements 2023).


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≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


	2025	2024
	Associate	Associate
(in millions)	Nationale-Nederlanden ABN AMRO Verzekeringen Holding B.V.	Nationale-Nederlanden ABN AMRO Verzekeringen Holding B.V.
Other income	26	13
Operating income	26	13
Other operating expenses		2
Operating expenses		2
Profit/(loss) before taxation	25	11
Income tax expense
Profit/(loss) for the period	25	11
Other comprehensive income
Total comprehensive income	25	11


	2025	2024
(in millions)	Associates	Associates
Operating income	633	587
Operating expenses	576	520
Profit/(loss) before taxation	57	67
Income tax expense	1	-1
Profit/(loss) for the period	56	68

The joint ventures and associates had no contingent liabilities or capital commitments other than the minimum capital

requirements under the Solvency Regulation as at 31 December 2025 and 2024.

Unconsolidated structured entities

Unconsolidated structured entities are entities over which ABN AMRO has no control or significant influence.

ABN AMRO is involved with structured entities through securitisation of financial assets and investments in structured

entities. Structured entities generally finance the purchase of assets by issuing debt and equity securities that are

collateralised by the assets held by the structured entities. The debt and equity securities issued by the structured

entities may include tranches with varying levels of subordination. The maximum exposure to losses from these

interests is equal to the total carrying amount.

Sponsoring of unconsolidated structured entities

An entity is considered a sponsor of an unconsolidated structured entity if it had a key role in establishing that entity in

order to enable the transaction that is the purpose of the entity to occur. No sponsoring occurred during 2025.


ABN AMRO	Annual Report 2025	354


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

24 Property and equipment, leases, goodwill and other intangible assets



	Accounting policy for property and equipment
	Property and equipment are stated at cost less accumulated depreciation and any accumulated impairment amount. At each balance sheet date, an assessment is performed to determine whether there is any indication of impairment. Subsequent costs are capitalised if these result in an enhancement to the asset. Depreciation is charged to the income statement on a straight-line basis over the estimated useful lives of items of property and equipment, and of major components that are accounted for separately. ABN AMRO generally applies the following useful lives to calculate depreciation: • Land: not depreciated • Buildings: 30 years • Leasehold improvements: 5 years • Equipment: 5 years • Installations (durable): 10 years • Computer installations: 2 to 5 years Depreciation rates and residual values are reviewed at least periodically to take into account any change in circumstances. Capitalised leasehold improvements are depreciated in a manner that takes into account the term and renewal conditions of the related lease.

	Assets for which the bank acts as a lessor in an operational lease contract are included in property and equipment. The asset is depreciated on a straight-line basis, over its useful life, to its estimated residual value.

	Accounting policy for impairment of non-financial assets
	At each reporting date, ABN AMRO reviews the carrying amounts of its non-financial assets (i.e. ROU assets, equipment, goodwill and other intangible assets) to determine whether there is any indication of impairment. If any such indication exists, the asset’s recoverable amount is estimated. Goodwill is tested annually for impairment. For impairment testing, assets are grouped together into the smallest group of assets that generates cash inflows from continuing use that is largely independent of the cash inflows of other assets or cash-generating units. Goodwill arising from a business combination is allocated to cash-generating units or groups of cash‑generating units that are expected to benefit from the synergies of the combination. The recoverable amount of an asset or cash-generating unit is the greater of its value in use and its fair value less costs to sell. Value in use is based on the estimated future cash flows, discounted to their present value using a pre-tax discount rate that reflects current market assessments of the time value of money and the risks specific to the asset or cash-generating unit. An impairment loss is recognised if the carrying amount of an asset or cash-generating unit exceeds its recoverable amount. In general, ABN AMRO’s corporate assets do not generate separate cash inflows and are used by more than one cash-generating unit. Corporate assets are allocated to cash-generating units on a reasonable and consistent basis and tested for impairment as part of the testing of the cash-generating unit to which the corporate assets are allocated. Impairment losses are recognised in the income statement as a component of depreciation and amortisation expense. They are allocated first to reduce the carrying amount of any goodwill allocated to the cash-generating unit, and then to reduce the carrying amounts of the other assets in the cash-generating unit on a pro rata basis. An impairment loss in respect of goodwill is not reversed. For other assets, an impairment loss is reversed only to the extent that the asset’s carrying amount does not exceed the carrying amount that would have been determined, net of depreciation or amortisation, if no impairment loss had been recognised.


ABN AMRO	Annual Report 2025	355


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025



	Accounting policy for leases Lessor accounting Where ABN AMRO acts as lessor, a distinction is made between operating and finance leases. Leases where the bank transfers all risks and rewards incidental to ownership of the asset to the lessee are classified as finance leases. Leases that do not transfer these risks and rewards are classified as operating leases. Finance leases are recognised as a receivable in loans and advances at an amount equal to the net investment in the lease, less credit loss allowances. Assets subject to operating leases are recognised at cost in property and equipment. Operating income from finance leases is recognised in a pattern reflecting a constant periodic rate of return on the net investment in the lease.

	Lessee accounting
	All leases, except for low-value leases and leases with a duration of less than one year, are recognised on the balance sheet as a right of use (ROU) asset and lease liability. As a lessee, ABN AMRO enters into various lease contracts, mainly for office buildings and cars that the bank leases for its own use. When accounting for contracts as a lessee, ABN AMRO separates non-lease components from lease components. Payments such as variable lease payments that do not depend on an index or a rate and non-lease components are not included in the lease liability. The ROU asset is initially measured at cost, which reflects the initial lease liability, adjusted for upfront lease payments, received incentives and initial direct costs. The initial lease liability is equal to the sum of the fixed lease payments, discounted by the incremental borrowing rate. Given that ABN AMRO cannot readily determine the interest rate implicit in the lease, it uses the incremental borrowing rate to measure lease liabilities.

	The ROU asset is depreciated over the period of the lease, using the straight-line method.

	Adjustments to the ROU asset and corresponding lease liability result from remeasurement and/or modification. Remeasurement occurs when there is a change in the lease term or discount rate, a change in lease payments due to a change in an index or rate, or when ABN AMRO changes its assessment regarding purchase, extension or termination options. A lease modification is a change in the scope of the lease, or the consideration of a part of a lease that was not in the original terms and conditions of the lease. A lease modification results in either a separate additional lease or a change in the accounting for the existing lease. In the case of a lease modification not resulting in an additional lease, the lease liability is remeasured by adjusting the carrying amount of the ROU asset and, to reflect the partial or full termination of the lease, recognising any gain or loss in the statement of profit and loss. Expenses related to short-term leases with a term of less than 12 months and leases of low value are recognised in the income statement. ROU assets are included in property and equipment, while the lease liabilities are included in other liabilities. Depreciation of the ROU assets is included in depreciation, while amortisation of tangible and intangible assets is included in the income statement, and interest expense on lease liabilities is included in other interest and similar expense. Sale and leaseback transactions In a sale and leaseback transaction, the seller/lessee transfers an underlying asset to the buyer/lessor and leases that asset back from the buyer/lessor. Seller/lessee accounting If the bank is involved in a sale and leaseback transaction as a seller/lessee, the accounting policy described below is from the perspective of a seller/lessee. To determine how to account for a sale and leaseback transaction, the bank first considers whether the initial transfer of the underlying asset from the seller/lessee to the buyer/lessor is a sale in accordance with IFRS 15.


ABN AMRO	Annual Report 2025	356


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025



	If a sale and leaseback transaction constitutes a sale in accordance with IFRS 15, the underlying asset is derecognised and the lessee accounting model is applied to the leaseback. The ROU asset arising from the leaseback is measured based on the proportion of the previous carrying amount of the asset that relates to the rights of use retained by the seller/lessee. Accordingly, any gain or loss that relates to the rights transferred to the buyer/lessor is recognised. The proportion of the rights of use retained is the ratio between the present value of lease payments at market rates (excluding any future index changes) and the fair value of the consideration for the sale proceeds. The residual proportion is the proportion of the rights transferred. The fair value of the consideration for the sale proceeds is equal to the fair value of the underlying asset in the sale-and-leaseback transaction. If this does not equal the fair value of the underlying asset, or if the payments for the lease are not at market rates, the bank makes adjustments to recognise the sale proceeds at the fair value. Any below-market terms are recognised as a prepayment of lease payments and any above-market terms are recognised as additional financing provided by the buyer/lessor to the seller/lessee.

	Accounting policy for intangible assets
	Goodwill Goodwill is capitalised and stated at cost, being the excess of the consideration paid over the fair value of ABN AMRO’s share of the acquired entity’s net identifiable assets at the acquisition date, less any accumulated impairment losses. For the purpose of calculating goodwill, the fair values of acquired assets, liabilities and contingent liabilities are determined by reference to market values or by discounting expected future cash flows to present value. Goodwill is not amortised, but is reviewed annually for impairment, or more frequently if there are indications that impairment may have occurred. In the test, the carrying amount of goodwill is compared with the higher of the fair value less costs to sell and the value in use, being the present value of the cash flows discounted at a pre-tax discount rate that reflects the risk of the cash-generating unit to which the goodwill relates. Impairment losses are recognised in the income statement as depreciation and amortisation expense and are irreversible.

	Software and other intangible assets The accounting policy for software and other intangible assets is determined by IAS 38 Intangible assets. Software is amortised over a period of three years, unless it is classified as core application software, which is amortised over its estimated useful life, set at a maximum of seven years. For own-developed software, only the development phase is capitalised. Other intangible assets include separately identifiable items arising from acquisitions of subsidiaries, such as client relationships, and certain purchased trademarks and similar items. In general, the estimated useful life does not exceed ten years. Amortisation rates and residual values are reviewed at least annually to take into account any change in circumstances.


(in millions)	31 December 2025	31 December 2024
Land and buildings held for own use	581	379
Leasehold improvements	38	44
Plant & equipment under operating lease	232	306
Equipment	74	70
Right of use assets	288	260
Other	8	8
Total property and equipment	1,221	1,068

The right of use assets consist primarily of real estate.


ABN AMRO	Annual Report 2025	357


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


(in millions)	31 December 2025	31 December 2024
Goodwill	44	44
Purchased software	21	5
Internally developed software	267	188
Other	24	15
Total goodwill and other intangible assets	356	253


									2025
(in millions)	Land and buildings held for own use	Leasehold improve- ments	Plant & equipment under ope- rating lease	Equip- ment	Right of use assets	Other property and equipment	Total property and equipment	Good- will	Other intangible assets	Total goodwill and other intangible assets
Acquisition costs as at 1 January	941	209	570	607	565	11	2,902	150	623	773
Acquisitions/divestments of subsidiaries	24			13	80		117		36	36
Additions	195	9	64	25	37		331		5	5
Reversal of cost due to disposals	-5	-13	-222	-142	-15		-398		-28	-28
Foreign exchange differences		-1	-3	-4	-4		-12		-1	-1
Internally generated software									94	94
Other	6	-2			-17		-13		-6	-6
Acquisition costs as at 31 December	1,160	201	408	499	646	11	2,926	150	722	871

Accumulated depreciation/ amortisation as at 1 January	-557	-165	-263	-537	-297	-1	-1,819		-404	-404
Acquisitions/divestments of subsidiaries
Depreciation/amortisation	-15	-14		-33	-86		-149		-25	-25
Depreciation of assets subject to operating lease			-70				-70
Reversal of depreciation/amortisation due to disposals	2	13	155	142	11		323		22	22
Foreign exchange differences		1	2	3	2		9		1	1
Other	-6	2			17		12
Accumulated depreciation/ amortisation as at 31 December	-576	-164	-176	-425	-353	-1	-1,694		-406	-406

Accumulated impairments as at 1 January	-5		-1		-7	-2	-14	-105	-10	-116
Increase of impairments charged to the income statement							-1		-6	-6
Reversal of impairments due to disposals	2		1		1		4		6	6
Other									6	6
Accumulated impairments as at 31 December	-3				-6	-2	-11	-105	-4	-110

Total as at 31 December	581	38	232	74	288	8	1,221	44	311	356

The fair value of land and buildings held for own use is estimated at EUR 232 million as at 31 December 2025

(2024: EUR 198 million). Of this fair value 100% is based on external valuations performed in 2020 to 2025. There are

some properties that have a lower fair value than the recorded carrying value. No impairment is recorded because

these properties are considered corporate assets. The value in use for the cash generating units within

ABN AMRO Group is sufficient to cover the total value of all these assets.

The building at Foppingadreef in Amsterdam was transferred from ABN AMRO Bank N.V. to a subsidiary at a carrying

value of EUR 376 million. The building at Foppingadreef in Amsterdam is being reconstructed to serve as an example

with regard to sustainability and circularity. In 2023, ABN AMRO signed a construction contract with BAM for a total

value of EUR 431 million, subject to price indexation based on the BDB Index. In the second half of 2025, additional

design aspects were added to the original contract. In combination with the price indexation, the total contract value

amounts to EUR 527 million. As of 31 December 2025, EUR 351 million has been paid towards the construction

contract (2024: EUR 298 million), and a total of EUR 424 million has been capitalised as an asset under construction

(2024: EUR 238 million). The project is scheduled for completion in 2027.


ABN AMRO	Annual Report 2025	358


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


										2024
(in millions)	Land and buildings held for own use	Leasehold improve- ments	Plant & equipment under ope- rating lease	Equip- ment	Right of use assets	Other property and equipment	Total property and equipment	Good- will	Other intangible assets	Total goodwill and other intangible assets
Acquisition costs as at 1 January	777	208	649	626	584	11	2,853	115	517	632
Acquisitions/divestments of subsidiaries									33	33
Additions	174	13	97	28	53		365	44	4	48
Reversal of cost due to disposals	-12	-13	-182	-48	-58		-313	-10	-22	-31
Foreign exchange differences		1	6	1	3		10		1	1
Internally generated software									93	93
Other	2			-1	-17		-15		-4	-3
Acquisition costs as at 31 December	941	209	570	607	565	11	2,902	150	623	773

Accumulated depreciation/ amortisation as at 1 January	-547	-160	-308	-546	-256		-1,817		-408	-408
Acquisitions/divestments of subsidiaries									-7	-7
Depreciation/amortisation	-16	-14		-36	-81		-147		-13	-13
Depreciation of assets subject to operating lease			-86				-86
Reversal of depreciation/amortisation due to disposals	10	9	135	45	21		219		22	22
Foreign exchange differences		-1	-3	-1	-1		-6		-1	-1
Other	-4	1		1	20		18		3	3
Accumulated depreciation/ amortisation as at 31 December	-557	-165	-263	-537	-297	-1	-1,819		-404	-404

Accumulated impairments as at 1 January	-5	-4	-3	-2	-43	-2	-59	-115	-10	-125
Impairments on assets subject to operating lease			2				2
Reversal of impairments due to disposals	2	4		2	37		45	10		10
Foreign exchange differences					-1		-1
Other	-2						-2
Accumulated impairments as at 31 December	-5		-1		-7	-2	-14	-105	-10	-116

Total as at 31 December	379	44	306	70	260	8	1,068	44	209	253

Leases

ABN AMRO enters into leases both as lessor and lessee. In its capacity as lessee, ABN AMRO leases various assets

(mainly office properties, cars and equipment) that support the bank’s operations. These leases have various terms and

termination and renewal options. The majority of termination and renewal options are exercisable only by the bank

and not by the relevant lessor. There are no variable lease payments in lease contracts in which ABN AMRO acts as the

lessee. These lease contracts do not contain any covenants, and ABN AMRO is not allowed to use leased assets as

security for financing purposes. The total cash outflow relating to leases in 2025 amounted to EUR 121 million.

The following table shows the maturity of lease liabilities for leases in which the bank acts as lessee, as well as

the future undiscounted minimum lease receipts under operating and financial leases where the bank acts as lessor.

It also reconciles the total future minimum lease receipts under financial leases and the net investment in the leases.


						31 December 2025
(in millions)	Within 3 months	More than 3 months but within 1 year	More than 1 year but within 5 years	More than 5 years	Total	Unearned finance income	Net investment in the lease
Lease liabilities	26	81	166	249	522	n/a	n/a
Future minimum lease receipts under financial leases	362	488	1,084	119	2,053	-162	1,891
Future minimum lease receipts under operating leases	22	56	169	13	260	n/a	n/a


ABN AMRO	Annual Report 2025	359


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


						31 December 2024
(in millions)	Within 3 months	More than 3 months but within 1 year	More than 1 year but within 5 years	More than 5 years	Total	Unearned finance income	Net investment in the lease
Lease liabilities	24	65	158	201	447	n/a	n/a
Future minimum lease receipts under financial leases¹	298	663	1,485	221	2,668	-238	2,430
Future minimum lease receipts under operating leases	26	82	214	21	342	n/a	n/a
1. ABN AMRO performed a review on the classification of loan-to-book value facilities. This resulted in a reclassification from Financial lease receivables to Corporate loans for comparative purposes of EUR 1.4 billion for 2024.

The net investment in leases amounted to EUR 1,891 million (31 December 2024: EUR 2,430 million). The decline was

primarily attributable to the continued wind‑down of the foreign branches of ABF, including the sale of the UK lease

portfolio. No rights are retained in the underlying assets for financial leases, and the sale of the UK lease portfolio

resulted in a loss.

In its capacity as lessor, ABN AMRO leases out various assets. Operating leases in which the bank acts as the lessor are

included in Property and equipment – equipment. Financial leases in which the bank acts as the lessor are included

in corporate loans under loans and advances customers. Income from leases in which ABN AMRO acts as the lessor is

presented in the following table.


(in millions)	2025	2024
Income from financial leases	109	180
Income from operating leases	87	101
Total income from leases	197	281

Income related to variable lease payments on financial leases amounted to EUR 0.2 million. There is no income

relating to variable lease payments on operating leases.

ABN AMRO also acts as an intermediate lessor in subleases, where it subleases right of use assets to a third party.

In 2025, the total income from subleasing right of use assets amounted to EUR 4 million.

Valuation of goodwill


						31 December 2025	31 December 2024
(in millions)	Segment	Method used for recoverable amount	Discount rate	Long- term growth rate	Impairment charges	Goodwill	Goodwill
Entity
Bux	Wealth Manage ment	Value in use	13.8%	2.0%		44	44
Total goodwill and impairment charges						44	44

ABN AMRO performed its annual impairment test in the last quarter of 2025. The factors considered by ABN AMRO

when reviewing for indicators of impairment include the relationship between its market capitalisation and its book

value. The outcome of the impairment test performed is that no impairment needs to be recognised.


ABN AMRO	Annual Report 2025	360


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


(in millions)	2025	2024
Depreciation on tangible assets
Land and buildings held for own use	15	16
Leasehold improvements	14	14
Equipment	33	36
Right of use assets	86	81
Amortisation on intangible assets
Purchased software	6	5
Internally developed software	15	6
Other intangible assets	4	2
Impairment losses on intangible assets
Internally developed software	1
Other intangible assets	5
Total depreciation, amortisation and impairment losses	180	160

25 Non-current assets and disposal groups held for sale



	Accounting policy for non-current assets and disposal groups held for sale Non-current assets and/or businesses are classified as held for sale if their carrying amount is to be recovered principally by selling them within 12 months, rather than through ongoing use. Assets held for sale (other than financial instruments) are not depreciated and are measured at the lower of their carrying amount and fair value, less costs to sell. Assets and liabilities of a business held for sale are presented separately in the consolidated statement of financial position.


(in millions)	31 December 2025	31 December 2024
Assets
Residential mortgages	1,153
Consumer loans	1,312
Corporate loans		1,329
Property and equipment		1
Assets of businesses held for sale	2,466	1,330
Liabilities
Tax liabilities	5
Other liabilities	15
Liabilities of businesses held for sale	20

The 2025 held-for-sale asset position of EUR 2.5 billion comprises EUR 1.3 billion of consumer loans relating to ALFAM

Holding N.V. and a mortgage portfolio of EUR 1.2 billion relating to ABN AMRO Hypotheken Group B.V. The 2025

held‑for‑sale liability position of EUR 20 million relates to Alfam. In 2024, the held-for-sale position included

EUR 1.3 billion of corporate loans, for which the transaction was closed in the first quarter of 2025. The corporate

loans were part of the Corporate Banking segment.

In the fourth quarter of 2025, ABN AMRO announced that its subsidiary Alfam will be sold to Rabobank. ABN AMRO

continues to offer consumer loans through a third-party agreement with Rabobank. The expected closing is in the third

quarter of 2026, subject to regulatory approval. ABN AMRO anticipates a loss on sale of approximately

EUR 118 million. Consistent with the measurement requirements of IFRS 5 Non-Current Assets Held for Sale and

Discontinued Operations, which excludes financial instruments from the measurement requirements of this standard,

the loss will be recognised at closing. Alfam is part of the Personal & Business Banking segment.

Additionally, in the fourth quarter of 2025, a mortgage portfolio of EUR 1.2 billion was recorded as held for sale.

This portfolio is listed for sale as an incidental disposal from the mortgage portfolio in line with our risk

management strategy. ABN AMRO expects the portfolio to be sold during 2026. Mortgages are part of the

Personal & Business Banking segment.


ABN AMRO	Annual Report 2025	361


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

26 Other assets


(in millions)	31 December 2025	31 December 2024
Accrued other income	536	503
Prepaid expenses	15	21
Unsettled securities transactions	1,262	1,893
Trade and other receivables	2,615	2,759
Other	564	342
Total other assets	4,993	5,518

Unsettled securities transactions are related to reversed repurchase and securities borrowing transactions that have

been delivered but not settled. Other includes Carbon Emission rights that qualify as inventory under IFRS. ABN AMRO

acquires these carbon emission rights with the intention of selling these rights in the future.

27 Due to banks



	Accounting policy for due to banks and due to customers Amounts due to banks and customers are held at amortised cost. That is, at fair value upon initial recognition, adjusted for repayment and amortisation of coupon, fees and expenses to represent the effective interest rate of the instrument.


(in millions)	31 December 2025	31 December 2024
Current accounts	1,369	1,522
Demand deposits	2	1
Time deposits	2,387	320
Cash collateral on securities lent	562	485
Total deposits	4,319	2,329
Other	1
Total due to banks	4,320	2,329


ABN AMRO	Annual Report 2025	362


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

28 Due to customers



	Accounting policy for due to customers The accounting policy for amounts due to customers is set out in Note 27 - Due to banks .


(in millions)	31 December 2025	31 December 2024
Current accounts	100,140	92,746
Demand deposits	132,299	108,008
Time deposits	45,601	53,533
Other	1,086	1,899
Total due to customers	279,126	256,186

29 Issued debt and subordinated liabilities



	Accounting policy for issued debt and subordinated liabilities Issued debt securities and subordinated liabilities are recorded at amortised cost using the effective interest rate method. Hybrid or structured financial liabilities are irrevocably designated upon initial recognition to be measured at fair value through profit or loss. The latter is applied when the instruments are held to reduce an accounting mismatch, are managed on the basis of their fair value or include terms that qualify as an embedded derivative that cannot be separated. ABN AMRO applies IAS 32 Financial Instruments: Presentation to determine whether funding is a financial liability or equity. Issued financial instruments or their components are classified as financial liabilities where the substance of the contractual arrangement results in ABN AMRO having a present obligation to deliver either cash or another financial asset or to satisfy the obligation other than by the exchange of a fixed number of equity shares. Issued liabilities qualify as subordinated debt if claims by the holders are subordinated to all other current and future liabilities of ABN AMRO and its subsidiaries. The valuation of liabilities measured at fair value includes the effect of changes in the bank’s own credit spreads. The change in fair value applies to those financial liabilities designated at fair value where own value credit risk would be considered by market participants. The cumulative amount of changes in fair value attributable to credit risk of issued debt is presented as liability own credit risk reserve in equity. Exchange-traded own debt measured at fair value through profit or loss is valued at market prices. Fair value changes are calculated based on a yield curve generated from observed external pricing for funding and quoted CDS spreads

The following table shows the types of debt certificates issued by ABN AMRO and the amounts outstanding at

31 December 2025. Movements in these debt instruments involve a continual process of redemption and issuance of

long-term and short‑term funding.

Issued debt


(in millions)	31 December 2025	31 December 2024
Bonds and notes issued	62,140	56,416
Certificates of deposit and commercial paper	11,773	17,922
Total at amortised cost	73,913	74,337
Designated at fair value through profit or loss	159	205
Total issued debt	74,072	74,542
- of which matures within one year	17,009	24,999


ABN AMRO	Annual Report 2025	363


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


	2025	2024
(in millions)	Carrying amount	Carrying amount
Balance as at 1 January	74,542	66,227
Cash flows
Issuance	49,649	42,885
Redemption	-48,161	-36,980
Non-cash changes
Foreign exchange differences	-1,863	909
Fair value changes own credit risk	1	-2
Fair value changes hedge accounting	-636	902
Other	540	601
Balance as at 31 December	74,072	74,542

The amounts of debt issued and redeemed during the period are shown in the Consolidated statement of cash flows.

Non-cash changes consist mainly of unrealised gains and losses and foreign exchange differences. Further details

of the funding programmes are provided in the Funding section of the Risk, funding & capital chapter.

Financial liabilities designated at fair value through profit or loss


(in millions)	31 December 2025	31 December 2024
Cumulative change in fair value of the structured notes attributable to changes in credit risk	2	1
Change during the year in fair value of the structured notes attributable to changes in credit risk	1	-2
Difference between amount contractually required to pay at maturity and the carrying amount	7	6

The change in fair value of the structured notes attributable to changes in credit risk is determined using the credit

spread implicit in the fair value of similar bonds traded in active markets and issued by ABN AMRO.

Subordinated liabilities

The following table shows the subordinated liabilities.


				31 December 2025		31 December 2024
(in millions)	ISIN/CUSIP	Maturity date	First possible call date	Nominal amount	Carrying amount	Nominal amount	Carrying amount
Tier 1¹
EUR 1,000 million 4.75% per annum	XS1693822634	Perpetual	September 2027	1,000	994	1,000	994
EUR 750 million 6.875% per annum	XS2774944008	Perpetual	September 2031	750	746	750	746
EUR 750 million 5.75% per annum	XS3004202811	Perpetual	September 2033	750	746
EUR 750 million 6.375% per annum	XS2893176862	Perpetual	September 2034	750	746	750	746
EUR 1,000 million 4.375% per annum	XS2131567138	Perpetual	September 2025			1,000	988
Total Tier 1 capital instruments				3,250	3,233	3,500	3,475

Tier 2
USD 1,000 million 4.8% per annum	US0008DAL47 / XS1392917784	April 2026		852	854	960	935
USD 300 million 5.6% per annum	XS1385037558	April 2031		256	238	288	256
SGD 750 million 5.5% per annum	XS2498035455	October 2032	July 2027	497	512	529	537
EUR 1,000 million 5.125% per annum	XS2558022591	February 2033	November 2027	1,000	1,051	1,000	1,056
USD 1,000 million 3.324% per annum	US00084DAV29 / XS2415308761	March 2037	December 2031	852	757	960	807
EUR 750 million 5.5% per annum	XS2637967139	September 2033	June 2028	750	764	750	782
EUR 750 million 4.375% per annum	XS2859413341	July 2036	July 2031	750	769	750	785
USD 1,500 million 4.75% per annum	US00080QAF28 / XS1264600310	July 2025				1,440	1,452
EUR various smaller instruments		2023 - 2025				3	4
Total Tier 2 capital instruments				4,956	4,946	6,681	6,613
- of which eligible for regulatory capital:
Basel IV / III, Tier 1 (fully-loaded)				3,250		3,500
Basel IV / III, Tier 2 (fully-loaded)				4,114		4,646
1. AT1 capital securities. For both AT1 instruments, the CET1 trigger levels are 7.0% for ABN AMRO Bank level, and 5.125% for ABN AMRO Bank solo level. The amount of available distributable items for ABN AMRO Bank N.V. as at 31 December 2025 totals EUR 23.0 billion (31 December 2024: EUR 21.7 billion).


ABN AMRO	Annual Report 2025	364


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


	2025	2024
(in millions)	Carrying amount	Carrying amount
Balance as at 1 January	6,613	5,572
Cash flows
Issuance	21	767
Redemption	-1,342	-21
Non-cash changes
Foreign exchange differences	-393	214
Fair value changes hedge accounting	72	60
Other	-25	20
Balance as at 31 December	4,946	6,613

30 Provisions



	Accounting policy for provisions A provision is recognised in the balance sheet when ABN AMRO has a legal or constructive obligation as a result of a past event, and it is more likely than not that an outflow of economic benefits will be required to settle the obligation, and a reliable estimate of the amount of the obligation can be made. If the effect of time value is material, provisions are determined by discounting the expected future cash flows at a pre-tax rate that reflects current market rates and, where appropriate, the risks specific to the liability. In cases where ABN AMRO expects disclosure of legal proceedings on a case-by-case basis to seriously prejudice its position, it only discloses the general nature of the dispute. A provision for restructuring is recognised when an obligation exists. An obligation exists when ABN AMRO has approved a detailed plan and has raised a valid expectation among those affected by the plan by starting to implement the plan or by announcing its main features. Future operating costs are not provided for. Provisions for insurance risks are determined by actuarial methods, which include the use of statistics, interest rate data and settlement cost expectations. Provisions are established for certain guarantee contracts for which ABN AMRO is liable to pay upon default of payment. Expected credit loss allowances of loan commitments and financial guarantees are recognised as provisions under IFRS 9.


(in millions)	31 December 2025	31 December 2024
Legal provisions	169	150
Credit commitments provisions	63	97
Restructuring provision	104	45
Provision for pension commitments	65	76
Other staff provision	191	181
Insurance fund liabilities	6	7
Other provisions	68	58
Total provisions	666	612

Restructuring

Restructuring provisions cover the costs of the restructuring plans for which implementation has been formally

announced.

Legal provisions

Variable interest rates for consumer loans

On 3 March 2021, the Kifid Appeals Committee confirmed a ruling of the Kifid Disputes Committee about the

recalculation of the variable interest charged to a specific client on a revolving credit. In short, Kifid ruled that

ABN AMRO should have followed the market rate while establishing the variable interest rate for certain revolving

consumer credits.


ABN AMRO	Annual Report 2025	365


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

In light of the Kifid ruling, ABN AMRO reached agreement with the Dutch Consumers' Association (Consumentenbond

Claimservice) on 5 September 2021 regarding a compensation scheme for affected clients. In Q3 of 2022, following

an August 2022 ruling of the Kifid Appeals Committee, ABN AMRO adjusted the compensation scheme to include

interest on interest. ABN AMRO has provisioned around EUR 505 million for the interest to be compensated and the

costs incurred in carrying out the scheme. The execution of the compensation scheme has been completed in 2025

and the handling of any other matters relating to consumer credits with a variable interest rate has been handed over

to the business as usual. Therefore, as at the end of Q4 2025, in total EUR 483 million of the provision has been used

and the remaining provision of EUR 22 million has been released.

It is unclear what the exact scope and application of the Kifid ruling is and whether the ruling will have a certain

knock-on effect on other (credit) products with variable interest rates, beyond the range of products covered by the

compensation scheme, such as credit products for micro and small enterprises. ABN AMRO cannot give a reliable

estimate of the (potentially substantial) financial risk of these contingent liabilities which have not been provided for.

Other provisions

Irrevocable payment commitment

The annual Single Resolution Fund (SRF) contribution is a levy introduced by the European Union in 2016. The Single

Resolution Board (SRB) allows institutions to use irrevocable payment commitments (IPCs) to pay part of their

contribution. ABN AMRO uses this option and has deducted the full amount of the IPCs from own funds for regulatory

purposes. In February 2024, the SRB confirmed that the SRF reached its target level. As such, no annual contribution

was collected in 2025. The cumulative amount of IPCs entered into is EUR 207 million, which is the maximum loss

when the SRB executes its call. Considering the time value of money and the attainment of the SRF target level, the

estimated value of the liability is deemed negligible. The IPCs are secured by collateral to ensure full and punctual

payment of the contribution when called by the SRB. As at 31 December 2025, ABN AMRO has transferred a

cumulative amount of EUR 207 million in collateral. The collateral is reported as an asset under ‘other loans and

advances customers’.


(in millions)	Legal provisions	Credit commitments	Restructuring provision	Provision for pension commitments	Other staff provision	Insurance fund liabilities	Other	Total
Provisions as at 1 January 2024	273	120	57	76	134	7	75	742
Increase of provisions	124	97	52		36		3	312
Reversal of unused provisions	-55	-75	-9			-6	-9	-153
Utilised during the year	-178		-48				-13	-239
Transfer between stages		2						2
Foreign exchange differences		8						8
Other	-14	-55	-8		11	5	2	-58
Provisions as at 31 December 2024	150	97	45	76	181	7	58	612
Acquisition and divestment of subsidiaries	11	1		49			3	64
Increase of provisions	59	10	104		43		20	236
Reversal of unused provisions	-23	-25	-4			-5	-6	-62
Utilised during the year	-18		-41		-40		-9	-108
Transfer between stages		1						1
Foreign exchange differences		-2						-3
Other	-9	-19		-60	6	5	1	-76
Provisions as at 31 December 2025	169	63	104	65	191	6	68	666


ABN AMRO	Annual Report 2025	366


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

31 Pension and other employee benefits



	Accounting policy for pension and other employee benefits ABN AMRO sponsors a number of pension schemes in the Netherlands and abroad. These schemes are mainly defined contribution plans. The majority of the beneficiaries of the plans are located in the Netherlands.
	Defined contribution plans For defined contribution plans, ABN AMRO pays annual contributions determined by a fixed method and has no legal or constructive obligation to pay any further contributions. Contributions are recognised directly in the income statement in the year to which they relate. Actuarial and investment risk are for the account of the participants in the plan.
	Defined benefit plans For defined benefit plans, the net obligation of each plan is the difference between the present value of the defined benefit obligations and the fair value of the plan’s assets. The actuarial assumptions used for calculating the present value of the defined benefit obligations include discount rates based on high-quality corporate bonds, the inflation rate, future salary increases, employee contributions, mortality assumptions and rates of employee turnover. The assumptions are based on available market data and management expectations at the end of the reporting period. Plan assets are measured at fair value at balance sheet date and are netted against the defined benefit obligations. Pension costs recognised in the income statement for defined benefit plans consist of: • service costs • net interest costs determined by multiplying the net defined benefit liability (asset) by the discount rate, both as at the start of the annual reporting period, taking into account any changes in the net defined benefit liability (asset) during the period as a result of contributions and benefit payments • curtailments or plan amendments Differences between pension costs and pension contributions payable are accounted for as provisions or prepayments. Remeasurement Remeasurements of the net defined benefit liability (asset) are actuarial gains and losses resulting from changes in actuarial assumptions and experience adjustments (i.e. unexpectedly high or low rates of employee turnover). They are recognised in other comprehensive income and are not recycled to profit or loss in later periods. The actual return on the pension plan’s assets is determined after deduction of the costs of managing the assets and any tax payable by the pension plan itself. Other employee benefits Some group companies provide post-retirement benefits to their retirees, such as long-term service benefits and discounts on banking products. Entitlement to these benefits is usually conditional on the employee remaining in service up to retirement age and the completion of a minimum service period. The expected costs of these benefits are accrued over the period of employment, using the same accounting methodology as that used for defined benefit pension plans. These obligations are calculated annually. Pension and other employee benefit plans in all countries comply with applicable local regulations concerning investments and minimum funding levels.


ABN AMRO	Annual Report 2025	367


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Pension and other employee benefits

Amounts recognised in the income statement for pensions and other employee benefits


			2025			2024
(in millions)	Defined post employment benefit	Other employee benefits	Total	Defined post employment benefit	Other employee benefits	Total
Current service cost	6	3	9	5	2	8
Interest cost	7	2	8	7	2	9
Interest income	-5		-5	-5		-5
Other		5	5	3	7	10
Total defined benefit expenses in actuarial report	8	9	17	10	11	21
Other expenses	-2	1	-2	-3		-3
Total defined benefit expenses	6	9	15	7	11	18
Defined contribution plans	328		328	366		366
Total pension expenses and other post retirement employee benefits	333	9	343	373	11	384

Pension expenses for defined contribution plans consist mainly of the cash contributions to the Dutch collective

defined contribution plan.

Dutch defined contribution plan

The Dutch defined contribution plan is a collective defined contribution plan, based on an average salary plan. The

target retirement age is set at 68 years. The contribution payable by pension fund participants is 5.5% (2024: 5.5%).

In 2025 ABN AMRO's contribution to the Dutch defined contribution plan amounted to EUR 287 million

(2024: EUR 336 million) and is included in the pension expenses.

Reconciliation to the statement of financial position and other comprehensive income


			2025			2024
(in millions)	Defined post employment benefit	Other employee benefits	Total	Defined post employment benefit	Other employee benefits	Total
Present value of defined benefit obligations - funded with plan assets	209	2	211	193	3	196
Less: Fair value of plan assets	178		178	155		155
	31	2	33	38	3	41
Present value of defined benefit obligations - unfunded	28	147	176	35	140	176
Net liabilities/(assets) balance sheet as at 31 December	60	149	209	73	143	216
- of which assets	5		5	3		3
- of which liabilities	65	149	214	76	143	219

Experience adjustments	6		6	-1
Remeasurements arising from changes in demographic assumptions DBO				1		1
Remeasurements arising from changes in financial assumptions DBO	3		4	-8		-9
Remeasurements arising from changes in financial assumptions plan assets	-4		-4	1		1
Remeasurements in other comprehensive income	5	1	5	-7		-7


ABN AMRO	Annual Report 2025	368


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Change in defined benefit obligation (DBO)


			2025			2024
(in millions)	Defined post employment benefit	Other employee benefits	Total	Defined post employment benefit	Other employee benefits	Total
Defined benefit obligation as at 1 January	228	143	371	228	134	362
Acquisition of subsidiaries	76		76
Current service cost	6	3	9	5	2	8
Interest cost	7	2	8	7	2	9
Past service cost				1		1
Curtailment	-51		-51
Benefits paid	-5		-5	-7		-7
Benefits paid in from employer	-15	-4	-19	-13	-3	-16
Remeasurements arising from changes in demographic assumptions				-1		-1
Experience adjustments	-6		-6	1
Remeasurements arising from changes in financial assumptions	-3		-4	8		9
Other		6	6	-2	9	7
Defined benefit obligation as at 31 December	237	149	386	228	143	371

As from 1 July 2025 ABN AMRO included the defined benefit plans of HAL. HAL has several defined benefit plans that

are funded or insured. Only employees of HAL are covered by this plan. In September 2025, HAL sold the defined

pension obligation related to inactive employees to an external party. This resulted in a decrease of the DBO of

EUR 51 million and a decrease of plan assets of EUR 6 million.

The net defined benefit liabilities/(assets) balance as at 31 December 2025 consisted of several defined benefit plans

outside of the Netherlands, pensioners with a profit share, and the indexation of benefits insured with an insurance

company.

Change in fair value of plan assets


			2025			2024
(in millions)	Defined post employment benefit	Other employee benefits	Total	Defined post employment benefit	Other employee benefits	Total
Fair value of plan assets as at 1 January	155		155	158		158
Acquisition of subsidiaries	32		32
Interest income	5		5	5		5
Return on plan assets excluding interest	-4		-4	1		1
Employer's contributions	6		6	5		5
Benefits paid	-5		-5	-7		-7
Curtailment	-6		-6
Other	-5		-5	-8		-8
Fair value of plan assets as at 31 December	178		178	155		155

Principal actuarial assumptions


	2025	2024
Discount rate	3.8%	3.2%
Indexation rate	2.1%	2.6%
Future salary increases¹	2.2%	2.2%
1. Salary increases in the Netherlands are not taken into consideration, because Dutch pension plan is defined contribution plan.

The above assumptions are weighted by defined benefit obligations. The discount rate consists of a risk-free rate and a

credit spread on AA-rated corporate bonds.


ABN AMRO	Annual Report 2025	369


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

32 Other liabilities


(in millions)	31 December 2025	31 December 2024
Accrued other expenses	889	1,010
Lease liabilities	405	382
Unsettled securities transactions	655	799
Sundry liabilities and other payables	1,968	2,056
Total other liabilities	3,918	4,247

33 Equity



	Share capital and other components of equity
	Ordinary shares As at 31 December 2025, all shares in the capital of ABN AMRO Bank N.V. were held by two foundations: NLFI and STAK AAB.

	Compound financial instruments Components of compound financial instruments (liability and equity parts) are classified in their respective areas of the statement of financial position.

	Currency translation reserve The currency translation reserve represents cumulative gains and losses on the translation of our net investment in foreign operations, net of the effect of hedging.

	Fair value reserve Under IFRS 9, the fair value reserve includes the gains and losses, net of tax, resulting from a change in the fair value of debt instruments measured at FVOCI. When the instruments are sold or otherwise disposed of, the related cumulative gain or loss recognised in equity is recycled to the income statement.

	Cash flow hedging reserve The cash flow hedging reserve comprises the effective portion of the cumulative net change in the fair value of cash flow hedging instruments, net of taxes, that are recycled to the income statement if the hedged transactions have an impact on profit or loss.

	Liability own credit risk reserve Under IFRS 9, the changes in fair value attributable to changes in the own credit risk of financial liabilities designated at FVTPL are presented in other comprehensive income. The cumulative amount of changes in fair value attributable to credit risk of such liabilities is presented as liability own credit risk reserve in equity.

	Other reserves Other reserves mainly comprise retained earnings and profit for the period.

	Dividends Dividends on ordinary shares classified as equity are recognised as a distribution of equity in the period in which they are approved by shareholders.

	Capital securities Undated, deeply subordinated, resettable, callable capital securities are classified as additional tier 1 (AT1) capital, under total equity. ABN AMRO Bank has the European Central Bank’s permission to carry out limited repurchases from investors and to sell back in the market.


ABN AMRO	Annual Report 2025	370


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


(in millions)	31 December 2025	31 December 2024
Share capital	823	833
Share premium	11,745	11,849
Accumulated other comprehensive income	80	-409
Other reserves (incl. retained earnings/profit for the period)	11,159	10,358
AT1 capital securities	3,233	3,475
Equity attributable to owners of the parent company	27,040	26,105
Equity attributable to non-controlling interests	3	3
Total equity	27,043	26,108

As at 31 December 2025 , the authorised share capital of ABN AMRO Bank N.V. amounted to 2,400,000,000 shares.

The authorised share capital consisted of 2,200,000,000 ordinary A-shares with a nominal value of EUR 1.00 each

and 200,000,000 ordinary B-shares with a nominal value of EUR 1.00 each. Every share is entitled to one vote at

the General Meeting. During the financial year, there were no changes in the authorised share capital. The total

number of issued shares as at 31 December 2025 was 823,201,264. In 2025, a final dividend for the year 2024 of

EUR 0.75 per share, amounting to EUR 625 million, and an interim dividend for 2025 of EUR 0.54 per share,

amounting to EUR 449 million, were paid. For the year 2025, a final dividend of EUR 0.70 per share has been

proposed.

During the second half of 2025, ABN AMRO Bank N.V. purchased treasury shares under the buyback programme

for EUR 250 million, at an average price of EUR 25,39 per share. These treasury shares were cancelled during Q4,

resulting in a reduction in the issued share capital of 9,847,302 shares, with a nominal value of EUR 1.00 each. The

amount of the purchase value between EUR 1.00 (the nominal value of the purchased shares) and EUR 11.55 (the

value of the purchased shares for tax purposes) has been deducted from the share premium reserve. The amount of

the purchase value in excess of EUR 11.55 has been deducted from other reserves.

Securities classified as Additional Tier 1 (AT1) capital are perpetual, junior, resettable securities that are callable and

are considered part of equity. AT1 Capital Security (XS3004202811) with a notional amount of EUR 750 million was

issued on 26 February 2025 at the fixed rate of 5.750% per annum. The amount raised was EUR 746 million after

deduction of discount. AT1 Capital Instrument (XS2131567138) with a notional of EUR 1.0 billion was called on

22 September 2025. In addition, the payment of interest on the AT1 Capital securities had an impact on equity of

EUR 217 million.

The following table shows the equity of the ABN AMRO Bank N.V. and the outstanding and issued share capital.


		31 December 2025		31 December 2024
	Class A ordinary shares	Class B ordinary shares	Class A ordinary shares	Class B ordinary shares
Number of shares
Authorised share capital	2,200,000,000	200,000,000	2,200,000,000	200,000,000
Unissued share capital	1,376,798,736	200,000,000	1,366,951,434	200,000,000
Issued share capital	823,201,264		833,048,566
Amount of shares (in EUR)
Authorised share capital	2,200,000,000	200,000,000	2,200,000,000	200,000,000
Unissued share capital	1,376,798,736	200,000,000	1,366,951,434	200,000,000
Issued share capital	823,201,264		833,048,566
Par value	1.00	1.00	1.00	1.00


ABN AMRO	Annual Report 2025	371


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Accumulated other comprehensive income is specified in the following table.


(in millions)	Remeasurements on post- retirement benefit plans	Currency translation reserve	Fair value reserve	Cash flow hedge reserve	Accumulated share of OCI of associates and joint ventures	Liability own credit risk reserve	Total
Balance as at 1 January 2024		37	-104	-250	3	-2	-315
Net gains/(losses) arising during the period	-7	61	-521	129	-3	2	-340
Less: Net realised gains/(losses) included in income statement				-194			-194
Net gains/(losses) in equity	-7	61	-521	323	-3	2	-145
Related income tax	-1		-134	83			-51
Balance as at 31 December 2024	-5	99	-492	-10			-409
Net gains/(losses) arising during the period	5	-185	610	92		-1	520
Less: Net realised gains/(losses) included in income statement				-204			-204
Net gains/(losses) in equity	5	-185	610	295		-1	724
Related income tax	1		158	76			235
Balance as at 31 December 2025	-1	-87	-40	209		-1	80

Accumulated other comprehensive income increased by EUR 489 million, mainly driven by the increase in the fair

value reserve. This was attributable to the higher valuation of financial investments. The increase of the cash flow

hedge reserve was a result of changes in market value of active swaps and amortisations of discontinued swaps.

34 Transferred, pledged, encumbered and restricted assets



	Accounting policy for transferred, pledged and encumbered assets Transferred financial assets are arrangements/transactions for which ABN AMRO has: • transferred the contractual rights to receive the cash flows of the financial asset to a third party, or • retained the contractual rights to receive the cash flows of that financial asset, but has assumed a contractual obligation to pay the cash flows to a third party Depending on the circumstances, these transfers may either result in financial assets that are not derecognised in their entirety or in assets that are derecognised in their entirety. More detailed information on our recognition and derecognition policy is provided in the paragraph on material accounting policies under Note 1 - Accounting policies. Pledged assets are assets given as security (collateral) to guarantee the payment of a debt or fulfilment of an obligation by ABN AMRO to a third party. Encumbered assets are assets that have been pledged or are subject to any form of arrangement to secure, collateralise or credit enhance any transaction from which free withdrawal is not allowed. The key difference between encumbered and pledged assets is that the latter is based on the legal terms such as title transfer while the former is based on economic principles.

Transferred financial assets

This disclosure provides insight into the relationship between these transferred financial assets and associated

financial liabilities in order to show the risks the bank is exposed to when the assets are transferred. If transferred

financial assets continue to be recognised in the balance sheet, ABN AMRO is still exposed to changes in the fair value

of these assets.


ABN AMRO	Annual Report 2025	372


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

Transferred financial assets not derecognised in their entirety

The following table shows transferred financial assets that have not been derecognised in their entirety.


		31 December 2025			31 December 2024
(in millions)	Financial investments (at fair value through OCI)	Financial assets held for trading (at fair value through profit and loss)	Total	Financial investments (at fair value through OCI)	Financial assets held for trading (at fair value through profit and loss)	Total
Securities financing
Carrying amount Transferred assets	12,306		12,306	12,748	1	12,748
Carrying amount Associated liabilities	1,097		1,097	873	1	874
Fair value of assets	12,306		12,306	12,748	1	12,748
Fair value of associated liabilities	1,097		1,097	873	1	874
Net position	11,209		11,209	11,875		11,875

Securitisations

The bank uses securitisations as a source of funding, whereby the special purpose entity (SPE) issues debt securities.

In a securitisation transaction utilising true sale mechanics, the bank transfers the title of the assets to SPEs. When the

cash flows are transferred to investors in the notes issued by consolidated securitisation vehicles, the assets (mainly

residential mortgage loans) are considered to be transferred. The bank does not have any transferred and associated

securitisations at 31 December 2025.

Securities financing

Securities financing transactions are entered into on a collateralised basis to mitigate the bank’s credit risk exposure.

In repurchase agreements and securities lending transactions, the securities are returned to ABN AMRO at maturity.

The counterparty in the transactions holds the securities as collateral, but has no recourse to other assets of ABN AMRO.

Continuing involvement in transferred financial assets derecognised in their entirety

The bank does not have any material transferred assets that are derecognised in their entirety while ABN AMRO has

continuing involvement.

Pledged and encumbered assets

Pledged and encumbered assets are no longer readily available to ABN AMRO to secure funding, satisfy collateral

needs or be sold to reduce the funding requirement. The following activities conducted by ABN AMRO give rise

to pledged assets:

• cash and securities provided as collateral to secure trading and other liabilities, mainly derivatives

• mortgages and SME loans pledged to secure funding transactions such as covered bonds and securitisations

• securities lent as part of repurchase and securities lending transactions

The following differences apply to ABN AMRO:

• Encumbered assets exclude retained mortgage-backed securities, unless these have been pledged or are subject

to any form of arrangement to secure, collateralise or credit enhance any transaction from which free withdrawal is

not allowed

Significant restrictions on assets may arise from statutory, contractual or regulatory requirements such as:

• requirements that restrict the ability of the parent or its subsidiaries to transfer cash or other financial assets to or

from other entities within the group

• guarantees or other requirements that may restrict dividends and other capital distributions being paid, or loans and

advances being made or repaid to other entities within the group

• protective rights of other non-controlling interests that may restrict the ability of the bank to access and transfer

assets freely to or from other entities within the group and to settle liabilities of the bank


ABN AMRO	Annual Report 2025	373


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

The following table provides an overview of assets pledged as security and encumbered assets.


(in millions)	31 December 2025	31 December 2024
Assets pledged
Financial assets held for trading	55	267
Financial investments FVOCI	3,360	3,180
Loans and advances banks
- Interest bearing deposits	611	669
Loans and advances customers¹
- Residential mortgages	86,635	82,698
- Commercial loans	6,032	6,632
Total assets pledged as security	96,694	93,445
Differences between pledged and encumbered assets
Loans and advances customers	-40,147	-38,568
Total differences between pledged and encumbered assets	-40,147	-38,568
Total encumbered assets	56,546	54,877
Total assets	413,210	385,047
Total encumbered assets as percentage of total assets	13.7%	14.3%
1. Excluding mainly mortgage-backed securities.

Off-balance sheet collateral held as security for assets

Mainly as part of professional securities transactions, ABN AMRO obtains securities on terms which permit it to

repledge or resell the securities to others. These transactions are conducted under terms that are usual and customary

in standard professional securities transactions.

ABN AMRO controls the credit risk associated with these activities by monitoring counterparty credit exposure and

collateral value on a daily basis and, when necessary, requiring additional collateral to be deposited with or returned

to the group.


(in millions)	31 December 2025	31 December 2024
Fair value of securities received which can be sold or repledged	71,967	72,196
- of which: fair value of securities repledged/sold to others	44,342	46,541

ABN AMRO has the obligation to return securities accepted as collateral to its counterparties.

Significant restrictions on the ability to access or use the bank’s assets

Restricted financial assets consist of assets pledged as collateral against an existing or contingent liability and

encumbered assets. Other restrictions impacting on the bank’s ability to use assets include:

• assets as a result of collateralising repurchase and borrowing agreements (31 December 2025: EUR 40.2 billion;

31 December 2024: EUR 27.0 billion)

• assets held in certain jurisdictions to comply with local liquidity requirements and that are subject to restrictions in

terms of their transferability within the group (31 December 2025: EUR 0.3 billion; 31 December 2024:

EUR 0.4 billion)

• ABN AMRO is in general not subject to any significant restrictions that would prevent the transfer of dividends and

capital within the group, except for regulated subsidiaries that are required to maintain capital in order to comply

with local regulations (31 December 2025: EUR 0.1 billion; 31 December 2024: EUR 0.5 billion).


ABN AMRO	Annual Report 2025	374


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

35 Commitments and contingent liabilities



	Accounting policy for off-balance sheet items
	Commitments Loan commitments that allow for draw-down of a loan within the timeframe generally established by regulation or convention in the marketplace are not recognised as derivative financial instruments. Acceptances comprise undertakings by ABN AMRO to pay bills of exchange drawn on clients. ABN AMRO expects most acceptances to be settled simultaneously with the reimbursement from clients. Acceptances are not recognised in the balance sheet and are disclosed as commitments.

	Financial guarantee contracts A financial guarantee contract requires the issuer to make specified payments to reimburse the holder for a loss it incurs if a specified debtor fails to make payment when due under the original or modified terms of a debt instrument. Initial recognition of financial guarantee contracts is at their fair value. Subsequent measurement is at the higher of the amount of the expected credit loss and the amount initially recognised, less – when appropriate – the cumulative amount of income recognised in the income statement.

	Contingent liabilities Contingent liabilities are possible obligations whose existence will be confirmed only by uncertain future events, and present obligations where the transfer of economic resources is uncertain or cannot be reliably measured. Contingent liabilities are not recognised in the balance sheet, but disclosed if the likelihood of an outflow of economic resources is not more likely than not, or if the likelihood of an outflow of economic resources is more likely than not, but cannot be reliably estimated.

Committed credit facilities

Commitments to provide credit consist of approved but undrawn loans, revolving and underwriting facilities. New loan

offers have a commitment period that does not extend beyond the normal underwriting and settlement period.

Guarantees and other commitments

ABN AMRO provides financial guarantees and letters of credit to guarantee the performance of its clients to third

parties. These transactions have fixed limits and generally extend for periods of up to 5 years. Expirations are not

concentrated in any particular period. ABN AMRO also provides guarantees by acting as a settlement agent

in securities borrowing and lending transactions.

Many of the contingent liabilities and commitments are expected to expire without being paid out in whole or in part.

This means that the amounts stated do not represent expected future cash flows. Additionally, guarantees and letters

of credit are supported by varying levels of collateral. Furthermore, statements of liability within the meaning of article

403, Book 2 of the Dutch Civil Code have been issued for a number of ABN AMRO’s affiliated companies (see also

the chapter Other information).

The committed credit facilities, guarantees and other commitments are summarised in the following table.

The amounts stated in the table for commitments assume that amounts are fully paid out. The amounts shown

in the table for guarantees and letters of credit represent the maximum amount ABN AMRO is exposed to if

the contract parties completely fail to perform as contracted.


ABN AMRO	Annual Report 2025	375


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025


				31 December 2025
(in millions)	Less than one year	Between one and three years	Between three and five years	After five years	Total
Committed credit facilities	29,714	7,842	13,832	3,852	55,240
Guarantees and other commitments
Guarantees granted	187	248	223	45	703
Irrevocable letters of credit	2,632	689	370	104	3,796
Recourse risks arising from discounted bills	1,085	815	198	12	2,110
Total guarantees and other commitments	3,904	1,752	791	161	6,609
Total	33,618	9,594	14,623	4,014	61,849


				31 December 2024
(in millions)	Less than one year	Between one and three years	Between three and five years	After five years	Total
Committed credit facilities	27,869	8,408	12,411	3,928	52,617
Guarantees and other commitments
Guarantees granted	225	267	84	203	779
Irrevocable letters of credit	2,507	1,004	183	226	3,920
Recourse risks arising from discounted bills	1,421	290	209	19	1,939
Total guarantees and other commitments	4,154	1,561	476	448	6,638
Total	32,023	9,969	12,887	4,376	59,255

Contingent liabilities

ABN AMRO is involved in a number of legal proceedings in the ordinary course of business in various jurisdictions.

In presenting the Consolidated Annual Financial Statements, management estimates the outcome of legal, regulatory

and arbitration matters, and takes provisions to the income statement when losses with respect to such matters are

more likely than not. Provisions are not recognised for matters for which an expected cash outflow cannot be

reasonably estimated or that are not more likely than not to lead to a cash outflow. Some of these matters may be

regarded as a contingency.

Proceedings against regulator on regulatory levies

ABN AMRO is in discussion with the Single Resolution Board (SRB) about the calculation method applied for annual

Single Resolution Fund (SRF) contributions paid in the past. At this time, the outcome of these discussions are still

uncertain. The annual SRF contribution is a levy introduced by the European Union in 2016. The SRB calculates the SRF

contribution based on the information annually provided by the credit institutions within the European Banking Union

in scope of SRF. The SRB is of the opinion that ABN AMRO has reported variables to calculate the annual SRF

contribution incorrectly over the 2016-2022 period. ABN AMRO disagrees with the SRB’s point of view and, as

from 2016, has repeatedly and extensively communicated its position with regard to the adjusted amount to the SRB.

The different points of view held by the SRB and ABN AMRO are due to a differing interpretation of the regulation with

regard to the annual SRF contribution.

ABN AMRO received on 11 May 2023 the final decision from the SRB regarding the ex-ante contributions to the SRF.

In its final decision, SRB reiterates its arguments and doesn’t agree with ABN AMRO’s position. The SRB recalculated

the contribution of ABN AMRO Hypotheken Groep B.V. (AAHG) over the years 2016 - 2022. Therefore the total amount

of the invoice for the year 2023 is EUR 177 million. This amount consists of both the contribution for the year 2023

(approximately EUR 57 million) and the amount AAHG has to pay extra in contribution for the years 2016 – 2022

(approximately EUR 120 million, included as an ‘other asset’). Upon DNB’s and SRB’s explicit request and in order to

comply with the Dutch legislation, which requires the SRF contribution 2023 to be paid within six weeks after the

notification of the final decision (under penalty of fines), AAHG paid on 22 June 2023, under protest, the SRF

contribution 2023 to the SRB.

AAHG and ABN AMRO challenged the SRB’s final decision by filing a petition with the court of Justice of the European

Union on 14 July 2023. On 19 November 2025 the hearing took place at the European Court of Justice in

Luxembourg. Parties now have to await the court’s judgment.


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The outcome of this challenge is uncertain, because the SRF regulation is relatively new and there is little to no case

law on the subject. ABN AMRO nevertheless considers it more likely than not that such challenge will be successful.

The current status is that the court will now decide if and when a hearing will take place.

Equity trading in Germany

German authorities are conducting investigations into the involvement of individuals from various banks and other

parties in equity trading extending over dividend record dates in Germany, including several forms of tainted dividend

arbitrage (i.e. tainted dividend stripping, including cum/ex and cum/cum) for the purpose of obtaining German tax

credits or refunds in relation to withholding tax levied on dividend payments, including, in particular, transaction

structures that resulted in more than one market participant claiming such credit or refund with respect to the same

dividend payment. ABN AMRO’s legal predecessor, Fortis Bank (Nederland) N.V., ABN AMRO and several former

subsidiaries were directly or indirectly involved in these transactions in the past in various capacities. Criminal

investigation proceedings relating to the activities of these entities and individuals involved at the time were instigated.

These proceedings also resulted in search warrants being issued against ABN AMRO. ABN AMRO is cooperating with

these investigations, but has no knowledge of the results of any such investigations other than through public sources.

ABN AMRO also frequently receives information requests from German authorities in relation to criminal and other

investigations of individuals from other banks and other parties relating to equity trading extending over dividend

record dates in Germany. ABN AMRO cooperates and provides the requested information to the extent possible.

Although a number of subsidiaries associated with these transactions have been sold by means of a management

buy-out, legal risks remain for ABN AMRO, in particular relating to administrative offences and criminal and civil law.

All material tax issues with respect to ABN AMRO’s tax reclaims relating to cum/ex transactions have been settled with

the German tax authorities.

With respect to cum/cum transactions, the German Federal Ministry of Finance released two circular rulings dated

9 July 2021 (published 15 July 2021); these contain a change in interpretation of tax legislation compared to previous

circular rulings. While these circular rulings, in ABN AMRO’s view, contradict case law of the German Federal Tax Court

after the circulars were published, the German Federal Ministry of Finance has not withdrawn or amended the rulings,

and the German local tax authorities are therefore expected to recollect dividend withholding tax credited to

taxpayers where such credits related to cum/cum strategies. ABN AMRO has received dividend withholding tax

refunds that relate to transactions that could be considered to be cum/cum transactions under the new circular

rulings. In anticipation of a decision by the German tax authorities, ABN AMRO has, as a precaution, repaid the relevant

dividend withholding tax amounts, while retaining its rights to contest any such future decision. Some counterparties

of ABN AMRO have initiated civil law claims against ABN AMRO with respect to cum/cum securities lending

transactions (one pending before a German court, two cases ruled in favor of ABN AMRO), arguing that ABN AMRO

failed to deliver beneficial ownership of the loaned securities to these counterparties and that this resulted in a denial

of tax credit entitlement by the relevant German tax authorities. Although ABN AMRO considers it not probable that

any such claims will be successful, the possibility that they will succeed cannot be ruled out.

It cannot be excluded that ABN AMRO or subsidiaries will face financial consequences as a result of their involvement

in tainted dividend arbitrage transactions, in particular corporate administrative fines, forfeiture orders and civil law

claims. It is currently unclear, however, as to how and when the German prosecution authorities’ investigations will

impact ABN AMRO and its subsidiaries and if, and to what extent, corporate administrative fines or forfeiture orders

will be imposed. It is also uncertain whether tax authorities or third parties will successfully claim amounts from ABN

AMRO in secondary tax liability or civil law cases. Only for known individual claims a provision has been recognised as

far as it was deemed more likely than not, that an outflow of economic benefit will be required to settle the obligation

(see also Note 30 - Provisions). Because of the sensitivity of the underlying information, individual claims are not

disclosed in detail. The financial impact of potential other claims cannot be reliably estimated, and no provision has

been recorded in this respect.

Matters related to duty of care and the EU directive on unfair terms in commercial contracts

There are a number of threatened or pending claims and proceedings against ABN AMRO for alleged breaches of its

duty of care and/or the EU Directive on Unfair Terms in Commercial Contracts. Where applicable, provisions for these

matters have been made.


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There can be no assurance that additional proceedings will not be instigated or that amounts demanded in claims

brought to date will not rise. Current claims and proceedings are pending and their outcome, as well as the outcome

of any potential proceedings, is uncertain, as is the timing of reaching any finality on these legal claims and

proceedings. Because of the sensitivity of the underlying information, individual claims are not disclosed in detail.

Although the consequences could be substantial for ABN AMRO and potentially affect its reputation, results of

operations, financial condition and prospects, it is not possible to reliably estimate or quantify ABN AMRO’s exposure

at this time. These uncertainties are likely to continue for some time.

Luxembourg subsidiaries

In February 2018, ABN AMRO sold its Luxembourg subsidiary to BGL BNP Paribas (BGL). BGL is now being sued by a

Luxembourg investment fund (the Fund) which alleges that the Luxembourg subsidiary, in its capacity as custodian of

a sub-fund of the Fund, should have prevented an investment of USD 10 million from being made. The Fund is

claiming restitution of this amount from BGL in proceedings before the District Court of Luxembourg. BGL notified ABN

AMRO of this claim in January 2020 and, in June 2020, summoned it to appear in these proceedings in an intervention

procedure. In July 2020, the Fund and its Hong Kong subsidiary issued an additional claim against BGL. This claim

amounts to USD 20 million and also seems to relate to investments relating to the sub-fund of the Fund. Since

August 2020, this additional claim has also been part of the intervention procedure between BGL and ABN AMRO.

These proceedings are pending.

In addition, on 2 April 2021, BGL, as the legal successor of the Luxembourg subsidiary of ABN AMRO, was sued by a

Luxembourg investment fund (SIF A) and the liquidator of SIF A. In brief, it is alleged that a sub-fund of SIF A invested

in allegedly fictitious loan instruments for a period of time. The Luxembourg subsidiary acted as the custodian bank for

SIF A for a while within this time period. SIF A alleges that it did not perform its duties properly and therefore considers

that BGL, as the legal successor of the Luxembourg subsidiary, should be held liable, together with three other

defendants, for approx. EUR 4 million in damages. BGL notified ABN AMRO of this claim in May 2021. In brief, BGL is

claiming that any sentence that could be pronounced against it in the proceedings against the fund and its liquidator

should be borne by ABN AMRO. ABN AMRO rejects the alleged claim from BGL.

Finally, on 31 May 2021, BGL, as the legal successor of the Luxembourg subsidiary of ABN AMRO, was sued by an

alternative investment fund (AIF SIF). AIF SIF was originally a client of the subsidiary. AIF SIF accuses BGL, in its capacity

as the former depositary bank of AIF SIF, of having caused AIF SIF’s removal from the list of specialised investment

funds by the Luxembourg financial regulator (CSSF). The fund claimed damages from BGL in the amount of

EUR 126 million. BGL notified ABN AMRO of this claim in July 2021. In May 2025, BGL informed ABN AMRO that the

trustee of AIF SIF shifted the position adopted initially by the fund. The trustee now argues that the Luxembourg

subsidiary and BGL, committed several breaches of their legal obligations as depositary banks of the fund which

allegedly led to loss of assets of damages for the fund amounting to approximately EUR 145 million. In brief, BGL is

claiming that any sentence that could be pronounced against it in the proceedings against the trustee of the fund

should be borne by ABN AMRO. ABN AMRO rejects the alleged claim from BGL.

On 30 June 2023 BGL served a writ of summons against ABN AMRO in which BGL holds ABN AMRO primarily liable

for fraudulent concealment and misrepresentation and seeks compensation for its damages. ABN AMRO rejects the

alleged claim by BGL. The writ has not (yet) been served before the court in order to give parties a chance to discuss a

potential settlement.

Collective action regarding business credits with variable interest rate

ABN AMRO received a claim from the claim foundation Stichting Massaschade & Consument, alleging that ABN AMRO

charged too much interest on certain revolving business credits with a variable interest rate, which had been sold to

small and micro enterprises. The claim foundation argues that earlier Kifid rulings on revolving consumer credits with a

variable interest rate, in which Kifid ruled that the contractual interest rate must follow the movements of the average

market rate, should also apply to these business credits.

On 14 May 2024, ABN AMRO received a writ of summons to commence a collective action. ABN AMRO refutes the

allegations of the claim foundation, inter alia, because, according to ABN AMRO, the Kifid rulings on revolving

consumer credits with a variable interest rate cannot be applied to business credits and, thus far, the Kifid-approach

has not been adopted by the Dutch civil courts. A provision has not been recognised for this matter. The writ of


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summons does not specify exactly to which products the claim applies or a substantiation of the amount of damages

claimed. As a result, it is currently not possible to make a reliable estimate of the financial effects of this claim.

ABN AMRO put up a defence in court. It is expected that the collective action will take several years to complete. On

9 July 2025 the court has ruled that the foundation is inadmissible in its claims because the claims are not suitable for

collective treatment. The foundation lodged an appeal.

Investor claims regarding AML disclosures

ABN AMRO received claims from two groups of institutional investors for alleged losses as a result of developments in

ABN AMRO’s share price following disclosures made in the period from 2015 to 2022 in relation to (non-)compliance

by ABN AMRO with anti-money laundering laws and regulations, the related investigation of the Dutch Public

Prosecutor’s Office which resulted in a settlement, and associated risks. The groups of investors hold liable ABN AMRO

and certain former and current executive and supervisory board members for alleged damages of in total

approximately EUR 400 million. ABN AMRO disputes these allegations and has not recognised a provision for this

matter. No proceedings on the merits have been initiated yet by both groups of investors. One group of investors has

filed a request for the disclosure of certain documents and preliminary witness hearings of certain former board

members and employees of ABN AMRO. The district court recently denied this requests in full. An appeal against this

ruling is pending, provided that the request for preliminary witness hearing has been dropped.

DNB imposes fine on ABN AMRO for violation prohibition

On 10 June 2025, the Dutch Central Bank (DNB) imposed an administrative fine of EUR 15 million on ABN AMRO for

violating the bonus prohibition over the period from 2016 to 2024. Despite ABN AMRO’s good-faith interpretation and

application of the law, the bank admits its understanding was erroneous. ABN AMRO has decided to accept the

penalty without further challenging it and paid the related amount. There are still some other discussions with the

regulator on violation of remuneration restrictions.

Cross-liability

On 6 February 2010, the former ABN AMRO Bank N.V. demerged into two entities: NatWest Markets N.V. (formerly

known as RBS N.V.) and ABN AMRO Bank N.V. On the division of an entity by demerger, Dutch law establishes a cross-

liability between surviving entities for the benefit of the creditors at the time of the demerger. ABN AMRO’s cross-

liability amounts to EUR 197 million (31 December 2024: EUR 198 million).

Madoff related proceedings

ABN AMRO, certain of its subsidiaries and some of their client funds had exposure to funds that suffered losses (in

some cases, significant losses) as a result of the Madoff fraud. The provision of custodial and other financial services

resulted in several legal claims, including by the Bernard L. Madoff Investment Securities LLC (BLMIS) trustee in

bankruptcy (Irving Picard) and the liquidators of certain funds, who are pursuing legal action in an attempt to recover

payments made as a result of the fraud and/or to compensate their alleged losses. ABN AMRO and certain ABN AMRO

subsidiaries are defendants in these proceedings. There are three main claims remaining in relation to which

proceedings against ABN AMRO and its subsidiaries are pending before the US courts:

(i) claims of in total approximately USD 105 million against ABN AMRO Isle of Man (Nominees) Ltd Initiated by the

trustee of BLMIS;

(ii) claims of in total approximately USD 265 million against ABN AMRO Retained Custodial Services (Ireland) Ltd and

ABN AMRO Custodial Services (Ireland) Ltd initiated by the trustee of BLMIS; and

(iii) claims of in total approximately USD 235 million against ABN AMRO Isle of Man (Nominees) Ltd, ABN AMRO Global

Custody Services N.V., ABN AMRO Bank N.V. and ABN AMRO Cayman Bank Ltd initiated by the liquidators of

certain funds which invested in BLMIS.

Even though these proceedings have been ongoing for several years, the claims brought by the trustee of BLIMS are

still in their early stages and are expected to take several years to complete. The claims brought by the funds’

liquidators have been dismissed on appeal, but the funds’ liquidators may still request the US Supreme Court to review

the case. Certain of these claims initially were (significantly) higher, but have been reduced as a result of

developments in the proceedings. Hence, it is not possible to estimate the total amount of ABN AMRO’s potential

liability, if any.


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Claim relating to Reverse Factoring Program

ABN AMRO Asset Based Finance (ABF) is involved in litigation with a French client. The client alleges a claim for

(re)payment of various sums in connection with a reverse factoring arrangement between ABF, the client and certain of

the client's subsidiaries. The claim is based on the assertion that ABF has not fulfilled certain of its contractual

obligations under the reverse factoring program in 2022. The legal proceedings were initiated by the client in 2024.

In September 2025, the client submitted documents to the court for the purpose of (inter alia) substantiating its

claims. It is expected that parties will submit additional documents to the court during 2026.

AML remediation programme

ABN AMRO continues to enhance its internal AML processes and systems to increase both effectiveness and

sustainable compliance with regulatory requirements. ABN AMRO’s focus is on the effectiveness of our monitoring

processes and the quality of client due diligence. ABN AMRO maintains a dialogue with the Dutch central bank DNB,

keeping it regularly informed. DNB continues to monitor progress and provides observations, such as previously

identified shortcomings in ABN AMRO’s EDR process. DNB has indicated that these shortcomings may lead to

enforcement measures. A potential financial impact cannot be reliably estimated, and no provision has been recorded.

36 Remuneration of Executive Board and Supervisory Board

Remuneration of the Executive Board


							2025
	Base salary	Variable remuneration³	Other short-term benefits ⁴	Total short term benefits	Severance payments	Total pension-related contributions ⁵		Total
(in thousands)						Post-employment pension (a)	Short-term allowances (b)
M.M.A.S. Bérard, chair¹	599		96	695		20	120	835
R.A.J. Swaak, chair²	722		130	852	218	24	144	1,239
D.S. Dorner, vice-chair	736		10	746		29	142	917
C. Bittner	736		48	784		29	142	955
S. Fioravanti¹	736		107	843		29	142	1,014
C.L. van der Hooft - Cheong	736		36	772		29	142	944
A. van Nimwegen	736		69	805		29	142	977
F.G. Vaandrager	736		45	781		29	142	952
A.M. Vreugdenhil	736		24	760		29	142	931
Total	6,473		565	7,038	218	247	1,258	8,764

							2024
R.A.J. Swaak, chair²	829			829		38	208	1,075
D.S. Dorner, vice-chair	704		44	748		38	170	956
C. Bittner	704		48	752		38	170	960
T.J.A.M. Cuppen²	411		238	649		22	99	770
S. Fioravanti¹	176		26	202		10	42	254
C.L. van der Hooft - Cheong	704		38	742		38	170	950
A. van Nimwegen	704		65	769		38	170	977
C. Oosterloo ^{1, 2}	307		9	316		17	74	407
F.G. Vaandrager	704		58	762		38	170	970
A.M. Vreugdenhil	704		24	728		38	170	936
Total	5,947		550	6,497		315	1,443	8,255
1. The following members were appointed as Executive Board members in 2025 and 2024: M.M.A.S. Bérard (23 April 2025), C. Oosterloo (ad interim from 24 April 2024 until 1 October 2024) and S. Fioravanti (1 October 2024).
2. The following members stepped down as Executive Board members of ABN AMRO: R.A.J. Swaak (stepped down on 23 April 2025 and left with effect from 1 November 2025), T.J.A.M. Cuppen (stepped down on 24 April 2024 and left with effect from 1 August 2024) and C. Oosterloo (ad interim period ended with effect from 1 October 2024). For T.J.A.M. Cuppen, all remuneration components for the period until her services agreement ended on 1 August 2024 are included above.
3. Owing to the Bonus Prohibition Act, the Executive Board members are not entitled to receive variable compensation. This prohibition has applied since the 2011 performance.
4. Other short-term benefits consist of flight tickets, a housing allowance, compensation for lease car expenses, mortgage interest rate benefit and international schooling costs for Executive Board members' children when applicable. If applicable, the amount of the payment for remaining leave entitlement at the end of the services agreement is also included in Other short-term benefits.
5. The Executive Board members participate in ABN AMRO Bank's pension plans for employees in the Netherlands. This participation is not mandatory for M.M.A.S. Bérard and S. Fioravanti considering their specific international tax resident status. Total pension-related contributions refer to (a) the employer contribution to the pension fund for the CDC pension scheme for pensionable income up to EUR 137,800 (2024: EUR 137,800) and (b) the arrangement in accordance with the ABN AMRO Collective Labour Agreement ('ABN AMRO CAO'). In 2025 the employer contribution decreased from 30% to 23.75%.


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Loans from ABN AMRO to Executive Board members


			2025			2024
(in thousands)	Outstanding as at 31 December	(Addition)/ redemptions	Interest rate	Outstanding as at 31 December	(Addition)/ redemptions	Interest rate
D.S. Dorner	742	171	3.1%	913	-471	3.5%
C.L. van der Hooft - Cheong	904	27	1.2%	931	497	1.2%
C. Oosterloo¹				150		2.1%
F.G. Vaandrager	369	128	3.8%	497	-497	4.2%
1. The following member was appointed in 2024: C. Oosterloo (ad interim from 24 April 2024 until 1 October 2024).

Remuneration of the Supervisory Board


(in thousands)	2025	2024
T. de Swaan, chair	135	125
M.P. Lap, vice-chair	113	107
A.C. Dorland, vice-chair²	81	111
L.J. Griffith	113	108
D.U. Hartert¹	34
S.A.C. Russell	116	106
M.L. Tannemaat	112	108
F. de Vries	116	106
W.J.M. Devriendt²		9
Total	820	780
1. In 2025 and 2024 the following member was appointed as a member of the Supervisory Board: D.U. Hartert (11 September 2025).
2. In 2025 and 2024 the following members stepped down as a member of the Supervisory Board: W.J.M. Devriendt (5 February 2024) and A.C. Dorland (11 September 2025).

Loans from ABN AMRO to Supervisory Board members


			2025			2024
(in thousands)	Outstanding as at 31 December	(Addition)/ Redemptions	Interest rate	Outstanding as at 31 December	(Addition)/ Redemptions	Interest rate
T. de Swaan	1,881	-307	1.2%	1,574	6	1.0%
S.A.C. Russell	600	370	3.8%	970	-600	3.1%
M.L. Tannemaat	682	16	1.6%	698	9	1.6%
F. de Vries	1,306	-501	2.9%	805	14	2.6%


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37 Share-based payment



	Accounting policy for share-based payment Identified staff as defined by CRD V are entitled to receive variable compensation, consisting of a cash element and a share-based element settled in cash. The cash element in the variable compensation plan is recognised in accordance with IAS 19 and the other element qualifies as a cash-settled share-based payment in accordance with IFRS 2. Variable compensation is granted for a certain performance year, at 50% in cash and 50% in share-based compensation settled in cash. The vesting conditions include bad leaver conditions and consist of a deferral period and a retention period until the share-based compensation is settled in cash. Up to and including the performance year 2019, 30% of the share-based compensation settled in cash (depositary receipt) vests two years after the performance year. The remaining 20% vests in three equal tranches in the third, fourth and fifth year following the performance year. At the end of the vesting period, participants receive the cash value of the five-day average of an ABN AMRO listed depositary receipt (DR). Share-based compensation settled in cash granted for 2019 and the years before includes the option of requesting DRs rather than cash. This choice can be made during the quarter in which settlement takes place and is subject to Supervisory Board approval. This equity component in the plan is valued at nil until the request is approved. Participants receive the same amount of fair value, regardless of whether they choose cash or DRs. If participants choose DRs, the value of the DRs is transferred in its entirety from the liability to an equity account. The actual delivery to the participant is expected to take place in the same quarter as the choice is made.



	ABN AMRO will not issue additional shares for compensation granted for years 2019 and before, but will buy shares in the market when needed. As the purchase of shares is expected to take place in the quarter during which the DRs are delivered, there is no impact on (diluted) earnings per share. As from performance year 2020, the DRs were replaced by performance certificates (PCs) as share-based compensation settled in cash. The share-based compensation settled in cash vests for 30% in the first year. The remaining 20% vests in four equal tranches in the second, third, fourth and fifth year following the performance year. At the end of the vesting period, participants receive the cash value of the five-day average of ABN AMRO’s share price. Share-based compensation settled in cash granted from performance year 2020 onwards does not include the option of requesting DRs. A liability is recognised for the fair value of cash-settled transactions. The fair value is measured initially and at each reporting date up to and including the settlement date, with changes in fair value recognised in employee benefits expenses. The fair value is determined using an internally developed model based on the share price and market expectations of future dividends.

The carrying amount of the liability relating to share-based compensation settled in cash at 31 December 2025 was

EUR 12 million (2024: EUR 10 million). The expense recognised for the DRs and PCs awards during 2025 was

EUR 8 million, including retention bonus (2024: EUR 4 million).

The following table shows the total number of DRs and PCs awarded, forfeited and paid out.


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(in thousands of DRs and PCs)		2025		2024
Outstanding as at 1 January		627		649
Granted during the year		264		314
Forfeited during the year	11		14
Paid out during the year cash	321		316
Paid out during the year DRs and PCs	3		6
Total paid out/forfeited		-335		-336
Outstanding as at 31 December		556		627

The following table shows the total number of DRs and PCs granted, segmented by the respective vesting period after

which the award is paid out.


					31 December 2025
(in thousands of DRs and PCs)	Up to one year	Between one and two years	Between two and three years	Between three and four years	Between four and five years	Total
Number of granted DRs by vesting period	268	123	84	55	26	556


					31 December 2024
Number of granted DRs by vesting period	324	115	99	59	30	627

38 Related parties

Parties related to ABN AMRO Bank include NLFI and the Dutch State, which have significant influence, associates,

pension funds, joint ventures, the Executive Board, the Supervisory Board, close family members of any person

referred to above, entities controlled or significantly influenced by any person referred to above and any other related

entities. ABN AMRO has applied the partial exemption for government-related entities as described in IAS 24

paragraphs 25-27.

As part of its business operations, ABN AMRO frequently enters into transactions with related parties. Transactions

conducted with the Dutch State are limited to normal banking transactions, taxation and other administrative

relationships with the exception of items specifically disclosed in this note. Normal banking transactions relate to loans

and deposits and are entered into under the same commercial and market terms that apply to non-related parties.

Loans and advances to the Executive Board members and Supervisory Board and close family members, where

applicable, consist mainly of residential mortgages, which may be granted under standard personnel conditions. For

further information, please refer to Note 36 - Remuneration of Executive Board and Supervisory Board

in the Consolidated Annual Financial Statements 2025.

Balances with joint ventures, associates and other


				31 December 2025
(in millions)	Joint ventures	Associates	Other	Total
Assets		28		28
Liabilities		77		77
Guarantees given		20		20
Irrevocable facilities		3		3
				2025
Income received		2		2
Expenses paid		93	344	437


ABN AMRO	Annual Report 2025	383


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				31 December 2024
(in millions)	Joint ventures	Associates	Other	Total
Assets		34		34
Liabilities		70		70
Guarantees given		20		20
Irrevocable facilities		4		4
				2024
Income received		2		2
Expenses paid		96	387	483

Expenses paid in the column Other reflects pension contributions paid to the ABN AMRO pension fund. Under the new

pension scheme agreement, effective 1 January 2025, the premium percentage to be paid to the pension fund

declined from 37% to 30%.

Balances with the Dutch State


(in millions)	31 December 2025	31 December 2024
Assets
Financial assets held for trading	140	616
Derivatives	1
Financial investments	3,399	3,261
Loans and advances customers	10
Liabilities
Financial liabilities held for trading	584	181
Derivatives	1
Due to customers	467	471
	2025	2024
Income statement
Interest income	76	64
Interest expense	20	20
Net trading income	18	38
Net fee and commission income	3	2

On 1 April 2010, ABN AMRO signed an indemnity agreement with the Dutch State (currently represented by NLFI) for a

shortfall in capital above a certain amount related to specific assets and liabilities of RFS Holdings B.V. In 2019, Royal

Bank of Scotland (RBS) acquired all shares in RFS Holding. However, NLFI has given certain warranties related to its

previously owned shares in RFS Holdings and the indemnity agreement continues to exist. RFS Holdings is sufficiently

capitalised. Consequently, ABN AMRO has assessed the risk for any shortfall as remote.

Transactions conducted with the Dutch State are limited to normal banking transactions, taxation and other

administrative relationships. Normal banking transactions relate to loans and deposits, financial assets held for trading

and financial investments, and are entered under the same commercial and market terms that apply to non-related

parties.

Transactions and balances related to taxation, levies and fines in the Netherlands, are excluded from the table above.

The EUR 0.5 billion decrease in financial assets held for trading mainly related to lower amounts of Dutch government

bonds as a result of the primary dealership in the Netherlands and client facilitation. Most of these contracts are

hedged with short positions in government bonds.

The EUR 0.1 billion increase in financial investments was mainly due to higher Dutch government bonds held. This is

part of the liquidity buffer and is held for liquidity contingency purposes.

The EUR 0.4 billion increase in financial liabilities held for trading mainly related to higher amounts of Dutch

government bonds as a result of the primary dealership in the Netherlands and client facilitation. Most of these

contracts are hedged with short positions in government bonds.


ABN AMRO	Annual Report 2025	384


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Key management personnel compensation


								2025
	Base salary	Variable remuneration¹	Other short-term benefits²	Total short-term benefits	Severance payments	Total pension-related contributions³		Total
(in thousands)						Post-employment pension (a)	Short-term allowances (b)
Members ExBo	6,473		565	7,038	218	247	1,258	8,764

								2024
Members ExBo	5,947		550	6,497		315	1,443	8,255
1. Owing to the Bonus Prohibition Act, the Executive Board members are not entitled to receive variable compensation. This prohibition has applied since the 2011 performance.
2. Other short-term benefits consist of flight tickets, a housing allowance, compensation for lease car expenses, mortgage interest rate benefit and international schooling costs for Executive Board members' children when applicable. If applicable, the amount of the payment for remaining leave entitlement at the end of the employment contract are also included in Other short-term benefits.
3. The Executive Board members participate in ABN AMRO Bank's pension plans for employees in the Netherlands. This participation is not mandatory for M.M.A.S. Bérard and S. Fioravanti considering their specific international tax resident status. Total pension-related contributions refer to (a) the employer contribution to the pension fund for the CDC pension scheme for pensionable income up to EUR 137,800 (2024: EUR 137,800) and (b) the arrangement in accordance with the ABN AMRO Collective Labour Agreement ('ABN AMRO CAO'). In 2025 the employer contribution decreased from 30% to 23.75%.

Key management loans and advances


			2025			2024
(in thousands)	Outstanding 31 December	(Addition)/ Redemptions	Average Interest rate	Outstanding 31 December	(Addition)/ Redemptions	Average Interest rate
Executive Board	2,015	326	2.4%	2,491	-471	2.6%

39 Capital management

Capital management strategy

The primary objective of the bank’s capital management strategy is to ensure that capital adequacy requirements are

met at all times and that sufficient capital is available to support the bank’s strategy. Changes in the capital

requirements legislation, including new frameworks such as Basel IV, are decided by the European Parliament. The

European Central Bank is responsible for monitoring compliance with the capital requirements. ABN AMRO has

complied with all applicable capital adequacy requirements. Capital is a necessary resource for doing business and

defines the bank’s commercial possibilities. The balance between available and required capital is managed centrally

to optimise the use of available capital. The basis of the capital management strategy is the bank’s risk appetite and its

business plans. Other important factors in managing the capital position are expectations and requirements of external

stakeholders (such as regulators, investors, shareholders, equity analysts, rating agencies and clients), the bank’s

position in the market, market developments, contingent capital needs and the feasibility of capital management

actions. Although ABN AMRO manages its capital centrally, the group companies are sufficiently capitalised to comply

with all local regulatory solvency requirements and to meet any local business needs. Apart from prevailing statutory

and regulatory legislation, there are no specific material impediments for prompt transfer of the bank’s regulatory

capital. The objectives, policies and processes for managing capital have not changed from the previous years.

Regulatory capital structure


		31 December 2025		31 December 2024
(in millions)		CRR III		CRR II

Total equity (EU IFRS)		27,043		26,108
Cash flow hedge reserve		-209		10
Dividend reserve		-826		-625
AT1 capital securities (EU IFRS)		-3,233		-3,475
Share buyback reserve		-250
Regulatory and other adjustments		-1,626		-1,662
Common Equity Tier 1		20,899		20,357

AT1 capital securities (EU IFRS)		3,233		3,475
Regulatory and other adjustments		-5		-1
Tier 1 capital		24,127		23,831

Subordinated liabilities (EU IFRS)	4,946		6,613
Regulatory and other adjustments	-831		-1,967
Tier 2 capital		4,114		4,646
Total regulatory capital		28,241		28,477


ABN AMRO	Annual Report 2025	385


≡	Annual Financial Statements 2025	Consolidated Annual Financial Statements 2025

40 Post balance sheet events

ABN AMRO appoints Michiel Lap as Chair; nominates Jean‑Pierre Mustier to Supervisory Board

In January 2026, ABN AMRO Bank announced that Michiel Lap will succeed Tom de Swaan as Chair of the

Supervisory Board effective from the close of the Annual General Meeting on 22 April 2026. Furthermore, Jean-Pierre

Mustier has been nominated as a member of the Supervisory Board for a four-year term. The nomination is subject to

the approval of the European Central Bank.

ABN AMRO announces additional distribution EUR 500 million

In February 2026, ABN AMRO announced a plan to distribute an additional EUR 500 million, consisting of EUR 250

million in cash dividends and EUR 250 million through a share buyback programme, for which an application for

regulatory approval has been submitted.

Authorisation of the Consolidated Annual Financial Statements

10 March 2026

Supervisory Board

T. de Swaan , Chair

M.P. Lap, Vice-Chair

L.J. Griffith

D.U. Hartert

S.A.C. Russell

M.L. Tannemaat

F. de Vries

Executive Board

M.M.A.S. Bérard, Chief Executive Officer and Chair

D.S. Dorner, Chief Commercial Officer - Corporate Banking and Vice-Chair

C. Bittner, Chief Innovation and Technology Officer

S. Fioravanti, Chief Risk Officer

C.L. van der Hooft - Cheong, Chief Commercial Officer - Wealth Management

F.G. Vaandrager, Chief Financial Officer

A.M. Vreugdenhil, Chief Commercial Officer - Personal & Business Banking


ABN AMRO	Annual Report 2025	386

Company Annual

Financial Statements

of ABN AMRO Bank N.V.


ABN AMRO	Annual Report 2025	387


≡	Annual Financial Statements 2025	Company Annual Financial Statements of ABN AMRO Bank N.V.

Company income statement


(in millions)	Note	2025	2024
Income
Interest income		21,351	31,252
Interest expense		16,448	25,990
Net interest income	2	4,903	5,262
Fee and commission income		1,571	1,502
Fee and commission expense		260	262
Net fee and commission income		1,312	1,241
Results from financial transactions	3	-197	-324
Income from securities and participating interests	4	942	1,142
Other operating income	5	16	-20
Operating income		6,976	7,300
Expenses
Personnel expenses	6	2,571	2,339
General and administrative expenses		1,499	1,780
Depreciation, amortisation and impairment losses of tangible and intangible assets		146	143
Operating expenses		4,216	4,262
Impairment charges on financial instruments		-42	10
Total expenses		4,174	4,272
Profit/(loss) before taxation		2,802	3,029
Income tax expense		551	626
Profit/(loss)		2,252	2,403


ABN AMRO	Annual Report 2025	388


≡	Annual Financial Statements 2025	Company Annual Financial Statements of ABN AMRO Bank N.V.

Company statement of financial position


(in millions)	Note	31 December 2025	31 December 2024
Assets
Cash and balances at central banks	7	43,351	44,179
Short-term government paper	8	34,652	36,174
Loans and advances banks	9	173,700	160,763
Loans and advances customers	10	107,552	100,851
Debt securities	11	26,122	23,892
Equity securities	12	89	74
Participating interests in group companies	13	5,120	3,817
Equity-accounted investments	14	187	177
Intangible assets	15	296	221
Property and equipment	15	459	718
Other assets	16	5,335	5,368
Total assets		396,865	376,234
Liabilities
Due to banks	17	7,827	6,286
Due to customers	18	275,289	256,073
Issued debt	19	70,851	70,799
Subordinated liabilities	20	4,946	6,613
Provisions	21	596	531
Other liabilities	22	10,317	9,827
Total liabilities		369,826	350,129
Equity
Share capital		823	833
Share premium		11,745	11,849
Revaluation reserves		1,000	554
Currency translation reserves		-2	93
Other legal reserves		428	291
Other reserves		7,561	6,608
AT1 Capital securities		3,233	3,475
Profit/(loss) for the period		2,252	2,403
Total equity	23	27,040	26,105
Total liabilities and equity		396,865	376,234


ABN AMRO	Annual Report 2025	389


≡	Annual Financial Statements 2025	Company Annual Financial Statements of ABN AMRO Bank N.V.

Company statement of changes in equity


(in millions)	Share capital	Share premium	Revaluation reserves	Currency translation reserves	Other legal reserves	Other reserves ⁴	Capital securities	Profit/ (loss) for the period	Total
Balance as at 1 January 2024	866	12,192	191	56	290	5,886	1,987	2,697	24,165
Total comprehensive income			362	37	1	-495		2,403	2,308
Transfer						2,697		-2,697
Dividend						-1,244			-1,244
Share buyback	-33	-343				-124			-500
Paid interest on AT1 capital securities						-120			-120
Increase of capital							1,488		1,488
Other changes in equity¹						7			7
Balance as at 31 December 2024	833	11,849	554	93	291	6,608	3,475	2,403	26,105
Total comprehensive income			446	-95	137	1		2,252	2,741
Transfer						2,403		-2,403
Dividend						-1,074			-1,074
Share buyback²	-10	-104				-136			-250
Paid interest on AT1 capital securities						-217			-217
Increase of capital							751		751
Decrease of capital³							-1,000		-1,000
Other changes in equity ^{2, 3}						-24	7		-17
Balance as at 31 December 2025	823	11,745	1,000	-2	428	7,561	3,233	2,252	27,040
1. Reclassification of fair value reserve to retained earnings following the sale of Neuflize Vie.
2. On 6 August 2025, ABN AMRO Bank N.V. announced a share buyback program of EUR 250 million. The withholding tax related to this share buyback amounted to EUR 17 million. For more information on the share buyback, please refer to Note 33 Equity of the Consolidated Annual Financial Statements.
3. On 22 September 2025, ABN AMRO Bank N.V. called AT1 Capital Securities of EUR 1.0 billion. Upon repayment, the related discount of EUR 7 million was released through retained earnings.
4. Consists of actuarial gains/(losses) on post-employment benefit plans and retained earnings.


ABN AMRO	Annual Report 2025	390


≡	Annual Financial Statements 2025	Company Annual Financial Statements of ABN AMRO Bank N.V.

Notes to the Company

Annual Financial Statements

of ABN AMRO Bank N.V.

1 Accounting policies

The Company Annual Financial Statements of ABN AMRO Bank N.V. have been prepared in accordance with

the requirements of Title 9 of Book 2 of the Dutch Civil Code. ABN AMRO Bank N.V. applies the option set out

in Section 2:362 paragraph 8 of the Dutch Civil Code. ABN AMRO Bank N.V. prepares its Consolidated Annual Financial

Statements in accordance with International Financial Reporting Standards as adopted by the European Union

(EU IFRS). Reference is made to the accounting policies section in the Consolidated Annual Financial Statements and

the respective notes.

Corporate information

ABN AMRO Bank N.V. is registered at Gustav Mahlerlaan 10, 1082 PP Amsterdam, the Netherlands (Chamber

of Commerce number 34334259).

Basis of preparation

The impairment requirements of IFRS 9 are applicable to financial instruments measured at amortised cost and FVOCI.

These requirements also apply to intercompany transactions, which are eliminated upon consolidation.

In ABN AMRO Bank’s Company Annual Financial Statements, the elimination of expected credit losses on

intercompany transactions with subsidiaries is recognised in the carrying amount of the loans and advances and

participating interests in group companies.

Participating interests in group companies are measured at net asset value, determined on the basis of EU IFRS.

The share in the results of participating interests in group companies is reported in accordance with the principles

of valuation and profit determination that apply to the Consolidated Annual Financial Statements.

The financial statements are presented in euros, which is the functional and presentation currency of the company,

rounded to the nearest million (unless otherwise stated).

The financial statements are prepared on a going concern basis.

2 Net interest income

Net interest income for 2025 amounted to EUR 4,903 million, a decrease of EUR 359 million compared with

EUR 5,262 million in 2024, mainly due to decreased interest rates, partly offset by an overall higher balance volume.

Net interest income consists of interest income from loans, investments and other lending, interest expense on

borrowings by ABN AMRO and client accounts, as well as the results from interest-rate and foreign-exchange

contracts entered into for hedging purposes.


ABN AMRO	Annual Report 2025	391


≡	Annual Financial Statements 2025	Company Annual Financial Statements of ABN AMRO Bank N.V.

3 Results from financial transactions


(in millions)	2025	2024
Securities trading and derivatives transactions	-162	-268
Foreign exchange transaction results	4	11
Other	-39	-68
Total results from financial transactions	-197	-324

Results from financial transactions increased by EUR 128 million to EUR 197 million negative in 2025, mainly due to

higher trading results from securities and derivative transactions.

4 Income from securities and participating interests


(in millions)	2025	2024
Shares and equity-accounted investments	16	34
Participating interests	926	1,108
Total income from securities and participating interests	942	1,142

5 Other operating income


(in millions)	2025	2024
Disposal of operating activities and equity-accounted investments	1	-22
Other	15	1
Total other operating income	16	-20

Total other operating income increase by EUR 36 million to EUR 16 million in 2025, mainly due to the bargain

purchase gain from the acquisition of HAL.

6 Personnel expenses


(in millions)	2025	2024
Salaries and wages	1,862	1,688
Social security charges	282	242
Pension expenses relating to defined benefit plans	5	7
Defined contribution plan expenses	284	320
Other	138	83
Total personnel expenses	2,571	2,339

Total personnel expenses increased by EUR 232 million in 2025 compared to 2024, as a result of an increase in

FTEs and as part of a salary increase under the collective labour agreement (CLA).

7 Cash and balances at central banks

Cash and balances at central banks decreased by EUR 0.8 billion to EUR 43.4 billion as at 31 December 2025, mainly

due to changes in steering, liquidity and funding needs.


ABN AMRO	Annual Report 2025	392


≡	Annual Financial Statements 2025	Company Annual Financial Statements of ABN AMRO Bank N.V.

8 Short-term government paper


(in millions)	31 December 2025	31 December 2024
Short-term government paper held at fair value through other comprehensive income	34,046	35,005
Short-term government paper held for trading	606	1,169
Short-term government paper	34,652	36,174

Short-term government paper decreased by EUR 1.5 billion as at 31 December 2025, mainly as a result of changes in

steering and liquidity needs. Most of these instruments are part of the liquidity buffer and are held for liquidity

contingency purposes.

Changes in short-term government paper held at fair value through other comprehensive

income


(in millions)	2025	2024
Balance as at 1 January	35,005	30,156
Purchases	8,429	10,480
Proceeds from sales and redemptions	-8,360	-6,196
Gains/(losses) recorded in profit and loss	-448	567
Unrealised gains/(losses)	488	-464
Foreign exchange differences	-1,068	460
Other		2
Balance as at 31 December	34,046	35,005

The decrease in gains and losses recorded in profit and loss, offset by the increase in unrealised gains and losses, was

mainly caused by higher interest yields in 2025. Foreign exchange differences were mainly attributable to the

depreciation of the USD.

9 Loans and advances banks


(in millions)	31 December 2025	31 December 2024
Group companies	165,262	156,464
Third parties	8,438	4,300
Loans and advances banks	173,700	160,763


(in millions)	31 December 2025	31 December 2024
Interest-bearing deposits	165,789	157,056
Loans and advances	420	483
Mandatory reserve deposits with central banks	173	156
Securities financing	7,290	3,057
Other	28	12
Loans and advances banks	173,700	160,763

Loans and advances banks mainly consist of transactions with group companies. Loans and advances banks increased

by EUR 12.9 billion to EUR 173.7 billion as at 31 December 2025, mainly due to an increase in interest-bearing

deposits and securities financing.

None of the items within loans and advances banks were subordinated at 31 December 2025.

Mandatory reserve deposits are held with local central banks in accordance with statutory requirements. The minimum

reserve requirements determined by the ECB are the most relevant for the bank.


ABN AMRO	Annual Report 2025	393


≡	Annual Financial Statements 2025	Company Annual Financial Statements of ABN AMRO Bank N.V.

The ECB prescribes how the minimum reserve amount should be calculated during pre-defined reserve periods.

During such periods, the balances are available for use by ABN AMRO. The bank manages and monitors the deposits

to ensure that the minimum reserve requirements for each period are met.


(in millions)	31 December 2025	31 December 2024
The Netherlands	173,304	160,348
Rest of Europe	351	323
USA	46	93
Loans and advances banks	173,700	160,763

10 Loans and advances customers


(in millions)	31 December 2025	31 December 2024
Group companies	17,243	20,333
Third parties	90,309	80,518
Loans and advances customers	107,552	100,851

Loans and advances customers increased by EUR 6.7 billion to EUR 107.6 billion as at 31 December 2025, mainly due

to third parties and partly offset by a decrease in group companies.


(in millions)	31 December 2025	31 December 2024
Residential mortgages	208	251
Consumer loans	5,523	5,680
Corporate loans	77,771	79,264
Securities financing	21,356	12,516
Other loans and advances customers	2,694	3,139
Loans and advances customers	107,552	100,851

Loans and advances customers increased by EUR 6.7 billion to EUR 107.6 billion as at 31 December 2025, mainly due

to securities financing.


(in millions)	31 December 2025	31 December 2024
The Netherlands	83,344	81,297
Rest of Europe	8,412	8,032
USA	15,796	11,522
Loans and advances customers	107,552	100,851


ABN AMRO	Annual Report 2025	394


≡	Annual Financial Statements 2025	Company Annual Financial Statements of ABN AMRO Bank N.V.

11 Debt securities


(in millions)	31 December 2025	31 December 2024
Group companies	13,127	11,925
Third parties	12,996	11,966
Debt securities	26,122	23,892


(in millions)	31 December 2025	31 December 2024
Debt securities held at fair value through other comprehensive income	24,684	22,646
Debt securities held for trading	1,438	1,246
Debt securities	26,122	23,892

Debt securities increased by EUR 2.2 billion as at 31 December 2025, mainly as a result of several purchases. Most of

these instruments are part of the liquidity buffer and are held for liquidity contingency purposes.

Changes in debt securities held at fair value through other comprehensive income


(in millions)	2025	2024
Balance as at 1 January	22,646	21,159
Purchases	30,354	39,282
Proceeds from sales and redemptions	-28,092	-38,192
Gains/(losses) recorded in profit and loss		294
Unrealised gains/(losses)	113	-58
Foreign exchange differences	-336	161
Balance as at 31 December	24,684	22,646

12 Equity securities


(in millions)	31 December 2025	31 December 2024
Equity securities held at fair value through profit or loss	89	74
Equity securities	89	74

Equity securities increased by EUR 15 million, mainly due to the revaluation of equity instruments and additional

investments.

13 Participating interests in group companies


(in millions)	2025	2024
Balance as at 1 January	3,817	3,488
Acquisition of subsidiaries	714
Increase/(decrease) of capital	397	357
Proceeds from sales and redemptions	2	-202
Result from participating interests	926	1,108
Dividends	-948	-864
Unrealised gains/(losses)	7
Foreign exchange differences	-182	61
Other	388	-130
Balance as at 31 December	5,120	3,817


ABN AMRO	Annual Report 2025	395


≡	Annual Financial Statements 2025	Company Annual Financial Statements of ABN AMRO Bank N.V.

14 Equity-accounted investments


			31 December 2025		31 December 2024
(in millions)	Principle place of business	Business line	Carrying amount	Equity interest	Carrying amount	Equity interest
Nationale-Nederlanden ABN AMRO Verzekeringen Holding B.V.	The Netherlands	Personal & Business Banking	86	49%	79	49%
Other			101		98
Total equity associates and joint ventures			187		177


(in millions)	2025	2024
Balance as at 1 January	177	237
Purchases	1	4
Proceeds from sales and redemptions		-205
Gains/(losses) recorded in profit and loss	11	28
Dividends	-2	-13
Unrealised gains/(losses)		4
Other		123
Balance as at 31 December	187	177

15 Property, equipment and intangible assets

The following table shows the book value of property, equipment and intangible assets.


		2025		2024
(in millions)	Total property and equipment	Intangible assets	Total property and equipment	Intangible assets
Acquisition costs as at 1 January	2,208	694	2,037	576
Additions	250	1	251	47
Reversal of cost due to disposals	-145	-13	-57	-21
Foreign exchange differences	-1		1
Internally generated software		91		92
Other	-395	-6	-24
Acquisition costs as at 31 December	1,917	768	2,208	694
Accumulated depreciation/amortisation as at 1 January	-1,480	-357	-1,416	-371
Depreciation/amortisation	-128	-12	-136	-7
Reversal of depreciation/amortisation due to disposals	138	7	54	21
Foreign exchange differences	1		-1
Other	19		18
Accumulated depreciation as at 31 December	-1,449	-362	-1,480	-357
Impairments as at 1 January	-11	-116	-14	-116
Increase of impairments charged to the income statement		-6
Reversal of impairments due to disposals	2	6	2
Other		6	2
Impairments as at 31 December	-9	-110	-11	-116
Total as at 31 December	459	296	718	221

The building at Foppingadreef in Amsterdam was transferred from ABN AMRO Bank N.V. to a subsidiary at a carrying

value of EUR 376 million.


ABN AMRO	Annual Report 2025	396


≡	Annual Financial Statements 2025	Company Annual Financial Statements of ABN AMRO Bank N.V.

16 Other assets


(in millions)	31 December 2025	31 December 2024
Derivatives	3,766	4,346
Tax assets	168	223
Other	1,401	799
Other assets	5,335	5,368

Other assets decreased by EUR 33 million, primarily due to a EUR 580 million reduction in derivatives and a

EUR 55 million decline in tax assets. These decreases were partly offset by a EUR 602 million increase in other.

Derivatives decreased due to a EUR 419 million decline in over-the-counter derivatives trading, and a decrease of

EUR 161 million in non-trading derivatives. Derivatives include EUR 3.5 billion for derivatives held for trading

(31 December 2024: EUR 3.9 billion).

17 Due to banks


(in millions)	31 December 2025	31 December 2024
Group companies	3,119	3,344
Third parties	4,708	2,943
Due to banks	7,827	6,286


(in millions)	31 December 2025	31 December 2024
Current accounts	2,395	2,287
Demand deposits	2	1
Time deposits	2,939	1,586
Securities financing	1,967	1,927
Other	524	485
Due to banks	7,827	6,286

Due to banks increased by EUR 1.5 billion, mainly due to the increase in time deposits and current accounts.

18 Due to customers


(in millions)	31 December 2025	31 December 2024
Group companies	5,304	4,940
Third parties	269,985	251,133
Due to customers	275,289	256,073


(in millions)	31 December 2025	31 December 2024
Current accounts	84,385	83,962
Demand deposits	131,518	107,675
Time deposits	42,317	50,905
Total deposits	258,220	242,543
Securities financing	12,920	7,980
Other due to customers	4,149	5,551
Due to customers	275,289	256,073

Due to customers increased by EUR 19.2 billion as at 31 December 2025, mainly due to increases in demand deposits.


ABN AMRO	Annual Report 2025	397


≡	Annual Financial Statements 2025	Company Annual Financial Statements of ABN AMRO Bank N.V.

19 Issued debt

The following table shows the debt issued by ABN AMRO Bank.


(in millions)	31 December 2025	31 December 2024
Group companies
Third parties	70,851	70,799
Issued debt	70,851	70,799

The following table shows the types of debt issued by ABN AMRO Bank.


(in millions)	31 December 2025	31 December 2024
Bonds and notes issued	62,140	56,415
Certificates of deposit and commercial paper	8,553	14,179
Total at amortised cost	70,692	70,594
Designated at fair value through profit or loss	159	205
Issued debt	70,851	70,799

Total issued debt increased by EUR 0.1 billion to EUR 70.9 billion as at 31 December 2025, mainly due to an increase

in bonds and notes issued, offset by a decrease in certificates of deposit and commercial paper.

20 Subordinated liabilities

The following table specifies the outstanding subordinated liabilities. The issued and outstanding loans qualifying as

subordinated liabilities are subordinated to all other current and future liabilities.


(in millions)	31 December 2025	31 December 2024
Group companies
Third parties	4,946	6,613
Subordinated liabilities	4,946	6,613

The following table shows the main types of subordinated liabilities issued by ABN AMRO Bank.


(in millions)	ISIN/CUSIP	31 December 2025	31 December 2024
Subordinated liabilities		4,946	6,613
- of which USD 1,000 million 4.8% per annum	US0008DAL47 / XS1392917784	854	935
- of which USD 300 million 5.6% per annum	XS1385037558	238	256
- of which SGD 750 million 5.5% per annum	XS2498035455	512	537
- of which EUR 1,000 million 5.125% per annum	XS2558022591	1,051	1,056
- of which USD 1,000 million 3.324% per annum	US00084DAV29 / XS2415308761	757	807
- of which EUR 750 million 5.5% per annum	XS2637967139	764	782
- of which EUR 750 million 4.375% per annum	XS2859413341	769	785
- of which USD 1,500 million 4.75% per annum	US00080QAF28 / XS1264600310		1,452

Subordinated liabilities decreased by EUR 1.7 billion to EUR 4.9 billion as at 31 December 2025, mainly due to the

maturity of subordinated liabilities of EUR 1.3 billion and the FX result of EUR 0.4 billion.


ABN AMRO	Annual Report 2025	398


≡	Annual Financial Statements 2025	Company Annual Financial Statements of ABN AMRO Bank N.V.

21 Provisions

The following table shows a breakdown of provisions as at 31 December 2025 and 31 December 2024 .


(in millions)	31 December 2025	31 December 2024
Legal provisions	158	121
Restructuring provision	77	16
Provision for pension commitments	61	73
Other staff provision	190	180
Other	111	141
Provisions	596	531

Restructuring

Restructuring provisions cover the costs of the restructuring plans for which implementation has been formally

announced.

Legal provisions

Legal provisions are based on best estimates available at the year-end and taking into account the opinion of legal

specialists. The timing of the outflow of cash related to these provisions is by nature uncertain, given the

unpredictability of the outcome and the time required to conclude litigation. Any provision recognised does not

constitute an admission of wrongdoing or legal liability. Legal provions increased with EUR 37 million mainly due to

the increase in Group Functions and the decrease on the provision “Variabele Interest”.

Variable interest rates for consumer loans

On 3 March 2021, the Kifid Appeals Committee confirmed a ruling of the Kifid Disputes Committee about the

recalculation of the variable interest charged to a specific client on a revolving credit. In short, Kifid ruled that ABN

AMRO should have followed the market rate while establishing the variable interest rate for certain revolving

consumer credits.

In light of the Kifid ruling, ABN AMRO reached agreement with the Dutch Consumers' Association (Consumentenbond

Claimservice) on 5 September 2021 regarding a compensation scheme for affected clients. In Q3 of 2022, following

an August 2022 ruling of the Kifid Appeals Committee, ABN AMRO adjusted the compensation scheme to include

interest on interest. The execution of the compensation scheme has been completed in 2025 and the handling of any

other matters relating to consumer credits with a variable interest rate has been handed over to the business as usual.

Therefore, as at the end of Q4 2025, in total EUR 483 million of the provision has been used and the remaining

provision of EUR 22 million has been released.