ing-20251231

Securities registered or to be registered pursuant to Section 12(b) of the Act.


Title of each class	Trading symbols	Name of each exchange on which registered
American Depositary Shares	ING	New York Stock Exchange
Ordinary shares		New York Stock Exchange(i)
3.950% Fixed Rate Senior Notes due 2027	ING27	New York Stock Exchange
4.550% Fixed Rate Senior Notes due 2028	ING28	New York Stock Exchange
4.050% Fixed Rate Senior Notes due 2029	ING29	New York Stock Exchange
1.726% Callable Fixed-to-Floating Rate Senior Notes due 2027	ING27A	New York Stock Exchange
2.727% Callable Fixed-to-Floating Rate Senior Notes due 2032	ING32	New York Stock Exchange
Callable Floating Rate Senior Notes due 2027	ING27B	New York Stock Exchange
4.017% Callable Fixed-to-Floating Rate Senior Notes due 2028	ING28A	New York Stock Exchange
4.252% Callable Fixed-to-Floating Rate Senior Notes due 2033	ING33	New York Stock Exchange
6.083% Callable Fixed-to-Floating Rate Senior Notes due 2027	ING27C	New York Stock Exchange
$500,000,000 Callable Floating Rate Senior Notes due 2027	ING27D	New York Stock Exchange
$1,250,000,000 6.114% Callable Fixed-to-Floating Rate Senior Notes due 2034	ING34	New York Stock Exchange
5.335% Callable Fixed-to-Floating Rate Senior Notes due 2030	ING30	New York Stock Exchange
5.550% Callable Fixed-to-Floating Rate Senior Notes due 2035	ING35	New York Stock Exchange
4.858% Callable Fixed-to-Floating Rate Senior Notes due 2029	ING29A	New York Stock Exchange
5.066% Callable Fixed-to-Floating Rate Senior Notes due 2031	ING31	New York Stock Exchange
5.525% Callable Fixed-to-Floating Rate Senior Notes due 2036	ING36	New York Stock Exchange
Callable Floating Rate Senior Notes due 2029	ING29B	New York Stock Exchange

(i)Not for trading, but only in connection with the registration of American Depositary Shares representing

such ordinary shares, pursuant to the requirements of the Securities and Exchange Commission.

Securities registered or to be registered pursuant to Section 12(g) of the Act.None

Securities for which there is a reporting obligation pursuant to Section 15(d) of the Act. None

Indicate the number of outstanding shares of each of the issuer’s classes of capital or common stock as of the

close of the period covered by the annual report.

Ordinary Shares, nominal value EUR 0.01 per Ordinary Share 2,902,437,688

Indicate by check mark if the registrant is a well-known seasoned issuer, as defined in Rule 405 of the Securities

Act. ☒ Yes ☐ No

If this report is an annual or transition report, indicate by check mark if the registrant is not required to file reports

pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934. ☐ Yes ☒ No

Note — Checking the box above will not relieve any registrant required to file reports pursuant to Section 13 or

15(d) of the Securities Exchange Act of 1934 from their obligations under those Sections.

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of

the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant

was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.

☒ Yes ☐ No

Indicate by check mark whether the registrant has submitted electronically every Interactive Data File required to

be submitted pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or

for such shorter period that the registrant was required to submit and post such files). ☒ Yes ☐ No

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated

filer, or an emerging growth company. See definition of “large accelerated filer,” accelerated filer,” and “emerging

growth company” in Rule 12b-2 of the Exchange Act.

Large accelerated filer ☒ Accelerated filer ☐ Non-accelerated filer ☐ Emerging growth company ☐

If an emerging growth company that prepares its financial statements in accordance with U.S. GAAP, indicate by

check mark if the registrant has elected not to use the extended transition period for complying with any new or

revised financial accounting standards† provided pursuant to Section 13(a) of the Exchange Act. ☐


†	The term “new or revised financial accounting standard” refers to any update issued by the Financial Accounting Standards Board to its Accounting Standards Codification after April 5, 2012.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	6

Presentation of information

In this Annual Report, and unless otherwise stated or the context

otherwise dictates, references to "ING Groep N.V.", "ING Groep NV", "ING

Groep" and "ING Group" refer to ING Groep NV and references to "ING", the

"Company", the "Group", "we" and "us" refer to ING Groep NV and its

consolidated subsidiaries. ING Groep N.V.'s primary banking subsidiary is

ING Bank N.V. (together with its consolidated subsidiaries, "ING Bank").

References to "Executive Board or EB" and "Supervisory Board or SB" refer

to the Executive Board or Supervisory Board of ING Groep N.V.,

respectively.

ING presents its consolidated financial statements in euros, the currency of

the European Economic and Monetary Union. Unless otherwise specified or

the context otherwise requires, references to “$”, “US$” and “Dollars” are

to the United States dollars and references to "€" and “EUR” are to euros.

ING prepares financial information in accordance with International

Financial Reporting Standards as issued by the International Accounting

Standards Board (“IFRS-IASB”) for purposes of reporting with the U.S.

Securities and Exchange Commission (“SEC”), including financial

information contained in this Annual Report on Form 20-F. ING Group’s

accounting policies and its use of various options under IFRS-IASB are

described under Note '1.2 Basis of preparation of the Consolidated

financial statements’ in the consolidated financial statements. In this

document the term “IFRS-IASB” is used to refer to IFRS-IASB as applied by

ING Group.

The published 2025 Financial Statements of ING Group, however, are

prepared in accordance with IFRS-EU. IFRS-EU refers to International

Financial Reporting Standards (“IFRS”) as adopted by the European Union

(“EU”), including the decisions ING Group made with regard to the options

available under IFRS as adopted by the EU (IFRS-EU).

IFRS-EU differs from IFRS-IASB, in respect of certain paragraphs in IAS 39

‘Financial Instruments: Recognition and Measurement’ regarding hedge

accounting for portfolio hedges of interest rate risk. Under IFRS-EU, ING

Group applies fair value hedge accounting for portfolio hedges of interest

rate risk (fair value macro hedges) in accordance with the EU “carve-out”

version of IAS 39. Under the EU “IAS 39 carve-out”, hedge accounting may

be applied, in respect of fair value macro hedges, to core deposits and

hedge ineffectiveness is only recognised when the revised estimate of the

amount of cash flows in scheduled time buckets falls below the original

designated amount of that bucket, and is not recognised when the revised

amount of cash flows in scheduled time buckets is more than the original

designated amount. Under IFRS-IASB, hedge accounting for fair value

macro hedges cannot be applied to core deposits and hedge

ineffectiveness arises whenever the revised estimate of the amount of

cash flows in scheduled time buckets is either more or less than the

original designated amount of that bucket. IFRS-IASB financial information

is prepared by reversing the hedge accounting impacts that are applied

under the EU “carve-out” version of IAS 39. Financial information under

IFRS-IASB accordingly does not take into account the possibility that, had

ING Group applied IFRS-IASB as its primary accounting framework, it might

have applied alternative hedge strategies where those alternative hedge

strategies could have qualified for IFRS-IASB compliant hedge accounting.

These decisions could have resulted in different shareholders’ equity and

net result amounts compared to those indicated in this Annual Report on

Form 20-F.

Other than for the purpose of SEC reporting, ING Group intends to continue

to prepare its Financial Statements under IFRS-EU. A reconciliation

between IFRS-EU and IFRS-IASB for shareholders’ equity and net result is

included in Note 1 ‘Basis of preparation and material accounting policy

information’ to the consolidated financial statements.

In the discussion of ING’s financial performance, ING uses a number of

alternative performance measures, including resilient net profit,

commercial net interest income and net core lending and net core

deposits growth. Resilient net profit is defined as net profit adjusted for

significant items not linked to the normal course of business. ING considers

commercial net interest income, and the derived commercial net interest

margin, to be useful information because the scope is restricted to those

products that are mainly interest driven and excludes the interest on

products where performance measurement is primarily done based on fee

income or at the total income level (including Financial Markets and

Treasury). Commercial net interest income also excludes significant

volatile items in lending and liability net interest income, thus removing

items that distort period-on-period comparisons. Net core lending and net

core deposits growth measures the development of ING’s customer

lending and deposits adjusted for currency impacts and changes in the

Treasury and run-off portfolios. ING considers net core lending and net

core deposits growth as useful information to track ING’s real commercial

growth in customer balances.

For reconciliation of these alternative performance measures to the

nearest IFRS-IASB measures, please refer to Capital Management and Item

5. Operating and Financial Review and Prospects – A. Operating results -

Alternative performance measures.

Certain amounts set forth herein, such as percentages, may not sum due

to rounding.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	7

Cautionary Statement with respect to Forward-looking

Statements

Certain of the statements contained herein are not historical facts,

including, without limitation, certain statements made of future

expectations and other forward-looking statements that are based on

management’s current views and assumptions and involve known and

unknown risks and uncertainties that could cause actual results,

performance or events to differ materially from those expressed or implied

in such statements. Actual results, performance or events may differ

materially from those in such statements due to a number of factors,

including, without limitation:

§changes in general economic conditions and customer behaviour, in

particular economic conditions in ING’s core markets, including changes

affecting currency exchange rates and the regional and global economic

impact of the invasion of Russia into Ukraine and related international

response measures

§changes affecting interest rate levels

§any default of a major market participant and related market disruption

§changes in performance of financial markets, including in Europe and

developing markets

§fiscal uncertainty in Europe and the United States

§discontinuation of or changes in ‘benchmark’ indices

§inflation and deflation in our principal markets

§changes in conditions in the credit and capital markets generally, including

changes in borrower and counterparty creditworthiness

§failures of banks falling under the scope of state compensation schemes

§non-compliance with or changes in laws and regulations, including those

concerning financial services, financial economic crimes and tax laws, and

the interpretation and application thereof

§geopolitical risks, political instabilities and policies and actions of

governmental and regulatory authorities, including in connection with the

invasion of Russia into Ukraine, other existing or emerging military conflicts,

the risk of further military escalation, geopolitical tensions, trade restrictions

and the related international response measures

§legal and regulatory risks in certain countries with less developed legal and

regulatory frameworks

§prudential supervision and regulations, including in relation to stress tests

and regulatory restrictions on dividends and distributions, (also among

members of the group)

§ING’s ability to meet minimum capital and other prudential regulatory

requirements

§changes in regulation of US commodities and derivatives businesses of ING

and its customers

§application of bank recovery and resolution regimes, including write-down

and conversion powers in relation to our securities

§outcome of current and future litigation, enforcement proceedings,

investigations or other regulatory actions, including claims by customers or

stakeholders who feel misled or treated unfairly, and other conduct issues

§changes in tax laws and regulations and risks of non-compliance or

investigation in connection with tax laws, including FATCA

§operational and IT risks, such as system disruptions or failures, breaches of

security, cyber-attacks, human error, changes in operational practices or

inadequate controls including in respect of third parties with which we do

business and including any risks as a result of incomplete, inaccurate, or

otherwise flawed outputs from the algorithms and data sets utilized in

artificial intelligence

§risks and challenges related to cybercrime including the effects of cyber-

attacks and changes in legislation and regulation related to cybersecurity

and data privacy, including such risks and challenges as a consequence of

the use of emerging technologies, such as advanced forms of artificial

intelligence and quantum computing

§changes in general competitive factors, including ability to increase or

maintain market share

§inability to protect our intellectual property and infringement claims by third

parties

§inability of counterparties to meet financial obligations or ability to enforce

rights against such counterparties

§changes in credit ratings

§business, operational, regulatory, reputation, transition and other risks and

challenges in connection with climate change, diversity, equity and

inclusion and other ESG-related matters, including data gathering and

reporting and also including managing the conflicting laws and

requirements of governments, regulators and authorities with respect to

these topics

§inability to attract and retain key personnel

§future liabilities under defined benefit retirement plans

§failure to manage business risks, including in connection with use of models,

use of derivatives, or maintaining appropriate policies and guidelines

§changes in capital and credit markets, including interbank funding, as well

as customer deposits, which provide the liquidity and capital required to

fund our operations, and

§the other risks and uncertainties detailed in the most recent annual report

of ING Groep N.V. (including the Risk Factors contained therein) and ING’s

more recent disclosures, including press releases, which are available on

www.ing.com.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	8

This document may contain ESG-related material that has been prepared

by ING on the basis of publicly available information, internally developed

data and other third-party sources believed to be reliable. ING has not

sought to independently verify information obtained from public and

third-party sources and makes no representations or warranties as to

accuracy, completeness, reasonableness or reliability of such information.

This document may also discuss one or more specific transactions and/or

contain general statements about ING’s ESG approach. The approach and

criteria referred to in this document are intended to be applied in

accordance with applicable law. Due to the fact that there may be

different or even conflicting laws, the approach, criteria or the application

thereof, could be different.

Materiality, as used in the context of ESG, is distinct from, and should not

be confused with, such term as defined in the Market Abuse Regulation or

as defined for Securities and Exchange Commission (‘SEC’) reporting

purposes. Any issues identified as material for purposes of ESG in this

annual report are therefore not necessarily material as defined in the

Market Abuse Regulation or for SEC reporting purposes. In addition, there

is currently no single, globally recognized set of accepted definitions in

assessing whether activities are “green” or “sustainable.” Without limiting

any of the statements contained herein, we make no representation or

warranty as to whether any of our securities constitutes a green or

sustainable security or conforms to present or future investor expectations

or objectives for green or sustainable investing. For information on

characteristics of a security, use of proceeds, a description of applicable

project(s) and/or any other relevant information, please reference the

offering documents for such security.

This annual report contains inactive textual addresses to internet websites

operated by us and third parties. Reference to such websites is made for

information purposes only, and information found at such websites is not

incorporated by reference into this annual report. ING does not make any

representation or warranty with respect to the accuracy or completeness

of, or take any responsibility for, any information found at any websites

operated by third parties. ING specifically disclaims any liability with

respect to any information found at websites operated by third parties.

ING cannot guarantee that websites operated by third parties remain

available following the filing of this annual report or that any information

found at such websites will not change following the filing of this annual

report. Many of those factors are beyond ING’s control.

Any forward-looking statements made by or on behalf of ING speak only

as of the date they are made, and ING assumes no obligation to publicly

update or revise any forward-looking statements, whether as a result of

new information or for any other reason.

This document does not constitute an offer to sell, or a solicitation of an

offer to purchase, any securities in the United States or any other

jurisdiction.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	11

Item 3. Key Information

A. [Reserved]

B. Capitalization and indebtedness

This item does not apply to annual reports on Form 20-F.

C.Reasons for the offer and use of proceeds

This item does not apply to annual reports on Form 20-F.

D. Risk Factors

Summary of Risk factors

The following is a summary of the principal risk factors that could have a

material adverse effect on the reputation, business activities, financial

condition, results and prospects of ING. Please carefully consider all of the

information discussed in this section “Risk Factors” for a detailed

description of these risks.

Risks related to financial conditions, market environment and

general economic trends

§Our revenues and earnings are affected by volatility, regime shifts and

cross-market contagion of the economic, business, liquidity, funding

and capital markets environments of the various geographic regions in

which we conduct business, as well as by changes in customer

behaviour in these regions, and an adverse change in any one region

could have an impact on our business, results and financial condition.

§Inflation and deflation scenarios, as well as interest rate volatility and

changes may adversely affect our business, results and financial

condition.

§The default of a major market participant could disrupt the markets

and may have an adverse effect on our business, results and financial

condition.

§Continued risk of political instability and fiscal uncertainty around the

globe, as well as ongoing volatility in the financial markets and the

economy generally have adversely affected, and may continue to

adversely affect, our business, results and financial condition.

§Market conditions, including those observed over the past few years,

may increase the risk of loans being impaired and have a negative

effect on our results and financial condition.

§Discontinuation of interest rate benchmarks may negatively affect our

business, results and financial condition.

§We may incur losses due to failures of banks falling under the scope of

resolution funding or deposit schemes.

Risks related to the regulation and supervision of the Group

§Non-compliance with laws and/or regulations could result in fines and

other liabilities, penalties or consequences for us, which could

materially affect our business and reputation and reduce our

profitability.

§Changes in laws and/or regulations governing financial services or

financial institutions or the application of such laws and/or regulations

may increase our operating costs and limit our business activities.

§We are subject to additional legal and regulatory risk in certain

countries with less developed or less predictable legal and regulatory

frameworks or the supervision thereof.

§We are subject to the regulatory supervision of the ECB and other

regulators and public bodies with extensive supervisory and

investigatory powers.

§Failure to meet minimum capital and other prudential regulatory

requirements as applicable to us from time to time may have a

material adverse effect on our business, results and financial condition

and on our ability to make payments on certain of our securities.

§Our US commodities and derivatives business is subject to CFTC and SEC

regulation under the Dodd-Frank Act.

§We are subject to the EU recovery and resolution regime and several

other bank recovery and resolution regimes that include statutory

write-down and conversion as well as other powers, which remain

subject to significant uncertainties as to the scope and impact on us.

Risks related to litigation, enforcement proceedings and

investigations and to changes in tax laws

§We may be subject to litigation, enforcement proceedings,

investigations or other regulatory actions, and adverse publicity.

§We are subject to different tax regulations in each of the jurisdictions

where we conduct business, and are exposed to changes in tax laws

and risks of non-compliance resulting in proceedings or investigations

with respect to tax laws.

§Our reputation could be harmed and we could be subject to

enforcement actions, fines and penalties if we fail to comply with our

obligations under tax laws and regulations.

§ING is exposed to the risk of claims from customers or stakeholders

who feel misled or treated unfairly because of advice or information

received.

Risks related to the Group’s business and operations

§ING may be unable to meet evolving expectations or requirements with

respect to ESG-related matters.

§ING may be unable to adapt its products and services to meet

changing customer behaviour and demand, including as a result of

ESG-related matters.

§ING’s business and operations are exposed to transition risks related to

climate change.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	12

§ING’s business and operations are exposed to physical risks, including

as a direct result of climate change.

§Operational and IT risks, such as systems disruptions or failures,

breaches of security, human error, changes in operational practices,

inadequate controls including in respect of third parties with which we

do business or outbreaks of communicable diseases may adversely

impact our reputation, business and results.

§We are subject to increasing risks related to cybercrime and

compliance with cybersecurity regulation.

§Because we operate in highly competitive markets, including our home

market, we may not be able to increase or maintain our market share,

which may have an adverse effect on our results.

§We may not always be able to protect our intellectual property

developed in our products and services and may be subject to

infringement claims, which could adversely impact our core business,

inhibit efforts to monetise our internal innovations and restrict our

ability to capitalise on future opportunities.

§The inability of counterparties to meet their financial obligations or our

inability to fully enforce our rights against counterparties could have a

material adverse effect on our results.

§Ratings are important to our business for a number of reasons, and a

downgrade or a potential downgrade in our credit ratings could have

an adverse impact on our results and net results.

§An inability to retain or attract key personnel may affect our business

and results.

§We may incur further liabilities in respect of our defined benefit

retirement plans if the value of plan assets is not sufficient to cover

potential obligations, including as a result of differences between

actual results and underlying actuarial assumptions and models.

Risks related to the Group’s risk management practices

§Risks relating to our use of quantitative models to model client

behaviour for the purposes of our calculations may adversely impact

our results and reputation.

§We may be unable to manage our risks successfully through

derivatives.

Risks related to the Group’s liquidity and financing activities

§We depend on the capital and credit markets, as well as customer

deposits, to provide the liquidity and capital required to fund our

operations, and adverse conditions in the capital and credit markets, or

significant withdrawals of customer deposits, may negatively impact

our liquidity, borrowing and capital positions, as well as increase the

cost of liquidity, borrowings and capital.

§As a holding company, ING Groep N.V. is dependent for liquidity on

payments from its subsidiaries, many of which are subject to

regulatory and other restrictions on their ability to transact with

affiliates.

Additional risks relating to ownership of ING shares

§Holders of ING shares may experience dilution of their holdings and

may be impacted by any share buyback programme.

§Because we are incorporated under the laws of the Netherlands and

many of the members of our Supervisory and Executive Boards and our

officers reside outside of the United States, it may be difficult to

enforce judgements of US courts against ING or the members of our

Supervisory Board and Executive Board or our officers.

Risk factors

Any of the risks described below could have a material adverse effect on

the business activities, financial condition, results and prospects of ING as

well as ING’s reputation. ING may face a number of the risks described

below simultaneously and some risks described below may be

interdependent. While the risk factors below have been divided into

categories, some risk factors could belong in more than one category and

investors should carefully consider all of the risk factors set out in this

section. Additional risks of which the Company is not presently aware, or

that are currently viewed as immaterial, could also affect the business

operations of ING and have a material adverse effect on ING’s business

activities, financial condition, results and prospects. The market price of

ING shares or other securities could decline due to any of those risks

including the risks described below, and investors could lose all or part of

their investments.

Although the risk factors that ING currently believes to be most material

have been presented first within each category, the order in which the risk

factors are presented is not necessarily an indication of the likelihood of

the risks actually materialising, of the potential significance of the risks or

of the scope of any potential negative impact to our business, results,

financial condition and prospects.

Risks related to financial conditions, market environment and

general economic trends

Our revenues and earnings are affected by volatility, regime shifts and

cross-market contagion of the economic, business, liquidity, funding and

capital markets environments of the various geographic regions in which

we conduct business, as well as by changes in customer behaviour in

these regions, and an adverse change in any one region could have an

impact on our business, results and financial condition.

Because ING is a multinational banking and financial services corporation,

with a global presence and serving 40 million customers, corporate clients

and financial institutions in 38 countries, ING’s business, results and

financial condition may be significantly impacted by turmoil and volatility

in the worldwide financial markets or in the particular geographic areas in

which we operate. In Retail Banking, our products include savings,

payments, investments, loans and mortgages. In Wholesale Banking, we

provide specialised lending, tailored corporate finance, debt and equity

market solutions, payments & cash management, trade and treasury

services. Negative developments in relevant financial markets and/or

countries or regions have in the past had and may in the future have a

material adverse impact on our business, results and financial condition,

including as a result of the potential consequences listed below.

Factors such as inflation or deflation, interest rates, government spending,

geopolitical events and trends, supply chain disruptions, shortages,

terrorism, pandemics and epidemics (such as Covid-19 pandemic) or other

widespread health emergencies, securities prices, the volatility and


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	13

strength of the capital markets, exchange rates, credit spreads, liquidity

spreads, real estate values and private equity valuations, consumer

spending, business investment, changes in customer behaviour and

climate change, all impact the business and economic environment and,

ultimately, our solvency, liquidity and the amount and profitability of

business we conduct in a specific geographic region. Some of these risks

are often experienced globally as well as in specific geographic regions and

are described in greater detail below under the headings: ‘Inflation and

deflation scenarios, as well as interest rate volatility and changes may

adversely affect our business, results and financial condition'; 'Market

conditions, including those observed over the past few years may increase

the risk of loans being impaired and have a negative effect on our results

and financial condition'; and 'Continued risk of political instability and fiscal

uncertainty, as well as ongoing volatility in the financial markets and the

economy generally have affected, and may adversely affect, our business,

results and financial condition'. All of these are factors in local and regional

economies as well as in the global economy, and we may be affected by

changes in any one of these factors in any one country or region, and

more if more of these factors occur simultaneously and/or in multiple

countries or regions or on a global scale.

In case one or more of the factors mentioned above adversely affects the

profitability of our business, this might also result, among other things, in

the following:

§Inadequate reserves or provisions, in relation to which losses could

ultimately be realised through profit and loss and shareholders’ equity;

§The write-down of tax assets impacting net results and/or equity;

§Impairment expenses related to goodwill and other intangible assets,

impacting our net result and equity; and/or

§Movements in risk-weighted assets for the determination of required

capital.

In particular, we are exposed to financial, economic, market and political

conditions in the Benelux countries and Germany, from which we derive a

significant portion of our revenues in both Retail Banking and Wholesale

Banking, and which could present risks of economic downturn. Though less

material, we also derive substantial revenues in the following geographic

regions: United States, Türkiye, Poland and the remainder of Eastern

Europe, Southern Europe, East Asia and Australia. In an economic

downturn affecting some or all of these jurisdictions, we expect that higher

unemployment, lower family income, lower corporate earnings, higher

corporate and private debt defaults, lower business investments and lower

consumer spending would adversely affect the demand for banking

products, and that ING may need to increase its reserves and provisions,

each of which may result in overall lower earnings. Securities prices, real

estate values and private equity valuations may also be adversely

impacted, and any such losses would be realised through profit and loss

and shareholders’ equity. We also offer a number of financial products

that expose us to risks associated with fluctuations in interest rates,

securities prices, corporate and private default rates, the value of real

estate assets, exchange rates and credit spreads. As a result, their impact

may continue to affect our business. We also have wholesale banking

activities in both Russia and Ukraine, as well as investments in Russia,

some of which are denominated in local currency. In response to Russia’s

invasion of Ukraine, the international community imposed various punitive

measures, including sanctions, capital controls, restrictions on SWIFT

access and restrictions on central bank activity. These measures and

Russia’s response thereto have significantly impacted, and may continue

to significantly impact, Russia’s economy, our activities in Russia and our

activities involving Russian-owned parties. They have contributed to

heightened instability in global markets and increased inflation due in part

to supply chain constraints, as well as continued volatile and periodic

elevation of energy and commodity prices. Should prices remain elevated

for an extended period, most businesses and households would be

negatively impacted, and our business in Russia and Ukraine, as well as

our broader business, may be adversely affected, including through spill-

over risk to the entire wholesale banking portfolio (e.g. commodities

financing, energy and utilities and energy-consuming clients).

On 28 January 2025, ING announced its intention to sell its business in

Russia to a third party. As the buyer has not received all necessary

approvals, ING has been unable to complete the deal within the expected

timeframe. There is no guarantee that any such approvals will be received,

or any certainty as to the timing or occurrence of closing of the proposed

transaction, or the ultimate divestment of ING’s business in Russia.

Environmental and/or climate risks have also directly and indirectly

impacted ING without significant financial impact, for example through,

among other things, losses suffered as a result of extreme weather events,

the impact of climate-related transition risk on the risk and return profile

or value of security or operations of certain categories of customer to

which ING has exposure. In addition, these risks may also increase ING’s

reputational and litigation risk if the economic activity that ING supports is

not in line with community expectations or ING’s external commitments or

legal or regulatory requirements (this includes, but is not limited to,

greenwashing risk).

For more information on ING’s exposure to particular geographic areas,

see Note 31 ‘Information on geographical areas’ to the consolidated

financial statements.

Inflation and deflation scenarios, as well as interest rate volatility and

changes may adversely affect our business, results and financial

condition.

In general, both inflation and deflation may influence consumers’

spending habits, affecting the economic activity and consequently our

core revenue stream (e.g. in terms of overall financial health of borrowers

and loan demand, and collateral management, among other things).

Furthermore, inflation and deflation may have repercussions on interest

rate spreads, and therefore on the profitability of traditional banking

activities. Overall, both inflation and deflation can pose significant

challenges, impacting our ability to generate revenue, manage risk, and

maintain a stable financial position.

Furthermore, a significant and sustained increase in inflation has

historically also been associated with decreased prices for equity securities

and sluggish performance of equity markets generally. A sustained decline

in equity markets may:

§result in impairment charges to equity securities that we hold in our

investment portfolios and reduced levels of unrealised capital gains

available to us which would reduce our net income; and

§lower the value of our equity investments impacting our capital

position.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	14

Central banks continue to adopt a cautious stance in response to

persistent inflationary pressures, moderate economic growth, and

elevated geopolitical risks. With EU inflation converging toward the 2%

target and expected to remain near this level over the medium term,

markets anticipate stable interest rates through 2026.

Changes in interest rates may impact our business. In case of increased

interest rates, we may:

§experience a decrease of the estimated fair value of certain fixed

income securities that we hold in our investment portfolios, resulting in:

–reduced levels of unrealised capital gains available to us, which

could negatively impact our solvency position and net income, and/

–a decrease in collateral values;

§face an increased withdrawal of certain savings products, particularly

those with fixed rates below market rates;

§be required, as an issuer of securities, to pay higher interest rates on

debt securities that we issue in the financial markets from time to time

to finance our operations, which would increase our interest expenses

and reduce our results;

§experience further customer defaults as interest rate rises flow through

into payment stress for lower credit quality customers.

On the other hand, a decrease in prevailing interest rates may lead to

lower interest income from loans and investments, reduced profitability of

traditional banking activities, and potential declines in the value of certain

fixed income securities we hold in our investment portfolio, as well as

negatively affecting our business in other ways, including leading to:

§compress in the net interest income margins because of a potential

reduction in the interest income earned from loans;

§lower earnings over time on investments, as reinvestments will earn

lower rates;

§increased prepayment or redemption of mortgages and fixed maturity

securities in our investment portfolios, as well as increased

prepayments of corporate loans. This as borrowers seek to borrow at

lower interest rates potentially combined with lower credit spreads.

Consequently, we may be required to reinvest the proceeds into assets

at lower interest rates;

§lower profitability as the result of a decrease in the spread between

client rates earned on assets and client rates paid on savings, current

account and other liabilities;

§higher costs for certain derivative instruments that may be used to

hedge certain of our product risks;

§lower profitability since we may not be able to fully track the decline in

interest rates in our savings rates;

§lower profitability since we may not always be entitled to impose

surcharges to customers to compensate for the decline in interest

rates;

§lower profitability since we may have to pay a higher premium for the

defined contribution scheme in the Netherlands for which the premium

paid is dependent on interest rate developments and the Dutch Central

Bank’s (DNB) methodology for determining the ultimate forward rate;

§lower interest rates that may cause asset margins to decrease, thereby

lowering our results. This may, for example, be the consequence of

increased competition for investments as result of the low rates,

thereby driving margins down; and/or

§(depending on the position) a significant collateral posting requirement

associated with our interest rate hedge programs, which could

materially and adversely affect liquidity and our profitability.

In addition, given the volatility in inflation and related volatility in interest

rates, a failure to accurately anticipate inflation on an ongoing basis and

factor it into our product pricing assumptions may result in the mispricing

of our products, which could materially and adversely impact our results.

Each of the preceding risks, should they materialise, may adversely affect

our business, results and financial condition.

The default of a major market participant could disrupt the markets and

may have an adverse effect on our business, results and financial

condition.

Within the financial services industry, the severe distress or default of any

one institution (including sovereigns and central counterparties (CCPs))

could lead to defaults by, or the severe distress of, other market

participants. While prudential regulation may reduce the probability of a

default by a major financial institution, the actual occurrence of such a

default could have a material adverse impact on ING. Such distress of, or

default by, a major financial institution could disrupt markets or clearance

and settlement systems and lead to a chain of defaults by other financial

institutions, since the commercial and financial soundness of many

financial institutions may be closely related as a result of credit, trading,

clearing or other relationships. Also, the perceived lack of creditworthiness

of a sovereign or a major financial institution (or a default by any such

entity) may lead to market-wide liquidity problems and losses or defaults

by us or by other institutions. This risk is also referred to as ‘systemic risk’

and may adversely affect financial intermediaries, such as clearing

agencies, clearing houses, banks, securities firms and exchanges with

whom we interact on a daily basis, and financial instruments of sovereigns

in which we invest. Systemic risk could impact ING directly, by exposing it

to material credit losses on transactions with defaulting counterparties or

indirectly by significantly reducing the available market liquidity on which

ING and its lending customers depend to fund their operations and/or

leading to a write-down of loans or securities held by ING. In addition, ING

may also be faced with additional open market risk for which hedging or

mitigation strategies may not be available or effective (either by hedges

eliminated by defaulting counterparties, or reduced market liquidity).

Systemic risk could have a material adverse effect on our ability to raise

new funding and on our business, results and financial condition. In

addition, such distress or failure could impact future product sales as a

potential result of reduced confidence in the financial services industry.

Continued risk of political instability and fiscal uncertainty around the

globe, as well as ongoing volatility in the financial markets and the

economy generally have adversely affected, and may continue to

adversely affect, our business, results and financial condition.

Our global business and results are materially affected by conditions in the

global capital markets and the economy generally. In Europe, there are

continuing concerns over weaker economic conditions, levels of

unemployment in certain countries, as well as geopolitical developments,

including tariffs or other trade barriers introduced by the United States and

responses to those trade barriers, the availability and cost of credit, as well

as credit spreads. In addition, geopolitical issues, including military

conflicts, the risk of further military escalation, trade tensions between

major economies, increasing protectionism between key countries, and


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	15

issues with respect to North Korea and the Middle East, may all contribute

to adverse developments in the global capital markets and the economy

generally. Sustained uncertainty about, or worsening of, current global

economic conditions and further escalation of trade tensions between the

US and its trading partners, especially China, could result in a global

economic slowdown and long-term changes to global trade. In particular,

Russia’s invasion of Ukraine, the conflict in the Middle East and other

existing or emerging military conflicts, as well as the risk that such

conflicts could escalate or widen, and related international response

measures have had, and are expected to continue to have, a negative

impact on regional and global economic conditions, including heightened

instability in global markets and increased inflation due in part to supply

chain constraints, as well as higher energy and commodity prices. Should

prices remain elevated for an extended period, most businesses and

households would be negatively impacted, and our business in Russia and

Ukraine, as well as our broader business, may be adversely affected,

including through spill-over risk to our entire Wholesale Banking portfolio,

in areas such as commodities financing, energy and utilities and energy-

consuming clients

Moreover, there is a risk that an adverse credit event at one or more

European sovereign debtors (including a credit rating downgrade, such as

that experienced by France in 2025, or a default) could trigger a broader

economic downturn in Europe and elsewhere. In addition, the confluence

of these and other factors has resulted in volatile foreign exchange

markets. International equity markets have also continued to experience

heightened volatility and turmoil. These events, market upheavals and

continuing risks, including high levels of volatility, may have an adverse

effect on our results, in part because we have a large investment portfolio.

There is also continued uncertainty over the long-term outlook for the tax,

spending and borrowing policies of the US, the future economic

performance of the US within the global economy and any potential future

budgetary restrictions in the US, with a potential impact on a future

sovereign credit ratings downgrade of the US government, including the

rating of US Treasury securities. A downgrade of US Treasury securities

could also impact the ratings and perceived creditworthiness of

instruments issued, insured or guaranteed by institutions, agencies or

instrumentalities directly linked to the US government. US Treasury

securities and other US government-linked securities are key assets on the

balance sheets of many financial institutions and are widely used as

collateral by financial institutions to meet their day-to-day cash flows in

the short-term debt market. The impact of any further downgrades to the

sovereign credit rating of the US government or a default by the US

government on its debt obligations would create broader financial turmoil

and uncertainty, which would weigh heavily on the global financial system

and could consequently result in a significant adverse impact to the

Group’s business and operations.

In many cases, the markets for investments and instruments have been

and remain illiquid, and issues relating to counterparty credit ratings and

other factors have exacerbated pricing and valuation uncertainties.

Valuation of such investments and instruments is a complex process

involving the consideration of market transactions, pricing models,

management judgement and other factors, and is also impacted by

external factors, such as underlying mortgage default rates, interest rates,

rating agency actions and property valuations. Historically these factors

have resulted in, among other things, valuation and impairment issues in

connection with our exposures to European sovereign debt and other

investments.

Any of these general developments in global financial and political

conditions could negatively impact our business, results and financial

condition in future periods.

Discontinuation of interest rate benchmarks may negatively affect our

business, results and financial condition.

Changes to major interest rate benchmarks may adversely affect our

business, including net interest revenue. Historically, financial markets

relied on Interbank Offered Rates (IBORs) such as LIBOR, EONIA, CDOR, and

EURIBOR. While some benchmarks like EURIBOR have been reformed and

remain in use, others such as EONIA, CDOR, and LIBOR have been

discontinued and replaced by alternative rates.

In Poland, the National Working Group has established a roadmap to

replace WIBOR with POLSTR (Polish Short-Term Rate), a risk-free overnight

benchmark based on actual transactions. POLSTR was selected in

December 2024 and began publication in June 2025, including

compounded 1-, 3-, and 6-month versions. Treasury bonds referencing

POLSTR were launched in late 2025, with broader adoption in loans and

mortgages expected in 2026. Full transition and WIBOR phase-out are

anticipated by the end of 2027

The discontinuation of benchmarks and adoption of new rates may create

legal, operational, and financial risks, including documentation changes,

conduct risks, and potential earnings volatility from contract modifications

and hedge accounting adjustments.

ING continues to monitor market developments and reform plans for other

rates to anticipate the impact on our customers and any related risks.

Market conditions, including those observed over the past few years,

may increase the risk of loans being impaired and have a negative effect

on our results and financial condition.

We are exposed to the risk that our borrowers (including sovereigns) may

not repay their loans according to their contractual terms and that the

collateral securing the payment of these loans may be insufficient. We

may see adverse changes in the credit quality of our borrowers and

counterparties, for example, as a result of their inability to refinance their

indebtedness or in the case of a decline in financial performance. Adverse

changes in the credit quality of our borrowers and/or decreasing collateral

values would result in increased capital requirements and provisions, and

any deterioration of market conditions may lead to increasing

delinquencies, defaults and insolvencies across a range of sectors. This

may lead to impairment charges on loans and other assets, higher costs

and additions to loan loss provisions. A significant increase in the size of

our provision for loan losses could have a material adverse effect on our

business, results and financial condition.

ING manages concentration risk through a comprehensive framework of

limits on single names, countries, and sectors, supported by regular

monitoring and portfolio steering to ensure exposures remain within its

risk appetite. If we are significantly exposed to a concentrated set of

customers or counterparties, an adverse event affecting these parties


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	16

could lead to increased losses for the Group, and adversely affect our

business, results and financial condition.

We may incur losses due to failures of banks falling under the scope of

resolution funding or deposit schemes.

While prudential regulation is intended to minimise the risk of bank

failures, in the event such a failure occurs, given our size, we may incur

significant compensation payments to be made under the Dutch Deposit

Guarantee Scheme (DGS), which we may be unable to recover from the

bankrupt estate, and therefore the consequences of any future failure of

such a bank could be significant to ING. Such costs and the associated

costs to be borne by us may have a material adverse effect on our results

and financial condition. On the basis of the EU Directive on deposit

guarantee schemes, ING pays quarterly risk-weighted contributions into a

DGS-fund. The Dutch DGS-fund reached its intended target size of 0.8

percent of all deposits guaranteed under the DGS, in July 2024. Further,

quarterly risk-weighted contributions are only required when individual

and / or collective covered deposits show an increase in a quarter. In case

of failure of a Dutch bank, depositor compensation is paid from the DGS-

fund. If the available financial means of the fund are insufficient, Dutch

banks, including ING, may be required to pay extraordinary ex-post

contributions not exceeding 0.5 percent of their covered deposits per

calendar year. In exceptional circumstances, and with the consent of the

competent authority, higher contributions may be required. However,

extraordinary ex-post contributions may be temporarily deferred if, and

for so long as, they would jeopardise the solvency or liquidity of a bank.

Depending on the size of the failed bank, the available financial means in

the DGS-fund, and the required additional financial means, the impact of

the extraordinary ex-post contributions on ING may be material.

Since 2015, the EU has been discussing the introduction of a pan-European

deposit guarantee scheme (EDIS), which would (partly) replace or

complement national compensation schemes. As of the date of this

report, negotiations regarding EDIS have stalled and no such scheme has

been introduced.

On 18 April 2023, the European Commission published its proposals for the

revision of the common framework for bank crisis management and

deposit insurance (CMDI) that focuses on small and medium-sized banks,

but will affect banks in the EU. The CMDI framework consists of the Bank

Recovery and Resolution Directive (BRRD), the Single Resolution

Mechanism Regulation (SRMR) and the Deposit Guarantee Schemes

Directive (DGSD). The European Parliament adopted its first-reading reports

on the proposals in April 2024. The Council agreed on a negotiating

mandate for the revision of the CMDI on 19 June 2024. With this

agreement, the Council is ready to negotiate with the European

Parliament on the final form of this legislative proposal. On 25 June 2025,

the Council and the European Parliament reached a political agreement on

the reformed CMDI framework. The co-legislators are now expected to

finalise the legal text, after which the revised framework is expected to be

formally adopted and enter into force. The revision of the CMDI framework

is part of the debate on the completion of the Banking Union and in

particular its third and missing pillar EDIS.

Risks related to the regulation and supervision of the Group

Non-compliance with laws and/or regulations could result in fines and

other liabilities, penalties or consequences for us, which could materially

affect our business and reputation and reduce our profitability.

ING has faced, and in the future may continue to face, the consequences

of non-compliance with applicable laws and regulations, including the

potential initiation of regulatory investigations or legal proceedings. For

additional information on legal proceedings, see Note 42 ‘Legal

proceedings’ in the consolidated financial statements. There are potential

risks in areas where applicable regulations may be unclear, subject to

multiple interpretations or under development; where regulations may

conflict with one another; or where regulators revise their previous

guidance or courts overturn previous rulings. These could result in our

failure to comply with applicable standards. Regulators and other

authorities have the power to initiate investigations and/or administrative

or judicial proceedings against us, which may result, among other things,

in suspension or revocation of our licences, cease and desist orders, fines,

civil penalties, criminal penalties or other disciplinary measures, which

could materially harm our results and financial condition as well as ING’s

reputation. If we fail, or appear to fail to properly address, any of these

matters, our reputation may be harmed and we may be exposed to

additional legal risk, which in turn may increase the size and number of

claims and damages brought against us or subject us to enforcement

actions, fines and penalties.

Furthermore, as a financial institution, we are exposed to the risk of

unintentional involvement in criminal activity in connection with financial

economic crimes, including the circumvention of sanctions, money

laundering and the funding of terrorist and other criminal activities. The

failure or perceived failure by us to comply with legal and regulatory

requirements with respect to financial economic crimes may result in

adverse publicity, claims and allegations, litigation and regulatory

investigations and sanctions, which may have a material adverse effect on

our business, results, financial condition and/or prospects in any given

period. For further information on the impact of litigation, enforcement

proceedings, investigations or other regulatory actions with respect to

financial economic crimes, see 'We may be subject to litigation,

enforcement proceedings, investigations or other regulatory actions, and

adverse publicity' below.

Changes in laws and/or regulations governing financial services or

financial institutions or the application of such laws and/or regulations

may increase our operating costs and limit our business activities.

We are subject to detailed banking laws and financial regulations in the

jurisdictions in which we conduct business. The regulations governing the

industries in which we operate have become more extensive and complex,

while also attracting supervisory scrutiny. Compliance with current and

new laws and regulations is resource-intensive and may materially

increase our operating costs. Moreover, these regulations are designed to

protect our customers, markets and society as a whole and can limit or

redirect our activities, among others, through stricter net capital, market

conduct and transparency requirements and restrictions on the businesses

in which we can operate or invest.

Our revenues and profitability and those of our industry have been and

continue to be affected by requirements relating to capital, additional loss-

absorbing capacity, leverage, minimum liquidity and long-term funding

levels, resolution and recovery planning requirements, derivatives clearing

and margin rules and levels of regulatory oversight, as well as restrictions


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	17

on which and, if permitted, how certain business activities may be carried

out by financial institutions.

We are subject to additional legal and regulatory risk in certain

countries with less developed or less predictable legal and regulatory

frameworks or the supervision thereof.

In certain countries where we operate or where our clients reside, judicial

and dispute resolution systems may be less effective. As a result, in the

event of a breach of contract, we have experienced in the past and may

continue to have difficulties in making and enforcing claims against

contractual counterparties and, if claims are made against us, we have

experienced in the past and may continue to encounter difficulties in

mounting a defence against such allegations. If we become party to legal

proceedings in a market with an insufficiently developed judicial system, it

could have an adverse effect on our operations and net results. For

additional information on legal proceedings, see Note 42 ‘Legal

proceedings’ in the consolidated financial statements.

In addition, as a result of our operations in certain countries, we are

subject to risks of possible nationalisation, expropriation, price controls,

exchange controls and other restrictive government actions, as well as the

outbreak of hostilities and/or war, in these markets. In particular, we have

wholesale banking activities in both Russia and Ukraine, as well as

investments in Russia, some of which are denominated in local currency.

Furthermore, the current economic environment in certain countries in

which we operate may increase the likelihood for regulatory initiatives to

enhance consumer protection or to protect homeowners from

foreclosures. Any such regulatory initiative could have an adverse impact

on our ability to protect our economic interest, for instance in the event of

defaults on residential mortgages.

We are subject to the regulatory supervision of the ECB and other

regulators and public bodies with extensive supervisory and

investigatory powers.

In its capacity as the principal prudential supervisor in the EU, the ECB has

extensive supervisory and investigatory powers, including the ability to

issue requests for information, to conduct regulatory investigations and

on-site inspections, and impose monetary and other sanctions. For

example, under the Single Supervisory Mechanism (SSM), the relevant

(national) competent authorities, including the ECB, can conduct stress

tests and have the discretionary power to impose capital surcharges on

financial institutions for risks not otherwise recognised in risk-weighted

assets or other surcharges depending on the individual situation of the

bank, and take or require other measures, such as restrictions on or

changes to the Group’s business. Competent authorities may also prohibit

the Group from making dividend payments to shareholders or distributions

to holders of its regulatory capital instruments if the Group fails to comply

with regulatory requirements, in particular with regard to supervisory

measures, minimum capital requirements (including buffer requirements)

or with liquidity requirements, or if there are deficiencies in its governance

and risk management processes. A perceived failure to comply with

prudential or conduct regulations may have a material adverse effect on

the Group’s business, results and financial condition.

Failure to meet minimum capital and other prudential regulatory

requirements as applicable to us from time to time may have a material

adverse effect on our business, results and financial condition and on

our ability to make payments on certain of our securities.

ING is subject to a variety of regulations that require us to comply with

minimum requirements for capital (own funds) and additional loss-

absorbing capacity, as well as for liquidity, and to comply with leverage

restrictions. In addition, such capital, liquidity and leverage requirements

and their application and interpretation may change. Any changes may

require us to maintain more capital or to raise a different type of capital by

disqualifying existing capital instruments from continued inclusion in

regulatory capital, requiring replacement with new capital instruments

that meet the new criteria. Sometimes changes are introduced subject to

a transitional period during which the new requirements are being phased

in, gradually progressing to a fully phased-in, or fully-loaded, application of

the requirements.

Any failure to comply with these requirements, or to adapt to changes in

such requirements, may have a material adverse effect on our business,

results and financial condition, and may require us to seek additional

capital. Failures to meet minimum capital or other prudential

requirements may also result in ING being prohibited from making

payments on certain of our securities. Because implementation phases

and transposition into EU or national regulation where required may often

involve a lengthy period, the impact of changes in capital, liquidity and

leverage regulations on our business, results and financial condition, and

on our ability to make payments on certain of our securities, is often

unclear.

Our US commodities and derivatives business is subject to CFTC and SEC

regulation under the Dodd-Frank Act.

Our affiliate ING Capital Markets LLC is registered with the Commodity

Futures Trading Commission (CFTC) as a swap dealer and is subject to CFTC

regulation pursuant to Title VII of the US Dodd-Frank Wall Street Reform

and Consumer Protection Act (Dodd-Frank). Operating as a swap dealer

requires compliance with CFTC regulatory requirements, which may be

burdensome, impose additional compliance costs and could adversely

affect the profitability of this business, as well as exposing ING to the risk of

non-compliance with these regulations.

ING Capital Markets LLC is also registered with the SEC as a security-based

swap dealer. Operating as a security-based swap dealer requires

compliance with SEC regulatory requirements, which may be burdensome,

impose additional compliance costs and could adversely affect the

profitability of this business, as well as exposing ING to the risk of non-

compliance with these regulations. While most of these SEC requirements

apply to ING Capital Markets LLC, in addition to its CFTC swap dealer

requirements, SEC rules have permitted an Alternative Compliance

Mechanism that allows for compliance, subject to eligibility requirements,

with CFTC capital and margin rules applying to swap dealers in lieu of SEC

capital and margin rules applying to security-based swap dealers. ING

Capital Markets LLC has elected to use the Alternative Compliance

Mechanism. However, should ING Capital Markets LLC in the future be

ineligible for the Alternative Compliance Mechanism, it would be subject to

SEC security-based swap dealer rules for margin, capital, and related

financial reporting instead of the CFTC swap dealer rules which could be

more capital- intensive.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	18

Any of the foregoing factors, and any further regulatory developments

with respect to commodities and derivatives, could have a material impact

on our business, results and financial condition.

We are subject to the EU recovery and resolution regime and several

other bank recovery and resolution regimes that include statutory write-

down and conversion as well as other powers, which remains subject to

significant uncertainties as to scope and impact on us.

We are subject to several recovery and resolution regimes, including the

Single Resolution Mechanism (SRM) and the Bank Recovery and Resolution

Directive (BRRD) as implemented in national legislation such as the Dutch

Financial Supervision Act. The SRM applies to banks that are supervised by

the ECB under the SSM, with the aim of ensuring an orderly resolution of

failing banks at minimum cost for taxpayers and the real economy. The

BRRD establishes a common framework for the recovery and resolution of

banks within the European Union, with the aim of providing supervisory

authorities and resolution authorities with common tools and powers to

address banking crises pre-emptively to safeguard financial stability and

minimise taxpayers’ exposure to losses. Any application of statutory write-

down and conversion or other powers would not be expected to constitute

an event of default under our securities entitling holders to seek

repayment. If any of these powers were to be exercised in respect of ING,

there could be a material adverse effect on both ING and on holders of ING

securities, including through a material adverse effect on credit ratings

and/or the price of our securities. Investors in our securities may lose their

investment if resolution measures are taken under current or future

regimes.

Risks related to litigation, enforcement proceedings and

investigations and to changes in tax laws

We may be subject to litigation, enforcement proceedings,

investigations or other regulatory actions, and adverse publicity.

We are involved in governmental, regulatory, arbitration and legal

proceedings and investigations involving claims by and against us which

arise in the ordinary course of our businesses, including in connection with

our activities as financial services provider, employer, investor and

taxpayer. As a financial institution, we are subject to specific laws and

regulations governing financial services and/or financial institutions. See

'Changes in laws and/or regulations governing financial services or

financial institutions or the application of such laws and/or regulations

may increase our operating costs and limit our activities' and 'Our US

commodities and derivatives business is subject to CFTC and SEC

regulation under the Dodd-Frank Act' above. Financial reporting

irregularities involving other large and well-known companies, possible

findings of government authorities in various jurisdictions which are

investigating several processes, notifications made by whistleblowers,

increasing regulatory and law enforcement scrutiny of ‘know your

customer’ anti-money laundering regulations, tax evasion, prohibited

transactions with countries or persons subject to sanctions, and bribery or

other anti-corruption measures and anti-terrorist-financing procedures

and their effectiveness, regulatory investigations of the banking industry,

and litigation that arises from the failure or perceived failure by us to

comply with legal, regulatory, tax and compliance requirements could

result in adverse publicity and reputational harm. Such developments

could lead to increased regulatory supervision, affect our ability to attract

and retain customers and employees and maintain access to the capital

markets, result in cease and desist orders, claims, enforcement actions,

fines and civil and criminal penalties, other disciplinary action or have

other material adverse effects on us in ways that are not predictable. With

respect to sanctions, Russia’s continued occupation of Ukraine and the

associated conflict has seen successive significant sanctions packages

imposed and continued focus of the EU, US, and other governments on the

potential circumvention of sanctions against Russia, and the roles of third

countries and companies in facilitating the circumvention or undermining

of such sanctions' measures. The EU’s additional measures combating

sanctions circumvention has led to focus on several locations as potential

diversion hubs. While various sanctions include grace periods before full

compliance is required, there is no guarantee that ING will be able to

implement all required procedures within the applicable grace periods. In

addition, some claims and allegations may be brought by or on behalf of a

class and claimants may seek large or indeterminate amounts of

damages, including compensatory, liquidated, treble and punitive

damages. Our reserves for litigation liabilities may prove to be inadequate.

Claims and allegations, should they become public, need not be well

founded, true or successful to have a negative impact on our reputation. In

addition, press reports and other public statements that assert some form

of wrongdoing could result in inquiries or investigations by regulators,

legislators and law enforcement officials, and responding to these inquiries

and investigations, regardless of their ultimate outcome, is time

consuming and expensive. Adverse publicity claims and allegations,

litigation and regulatory investigations and sanctions have had in the past

and may continue to have in the future a material adverse effect on our

business, results, financial condition and/or prospects.

We are subject to different tax regulations in each of the jurisdictions

where we conduct business, and are exposed to changes in tax laws and

risks of non-compliance resulting in proceedings or investigations with

respect to tax laws.

Changes in tax laws (including case law) and tax treaties (including the

termination thereof) could increase our taxes and our effective tax rates

and could materially impact our tax receivables and liabilities as well as

deferred tax assets and deferred tax liabilities, which could have a material

adverse effect on our business, results and financial condition. Changes in

tax laws could also make certain ING products less attractive, which could

have adverse consequences for our businesses and results.

Because of the geographic spread of its business, ING may be subject to

tax audits, investigations and procedures in numerous jurisdictions at any

point in time. Although we believe that we have adequately provided for

all our tax positions, the ultimate resolution of these audits, investigations

and procedures may result in liabilities which are different from the

amounts recognised. In addition, increased bank taxes in countries where

the Group is active result in increased taxes on ING’s banking operations,

which could negatively impact our operations, financial condition and

liquidity.

Our reputation could be harmed and we could be subject to enforcement

actions, fines and penalties if we fail to comply with our obligations

under tax laws and regulations.

Due to the nature of its business, ING is subject to various provisions of EU,

US, and other local tax laws in relation to its customers. These include,

amongst others, the Foreign Account Tax Compliance Act (FATCA), which

requires ING to provide certain information for the US Internal Revenue


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	19

Service (IRS); the Qualified Intermediary (QI) requirements, which require

withholding tax on certain US-source payments; and the Common

Reporting Standards (CRS) which requires ING to provide certain

information to local tax authorities. Failure to comply with these

requirements and regulations could harm our reputation and could subject

the Group to enforcement actions, fines and penalties, which could have a

material adverse effect on our business, reputation, revenues, results,

financial condition and prospects.

ING is exposed to the risk of claims from customers or stakeholders who

feel misled or treated unfairly because of advice or information

received.

Our products and services, including banking products and advice services

for third-party products are exposed to claims from customers who might

allege that they have received insufficient advice or misleading

information from advisers (both internal and external) as to which

products were most appropriate for them, or that the terms and

conditions of the products, the nature of the products or the

circumstances under which the products were sold, were misrepresented

to them. When new financial products are brought to the market, it is

ING’s policy to engage in a multidisciplinary product approval process in

connection with the development and distribution of such products,

including production of appropriate marketing and communication

materials. Notwithstanding these processes, customers have made in the

past and may continue to make in the future claims against ING if the

products do not meet their expectations, either at the purchase/execution

of the product and/or through the life of the product. Customer protection

regulations, as well as changes in interpretation and perception by both

the public at large and governmental authorities of acceptable market

practices, influence customer expectations.

Products distributed through person-to-person sales forces have a higher

exposure to such claims as the sales forces may provide face-to-face

financial planning and advisory services. Complaints may also arise if

customers feel that they have not been treated reasonably or fairly, or

that the duty of care has not been complied with. While a considerable

amount of time and resources have been invested in reviewing and

assessing historical sales practices and products that were sold in the past,

and in the maintenance of risk management, legal and compliance

procedures to monitor current sales practices, there can be no assurance

that all of the issues associated with current and historical sales practices

have been or will be identified, nor that any issues already identified will

not be more widespread than presently estimated.

The negative publicity associated with any sales practices, any

compensation payable in respect of any such issues and regulatory

changes resulting from such issues, have had and could have a material

adverse effect on our reputation, business, results, financial condition and

prospects. For additional information regarding legal proceedings or

claims, see Note 42 ‘Legal proceedings’ to the consolidated financial

statements.

Risks related to the Group’s business and operations

ING may be unable to meet evolving expectations or requirements with

respect to ESG-related matters.

Environmental, Social and Governance (ESG) is an area of significant and

increased public dialogue and focus for governments and regulators,

investors, ING’s customers and employees, and other stakeholders or third

parties (e.g. non-governmental organisations or NGOs). As a result, an

increasing number of laws, regulations and legislative actions have been

introduced to address ESG-related matters, including in relation to the

financial sector’s operations and strategy. Such ESG-related matters may

relate to climate change, sustainability, diversity, equity and inclusion (DEI)

or other ESG-related matters. Such recent regulations include the EU

Sustainable Finance Disclosure Regulation (SFDR), EU Taxonomy regulation

and EU Green Bond Standards, which broadly focus on disclosure

obligations, standardised definitions and classification frameworks for

environmentally sustainable activities, and the EU Corporate Sustainability

Reporting Directive (CSRD), which requires certain companies, including

ING, to disclose information on what they see as the risks and

opportunities arising from environmental, social and governance issues,

and on the impact of their activities on people and the environment.

Similarly, the State of California’s legislation requires broad disclosure of

greenhouse gas emissions and other climate-related information.

National or international regulatory actions or developments may also

result in financial institutions coming under increased pressure from

internal and external stakeholders regarding the management and

disclosure of their ESG risks and related lending and investment activities.

ING may regularly adopt or update ESG-related policies, frameworks or

disclosures in connection with the conduct of its business and operations.

However, these approaches may change regularly and, ultimately, there is

no guarantee that ING will be able to fully comply with all applicable

requirements within anticipated timeframes, or at all. Our ability to satisfy

evolving ESG-related laws, regulations, initiatives, targets, ambitions, aims

or expectations and to accurately report performance or developments

with respect to such matters is subject to numerous risks, many of which

are outside of our control, including the evolving legal environment,

regulatory requirements for the tracking and reporting of standards or

disclosures, the actions of suppliers, partners, and other third parties, and

data that is outside of ING’s control.

Our stakeholders may hold differing views on ESG-related matters,

including DEI, which may result in negative attention in traditional and

social media or a negative perception of our response to concerns

regarding these matters. In addition, we may also face potentially

conflicting supervisory directives as certain US regulatory and non-US

authorities have prioritized ESG-related issues while Congress and certain

US state governments have signaled pursuing potentially conflicting

priorities. These circumstances, among others, may result in pressure from

investors, unfavourable reputational impacts, including inaccurate

perceptions or a misrepresentation of our actual ESG-related practices and

diversion of management’s attention and resources. Any failure, or

perceived failure, by us to adhere to our public statements, comply fully

with developing interpretations of ESG-related laws and regulations,

including with respect to DEI-related matters, or meet evolving and varied

stakeholder expectations and standards could negatively impact our

reputation or result in legal and enforcement proceedings against ING. For

instance, Friends of the Earth Netherlands (Milieudefensie) has alleged that

ING has contributed to climate change and has initiated legal proceedings

against ING. For additional information on legal proceedings, including

climate related litigation, see Note 42 ‘Legal proceedings’ in the

consolidated financial statements.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	20

Any of these factors may have an adverse impact on ING’s reputation and

brand value, or on ING’s business, financial condition and operating results.

ING may be unable to adapt its products and services to meet changing

customer behaviour and demand, including as a result of ESG-related

matters.

Customers or other counterparties may increasingly assess sustainability

or other ESG-related matters in their economic decisions. For instance,

customers may choose investment products or services based on

sustainability or other ESG criteria or may look at a financial institution’s

ESG-related lending strategy when choosing to make deposits. At the

same time, market and stakeholder views, including those of regulatory or

governmental authorities, on ESG-related matters may vary across

jurisdictions and over time, and we have faced scrutiny, reputational risk,

product boycotts, lawsuits or market access restrictions from these parties

regarding our ESG-related policies, including with respect to DEI matters.

To remain competitive and to safeguard its reputation, ING is required to

continuously adapt its business strategy, products and services to respond

to emerging, increasing or changing sustainability and other ESG-related

demands from customers, investors and other stakeholders. However,

there is no guarantee that ING’s current or future products or services will

meet applicable ESG-related regulatory requirements, customer

preferences or investor expectations.

ING’s business and operations are exposed to transition risks related to

climate change.

The transition to a low-carbon or net-zero economy gives rise to risks and

uncertainties associated with climate change-related laws, regulations

and oversight, changing or new technologies, and shifting customer

sentiment. For instance, ING may be required to change its lending

portfolio to comply with new climate change-related regulations and other

ESG-related demands from customers, investors and other stakeholders.

Such changes could affect ING’s ability to continue or expand certain

customer relationships. This could result in claims or legal challenges

against ING. At the same time, market and stakeholder views, including

those of regulatory or governmental authorities, on ESG-related matters

may vary across jurisdictions and over time, and we may face scrutiny,

reputational risk, product boycotts, lawsuits or market access restrictions

from these parties regarding our ESG-related policies. This transition may

also adversely impact the business and operations of ING’s customers and

other counterparties. Further, there is a risk that changing community

standards and market expectations could lead to a reduction in demand

and a decline in valuations for certain assets, which may affect the value

of collateral we hold or the financial strength of certain of our portfolios. If

ING fails to adequately factor in such risks in its lending or other business

decisions, ING could be exposed to losses.

The low-carbon or net-zero transition may also require ING to modify or

implement new compliance systems, internal controls and procedures or

governance frameworks. The integration and automation of internal

governance, compliance, and disclosure and reporting frameworks across

ING could lead to increased operational costs for ING and other execution

and operational risks. The implementation cost of these systems may

especially be higher in the near term as ING seeks to adapt its business, or

address overlapping, duplicative or conflicting regulatory or other

requirements in this fast-developing area. Furthermore, ING’s ongoing aim

to implement appropriate systems, controls and frameworks increasingly

requires ING to develop adequate climate change-related risk assessment

and modelling capabilities (as there is currently no standard approach or

methodology available), and to collect customer, third-party or other data.

There are significant risks and uncertainties inherent in the development of

new risk modelling methodologies and the collection of data, potentially

resulting in systems or frameworks that could be inadequate, inaccurate,

incomplete or susceptible to incorrect customer, third-party or other data.

Any delay, change or failure in developing, implementing or meeting ING’s

climate change-related policies and complying with applicable regulatory

requirements may have a material adverse impact on our business,

financial condition, operating results and reputation, and lead to climate

change or ESG-related investigations, enforcement proceedings or

litigation.

ING’s business and operations are exposed to physical risks, including as

a direct result of climate change.

ING’s business and operations are exposed to the impacts of physical risks

arising from climate and weather-related events, including heatwaves,

droughts, flooding, storms, rising sea levels, other extreme weather events

or natural disasters, and to the impacts of physical risks arising from

environmental degradation, including the loss of biodiversity, water or

resource scarcity, pollution or waste management. Such physical risks

have disrupted in the past and could continue in the future to disrupt ING’s

business continuity and operations or impact ING’s premises or property

portfolio, as well as its customers’ property, business or other financial

interests. These risks could potentially result in impairing asset values,

financial losses, declining creditworthiness of customers and increased

defaults, delinquencies, write-offs and impairment charges in ING’s

portfolio, etc. In particular, changing climate patterns resulting in more

frequent and extreme weather events, such as the severe flooding that

occurred in Spain in October 2024 or the severe flooding in Germany in

mid-2024, could lead to unexpected business interruptions or losses for

ING or its customers.

Furthermore, ING’s ongoing aim to implement appropriate systems,

controls and frameworks increasingly requires ING to develop adequate

physical risk assessment and modelling capabilities (as there is currently

no standard approach or methodology available), and to collect customer,

third-party or other data. There are significant risks and uncertainties

inherent in the development of new risk modelling methodologies and the

collection of data, potentially resulting in systems or frameworks that

could be inadequate, inaccurate, incomplete or susceptible to incorrect

customer, third-party or other data.

For a description of physical risks to our operations and business other

than resulting from natural disasters as a result of climate change, see

'Operational and IT risks, such as system disruptions or failures, breaches

of security, cyber attacks, human error, changes in operational practices,

inadequate controls including in respect of third parties with which we do

business or outbreaks of communicable diseases may adversely impact

our reputation, business and results' below.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	21

Operational and IT risks, such as systems disruptions or failures,

breaches of security, human error, changes in operational practices,

inadequate controls including in respect of third parties with which we

do business or outbreaks of communicable diseases may adversely

impact our reputation, business and results.

Operational and IT risks are inherent to our business. Our clients depend on

our ability to process and report a large number of transactions efficiently

and accurately. In addition, we routinely transmit, receive and store

personal, confidential and proprietary information electronically. Losses

can result from inadequately trained or skilled personnel, IT failures

(including due to a cyber attack), inadequate or failed internal control

processes and systems, regulatory breaches, human errors, employee

misconduct, (including fraud), or from natural disasters or other external

events that interrupt normal business operations. As the role of artificial

intelligence in the finance industry and in our business increases, losses

may also result from incomplete, inaccurate or otherwise flawed outputs

from the algorithms and data sets utilised. Such losses may adversely

affect our reputation, business and results.

We depend on the secure processing, storage and transmission of

confidential and other information in our IT systems and networks. The

equipment and software used in our computer systems and networks may

not always be capable of processing, storing or transmitting information

as expected. Despite our business continuity plans and procedures, certain

of our computer systems and networks may have insufficient recovery

capabilities in the event of a malfunction or loss of data. We are

consistently managing and monitoring our IT risk profile globally. ING is

subject to increasing regulatory requirements including EU General Data

Protection Regulation (GDPR) and EU Payment Services Directive (PSD2)

and the new Digital Operational Resilience Act (DORA) which applies from

17 January 2025. Failure to appropriately manage and monitor our IT risk

profile could affect our ability to comply with these regulatory

requirements, to securely and efficiently serve our clients or to timely,

completely and accurately process, store and transmit information, and

may adversely affect our reputation, business and results. For further

description of the particular risks associated with cybercrime, which is a

specific risk to ING as a result of its strategic focus on technology and

innovation, see 'We are subject to increasing risks related to cybercrime

and compliance with cybersecurity regulation' below.

In addition, as the use of artificial intelligence in the financial services

industry increases, data protection and information security risks may also

increase. Our or our customers’ sensitive, proprietary, or confidential

information could be leaked, disclosed, or revealed as a result of or in

connection with our or our third-party providers’ use of generative or other

artificial intelligence technologies. Any such information input into a third-

party generative or other artificial intelligence or machine learning

platform could be revealed to others, including if information is used to

train the third party's artificial intelligence models. Additionally, where an

artificial intelligence model ingests personal information and makes

connections using such data, those technologies may reveal other

sensitive, proprietary, or confidential information generated by the model.

The EU AI Act entered into force in 2024. Certain prohibitions and AI-

literacy requirements apply from February 2025, governance and GPAI

model provisions from August 2025, and obligations for high-risk system

are expected to phase in during 2026 and 2027. We are implementing AI

governance and model risk controls to comply with these requirements.

Widespread of communicable diseases (including pandemics or other

large-scale public health emergencies) may impact the health of our

employees, increasing absenteeism, or may cause a significant increase in

the utilisation of health benefits offered to our employees, and may also

disrupt broader economic activity and cross-border operations, either or

both of which could adversely impact our business. Further, a significant

portion of our staff continue to work from home on a full- or part-time

basis, which may raise operational risks, including with respect to

information security, data protection, availability of key systems and

infrastructure integrity. In addition, other events including unforeseeable

and/or catastrophic events can lead to an abrupt interruption of activities

and cause operational losses. Losses can result from destruction or

impairment of property, financial assets, trading positions, and the loss of

key personnel.

If our business continuity plans are implemented effectively or do not

sufficiently take such events into account, losses may increase further.

We are subject to increasing risks related to cybercrime and compliance

with cybersecurity regulation.

Like other financial institutions and global companies, we are regularly the

target of cyber attacks, which are a specific risk to ING as a result of its

strategic focus on technology and innovation. In particular, threats from

Distributed Denial of Service (DDoS), targeted attacks (also called

Advanced Persistent Threats) and ransomware have intensified worldwide,

and attempts to gain unauthorised access and the sophistication of

techniques used for such attacks is increasing. Cyber threats are

constantly evolving and the techniques used in these attacks change,

develop and evolve rapidly, including the use of emerging technologies,

such as advanced forms of artificial intelligence and quantum computing.

The new cyber risks introduced by these changes in technology require us

to devote significant attention to the identification, assessment and

analysis of the risks and the implementation of corresponding

preventative measures. We have faced, and expect to continue to face, an

increasing number of cyber attacks (both successful and unsuccessful) as

we have further digitalised. This includes the continuing expansion of our

mobile- and other internet-based products and services, as well as our

usage and reliance on cloud technology.

A substantial majority of our customers interact with us primarily through

digital channels. This increased reliance on digital banking and remote

working may increase the risk of cybersecurity breaches, loss of personal

data and related reputational risk. If any of these risks were to materialise

that may adversely affect our business, results and financial condition.

Cybersecurity, the use and safeguarding of customer data and data

privacy have become the subject of increasing legislative and regulatory

focus. The EU’s second Payment Services Directive (PSD2), GDPR, DORA,

NIS2 and the Cyber Resilience Act are examples of such regulations. The

EU Cyber Resilience Act entered into force on 10 December 2024. Certain

vulnerability and incident reporting obligations apply from 11 September

2026, with full obligations applicable from 11 December 2027. In 2024, the

ECB conducted its first cyber resilience stress test to assess banks’ ability

to respond to and recover from a severe cyber incident. The results,

reflected in the 2024 SREP, identified areas for improvement in our

response and recovery capabilities, leading to enhancements in our cyber

resilience measures. In certain locations where ING is active, there are


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	22

additional local regulatory requirements and legislation on top of EU

regulations that must be followed for business conducted in that

jurisdiction. Some of these legislations and regulations may be conflicting

due to local regulatory interpretations. We may become subject to new

legislation or regulation concerning cybersecurity, security of customer

data in general or the privacy of information we may store or maintain.

Compliance with such new legislation or regulation could increase the

Group’s compliance cost. Failure to comply with applicable laws or

regulation could harm our reputation and could subject the Group to

enforcement actions, fines and penalties.

ING may be exposed to the risks of misappropriation, unauthorised access,

including through malware (such as ransomware), other malicious code,

cyber attacks and internal breaches, for purposes of misappropriating

assets or sensitive information, corrupting data, or impairing operational

performance, each of which could have a security impact. These events

could also jeopardise our confidential information or that of our clients or

our counterparties. These events can potentially result in financial loss and

harm to our reputation, hinder our operational effectiveness, result in

regulatory censure, compensation costs or fines resulting from regulatory

investigations and could have a material adverse effect on our business,

reputation, revenues, results, financial condition and prospects. Even when

we are successful in defending against cyber attacks, such defence may

consume significant resources or impose significant additional costs on

ING.

Because we operate in highly competitive markets, including our home

market, we may not be able to increase or maintain our market share,

which may have an adverse effect on our results.

There is substantial competition in the Netherlands and the other

countries in which we do business for the types of wholesale banking,

retail banking, investment banking and other products and services we

provide. Customer loyalty and retention can be influenced by several

factors, including brand recognition, reputation, relative service levels, the

prices and attributes of products and services, scope of distribution, credit

ratings and actions taken by existing or new competitors (including non-

bank or financial technology competitors). A decline in our competitive

position as to one or more of these factors could adversely impact our

ability to maintain or further increase our market share, which would

adversely affect our results. Such competition is most pronounced in our

more mature markets of the Netherlands, Belgium, the rest of Western

Europe and Australia. In recent years, however, competition in emerging

markets, such as Asia and Central and Eastern Europe, has also increased

as large financial services companies from more developed countries have

sought to establish themselves in markets which are perceived to offer

higher growth potential, and as local institutions have become more

sophisticated and competitive and proceeded to form alliances, mergers

or strategic relationships with some of our competitors. The Netherlands is

our largest market. Our main competitors in the banking sector in the

Netherlands are ABN AMRO Bank and Rabobank.

Competition could also increase due to new entrants (including non-bank

and financial technology competitors) in the markets that may have new

operating models that are not burdened by potentially costly legacy

operations and that are subject to reduced regulation. Competitive

dynamics continue to evolve as a result of platform-based players and

fintechs, regulatory changes affecting payments and data access, and

accelerated cloud-native operating models, which may intensify price and

service-level pressure across retail and wholesale. New entrants may rely

on new technologies, advanced data and analytic tools, lower cost to

serve, less extensive oversight from regulators compared to the

frameworks established in respect of traditional banks and/or faster

processes to challenge traditional banks. Developments in technology

have also accelerated the use of new business models, and ING may not

be successful in adapting to this pace of change or may incur significant

costs in adapting its business and operations to meet such changes. For

example, new business models have been observed in retail payments,

consumer and commercial lending (such as peer-to-peer lending), foreign

exchange and low-cost investment advisory services. In particular, the

emergence of disintermediation in the financial sector resulting from new

banking, lending and payment solutions offered by rapidly evolving

incumbents, challengers and new entrants, in particular with respect to

payment services and products, and the introduction of disruptive

technology may impede our ability to grow or retain our market share and

impact our revenues and profitability.

Increasing competition in the markets in which we operate (including from

non-banks and financial technology competitors) may significantly impact

our results if we are unable to match the products and services offered by

our competitors. Future economic turmoil may accelerate additional

consolidation activity. Over time, certain sectors of the financial services

industry have become more concentrated, as institutions involved in a

broad range of financial services have been acquired by or merged into

other firms or have declared bankruptcy. These developments could result

in our competitors gaining greater access to capital and liquidity,

expanding their ranges of products and services, or gaining geographic

diversity. We may experience pricing pressures as a result of these factors

in the event that some of our competitors seek to increase market share

by reducing prices, which may have a material adverse impact on our

business, results and financial condition.

We may not always be able to protect our intellectual property

developed in our products and services and may be subject to

infringement claims, which could adversely impact our core business,

inhibit efforts to monetise our internal innovations and restrict our

ability to capitalise on future opportunities.

In the conduct of our business, we rely on a combination of contractual

rights with third parties and copyright, trademark, trade name, patent and

trade secret laws to establish and protect our intellectual property, which

we develop in connection with our products and services. Third parties

may infringe or misappropriate our intellectual property. We may have to

litigate to enforce and protect our copyrights, trademarks, trade names,

patents, trade secrets and know-how or to determine their scope, validity

or enforceability. In that event, we may be required to incur significant

costs, and our efforts may not prove successful. The inability to secure or

protect our intellectual property assets could have an adverse effect on

our core business and our ability to compete, including through the

monetisation of our internal innovations.

We may also be subject to claims made by third parties for (i) patent,

trademark or copyright infringement, (ii) breach of copyright, trademark or

licence usage rights, or (iii) misappropriation of trade secrets. Any such

claims and any resulting litigation could result in significant expense and

liability for damages. If we were found to have infringed or


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	23

misappropriated a third-party patent or other intellectual property right

(including where we or a third party have used generative artificial

intelligence outputs based on data for which the generative model may

not have had consent), we could in some circumstances be enjoined from

providing certain products or services to our customers or from utilising

and benefiting from certain methods, processes, copyrights, trademarks,

trade secrets or licences. Alternatively, we could be required to enter into

costly licensing arrangements with third parties or to implement a costly

workaround. Any of these scenarios could have a material adverse effect

on our business and results and could restrict our ability to pursue future

business opportunities.

The inability of counterparties to meet their financial obligations or our

inability to fully enforce our rights against counterparties could have a

material adverse effect on our results.

Third parties that have payment obligations to ING, or obligations to return

money, securities or other assets, may not pay or perform under their

obligations. These parties include the issuers and guarantors (including

sovereigns) of securities we hold, borrowers under loans originated,

reinsurers, customers, trading counterparties, securities lending and

repurchase counterparties, counterparties under swaps, credit default and

other derivative contracts, clearing agents, exchanges, clearing houses

and other financial intermediaries. Defaults by one or more of these

parties on their obligations to us due to bankruptcy, lack of liquidity,

downturns in the economy or real estate values, volatile oil or other

commodity prices, operational failure or other factors, or even rumours

about potential defaults by one or more of these parties or regarding a

severe distress of the financial services industry generally, could have a

material adverse effect on our results, financial condition and liquidity.

Given the high level of interdependence between financial institutions, we

are and will continue to be subject to the risk of deterioration of the

commercial and financial soundness, or perceived soundness, of

sovereigns and other financial services institutions. This is particularly

relevant to our franchise as an important and large counterparty in equity,

fixed income and foreign exchange markets, including related derivatives.

We routinely execute a high volume of transactions, such as unsecured

debt instruments, derivative transactions and equity investments with

counterparties and customers in the financial services industry, including

brokers and dealers, commercial and investment banks, mutual and hedge

funds, insurance companies, institutional clients, futures clearing

merchants, swap dealers, and other institutions, resulting in large periodic

settlement amounts, which may result in us having significant credit

exposure to one or more of such counterparties or customers. As a result,

we could face concentration risk with respect to liabilities or amounts we

expect to collect from specific counterparties and customers. We are

exposed to increased counterparty risk as a result of past financial

institution failures and weakness and will continue to be exposed to the

risk of loss if counterparty financial institutions fail or are otherwise unable

to meet their obligations. As a result of the Russian invasion of Ukraine and

related international response measures, including sanctions and capital

controls, we may be exposed to an increased risk of default of

counterparties located in Russia and Ukraine, counterparties of which the

ultimate parent is located in Russia or may be considered effectively

controlled or influenced through Russian involvement, and other

counterparties in sectors affected by the response measures. Also,

liquidity or currency controls enforced by the Russian central bank may

impact Russian companies’ ability to pay. In addition, we have

counterparty exposure to Russian entities in connection with foreign

exchange derivatives for future receipt of foreign currencies against the

Russian rouble (RUB). Remaining at risk for ING at year-end 2025 is €600

million of credit exposures booked outside of Russia and €550 million with

clients in Ukraine. A default by, or even concerns about the

creditworthiness of, one or more of these counterparties or customers or

other financial services institutions could therefore have an adverse effect

on our results or liquidity.

With respect to secured transactions, our credit risk may be exacerbated

when the collateral held by us cannot be liquidated or is liquidated at

prices not sufficient to recover the full amount of the loan or derivative

exposure due to us. We also have exposure to a number of financial

institutions in the form of unsecured debt instruments, derivative

transactions and equity investments. For example, we hold certain hybrid

regulatory capital instruments issued by financial institutions which permit

the issuer to cancel coupon payments on the occurrence of certain events

or at their option. Pursuant to regulatory powers and resolution

frameworks, the ECB has indicated that, in certain circumstances, it may

require these financial institutions to cancel payment. If this were to

happen, we expect that such instruments may experience ratings

downgrades and/or a drop in value and we may have to treat them as

impaired, which could result in significant losses. There is no assurance

that losses on these assets would not materially and adversely affect our

business, results or financial condition.

In addition, we are subject to the risk that our rights against third parties

may not be enforceable in all circumstances, including sanction risk. The

deterioration or perceived deterioration in the credit quality of third parties

whose securities or obligations we hold could result in losses and/or

adversely affect our ability to rehypothecate or otherwise use those

securities or obligations for liquidity purposes. A significant downgrade in

the credit ratings of our counterparties could also have a negative impact

on our income and risk weighting, leading to increased capital

requirements. While in many cases we are permitted to require additional

collateral from counterparties that experience financial difficulty, disputes

may arise as to the amount of collateral we are entitled to receive and the

value of pledged assets. Collateral valuation is performed in accordance

with internal policies aligned with market data hierarchies; however,

disputes may still occur under stress. Also in this case, our credit risk may

also be exacerbated when the collateral we hold cannot be liquidated at

prices sufficient to recover the full amount of the loan or derivative

exposure due to us, which is most likely to occur during periods of

illiquidity and depressed asset valuations, such as those experienced

during the financial crisis of 2008. The termination of contracts and the

foreclosure on collateral may subject us to claims. Bankruptcies,

downgrades and disputes with counterparties as to the valuation of

collateral tend to increase in times of market stress and illiquidity. Any of

these developments or losses could materially and adversely affect our

business, results, financial condition, and/or prospects.

Ratings are important to our business for a number of reasons, and a

downgrade or a potential downgrade in our credit ratings could have an

adverse impact on our results and net results.

Credit ratings represent the opinions of rating agencies regarding an

entity’s ability to repay its indebtedness. Our credit ratings are important


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	24

to our ability to raise capital and funding through the issuance of debt and

to the cost of such financing. In the event of a downgrade, the cost of

issuing debt will increase, having an adverse effect on our net results.

Certain institutional investors may also be obliged to withdraw their

deposits from ING following a downgrade, which could have an adverse

effect on our liquidity. They can also have lower risk appetite for our debt

notes, leading to lower purchases of (newly issued) debt notes. We have

credit ratings from S&P, Moody’s, Fitch and Scope. Each of the rating

agencies reviews its ratings and rating methodologies on a recurring basis

and may decide on a downgrade at any time.

As rating agencies continue to evaluate the financial services industry, it is

possible that rating agencies will heighten the level of scrutiny that they

apply to financial institutions, increase the frequency and scope of their

credit reviews, request additional information from the companies that

they rate and potentially adjust upward the capital and other

requirements employed in the rating agency models for maintenance of

certain ratings levels. It is possible that the outcome of any such review of

us would have additional adverse ratings consequences, which could have

a material adverse effect on our results and financial condition. We may

need to take actions in response to changing standards or capital

requirements set by any of the rating agencies, which could cause our

business and operations to suffer. We cannot predict what additional

actions rating agencies may take, or what actions we may take in

response to the actions of rating agencies.

Furthermore, ING’s assets are risk-weighted. Downgrades of these assets

could result in a higher risk-weighting, which may result in higher capital

requirements. This may impact net earnings and the return on capital, and

may have an adverse impact on our competitive position.

An inability to retain or attract key personnel may affect our business

and results.

ING Group relies to a considerable extent on the quality of its senior

management, such as members of the executive committee, and

management in the jurisdictions which are material to ING’s business and

operations. The success of ING Group’s operations is dependent, among

other things, on its ability to attract and retain highly qualified personnel.

Competition for key personnel in most countries in which ING Group

operates, and globally for senior management, is intense. ING Group’s

ability to attract and retain key personnel, in senior management and in

particular areas such as technology and operational management, client

relationship management, finance, risk and product development, is

dependent on a number of factors, including prevailing market conditions

and compensation packages offered by companies competing for the

same talent.

The increasing restrictions on, and public and political scrutiny of,

remuneration (especially in the Netherlands), may continue to have an

impact on existing ING Group remuneration policies and individual

remuneration packages for personnel. For example, under the EU’s

amended Shareholder Rights Directive, known as SRD II, which came into

effect on 10 June 2019, ING is required to hold a shareholder binding vote

on ING’s Executive Board remuneration policy and Supervisory Board

remuneration policy at least every four years. Furthermore, the

shareholders have an advisory vote on ING’s remuneration report

annually. This may restrict our ability to offer competitive compensation

compared with companies (financial and/or non-financial) that are not

subject to such restrictions and it could adversely affect ING Group’s ability

to retain or attract key personnel, which, in turn, may affect our business

and results.

We may incur further liabilities in respect of our defined benefit

retirement plans if the value of plan assets is not sufficient to cover

potential obligations, including as a result of differences between actual

results and underlying actuarial assumptions and models.

ING Group companies operate various defined benefit retirement plans

covering the post-employment benefits of a number of our employees.

The liability recognised in our consolidated balance sheet in respect of our

defined benefit plans is the present value of the defined benefit obligations

at the balance sheet date, less the fair value of each plan’s assets,

together with adjustments for unrecognised actuarial gains and losses and

unrecognised past service costs. We determine our defined benefit plan

obligations based on internal and external actuarial models and

calculations using the projected unit credit method. Inherent in these

actuarial models are assumptions, including discount rates, rates of

increase in future salary and benefit levels, mortality rates and the

consumer price index. These assumptions are based on available market

data and are updated annually. Nevertheless, the actuarial assumptions

may differ significantly from actual results due to changes in market

conditions, economic and mortality trends and other assumptions. Any

changes in these assumptions could have a significant impact on our

present and future liabilities and costs associated with our defined benefit

plans.

Risks related to the Group’s risk management practices

Risks relating to our use of quantitative models to model client

behaviour for the purposes of our calculations may adversely impact our

results and reputation.

We use quantitative methods, systems or approaches that apply

statistical, economic, financial, or mathematical theories, techniques and

assumptions to process input data into quantitative estimates. Errors in

the development, implementation, use or interpretation of such models, or

from incomplete or incorrect data, can lead to inaccurate, noncompliant or

misinterpreted model outputs, which may adversely impact our results

and reputation. In addition, we use assumptions to model client behaviour

for risk calculations in our banking books. Assumptions are used to

determine the interest rate risk profile of savings and current accounts and

to estimate the embedded option risk in loans and investment portfolios.

Assumptions based on past client behaviour may not always be a reliable

indicator of future behaviour. The use of different assumptions to

determine client behaviour could have a material adverse effect on the

calculated risk figures and, ultimately, our future results or reputation.

Furthermore, we may be subject to risks related to changes in laws and

regulations (e.g. with reference to client rates, prepayment compensation,

etc.) governing the risk management practices of financial institutions. For

more information, see 'Risks related to the regulation and supervision of

the Group – Changes in laws and/or regulations governing financial

services or financial institutions or the application of such laws and/or

regulations may increase our operating costs and limit our activities'

above. As noted there, regulation of the industries in which we operate is

becoming increasingly more extensive and complex, while also attracting

supervisory scrutiny. Compliance failures may lead to changes in the laws


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	25

and regulations governing the risk management practices and materially

increase our operating costs.

We may be unable to manage our risks successfully through derivatives.

We employ various economic hedging strategies with the objective of

mitigating the market risks that are inherent in our business and

operations. These risks include currency fluctuations, changes in the fair

value of our investments, the impact of interest rates, equity markets and

credit spread changes, the occurrence of credit defaults and changes in

client behaviour. We seek to control these risks by, among other things,

entering into a number of derivative instruments, such as swaps (e.g. CCY,

IR, etc.), options, futures and forward contracts, including, from time to

time, macro hedges for parts of our business, either directly as a

counterparty or as a credit support provider to affiliate counterparties.

Developing an effective strategy for dealing with these risks is complex,

and no strategy can completely insulate us from risks associated with

those fluctuations. Our hedging strategies also rely on assumptions and

projections regarding our assets, liabilities, general market factors and the

creditworthiness of our counterparties that may prove to be incorrect or

prove to be inadequate. Accordingly, our hedging activities may not have

the desired beneficial impact on our results or financial condition. Poorly

designed strategies or improperly executed transactions could actually

increase our risks and losses. Hedging strategies involve transaction costs

and other costs, and if we terminate a hedging arrangement, we may also

be required to pay additional costs, such as transaction fees or breakage

costs. There have been periods in the past, and it is likely that there will be

periods in the future, during which we have incurred or may incur losses

on transactions, possibly significant, after taking into account our hedging

strategies. Further, the nature and timing of our hedging transactions

could actually increase our risk and losses. Hedging instruments we use to

manage product and other risks might not perform as intended or

expected, which could result in higher realised or unrealised losses, such as

credit value adjustment risks or unexpected P&L effects, and unanticipated

cash needs to collateralise or settle such transactions. Adverse market

conditions can limit the availability and increase the costs of hedging

instruments, and such costs may not be recovered in the pricing of the

underlying products being hedged. In addition, hedging counterparties

may fail to perform their obligations, resulting in unhedged exposures and

losses on positions that are not collateralised. As such, our hedging

strategies and the derivatives that we use or may use may not adequately

mitigate or offset the risks they intend to cover, and our hedging

transactions may result in losses.

Our hedging strategy additionally relies on the assumption that hedging

counterparties remain able and willing to provide the hedges required by

our strategy. Increased regulation, market shocks, worsening market

conditions, and/or other factors that affect or are perceived to affect the

financial condition, liquidity and creditworthiness of ING may reduce the

ability and/or willingness of such counterparties to engage in hedging

contracts with us and/or other parties, affecting our overall ability to

hedge our risks and adversely affecting our business, results and financial

condition.

Risks related to the Group’s liquidity and financing activities

We depend on the capital and credit markets, as well as customer

deposits, to provide the liquidity and capital required to fund our

operations, and adverse conditions in the capital and credit markets, or

significant withdrawals of customer deposits, may negatively impact

our liquidity, borrowing and capital positions, as well as increase the

cost of liquidity, borrowings and capital.

Adverse capital market conditions may negatively impact our cost of

borrowed funds and our ability to borrow on a secured and unsecured

basis, thereby impacting our ability to support and/or grow our businesses.

From a liquidity perspective, central banks have continued its path of

quantitative tightening by decreasing its balance sheet, which may reduce

the liquidity provided to the financial system. Consequently, banks have

significantly increased debt issuance and heightened competition for

client deposits is observed.

We require liquidity to fund new and ongoing business, to pay our

operating expenses and interest on our debt as well as dividends on our

capital stock, maintain our securities lending activities and replace

maturing liabilities. Without sufficient liquidity, we will be forced to curtail

our operations and our business will suffer. The principal sources of our

funding include a variety of short- and long-term instruments, including

deposit funds, repurchase agreements, commercial paper, medium- and

long-term debt, subordinated debt securities, capital securities and

shareholders’ equity.

In addition, as we rely on customer deposits to fund our business and

operations, the confidence of customers in financial institutions may be

tested in a manner that may adversely impact our liquidity and capital

position. Consumer confidence in financial institutions may, for example,

decrease due to ING’s or our competitors’ failure to communicate to

customers the terms of, and the benefits and risks to customers of,

complex or high-fee financial products. Reduced customer confidence

could have an adverse effect on our liquidity and capital position through

the withdrawal of deposits, as well as on our revenues and total financial

results. As a significant percentage of our customer deposit base is

originated via internet banking, a loss of customer confidence may result

in a rapid withdrawal of deposits over the internet.

In the event that our current resources do not satisfy our liquidity

requirements, we may need to seek additional financing. The availability of

additional financing will depend on a variety of factors, such as market

conditions, the general availability of credit, the volume of trading

activities, the overall availability of credit to the financial services industry,

our credit rating and credit capacity, as well as the possibility that

customers or lenders could develop a negative perception of our long- or

short-term financial prospects. See also under the heading 'Ratings are

important to our business for a number of reasons, and a downgrade or a

potential downgrade in our credit ratings could have an adverse impact on

our results and net results'. Similarly, our access to funding may be limited

if regulatory authorities or rating agencies take negative actions against

us. If our internal sources of liquidity prove to be insufficient, there is a risk

that we may not be able to successfully obtain additional financing on

favourable terms, or at all. Any actions we might take to access financing

may, in turn, cause rating agencies to re-evaluate our ratings.

Disruptions, uncertainty or volatility in the capital and credit markets may

also limit our access to capital. Such market conditions may in the future

limit our ability to raise additional capital to support business growth, to

counterbalance the consequences of losses, or to meet increased


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	26

regulatory capital and rating agency capital requirements. This could force

us to (i) delay raising capital, (ii) reduce, cancel or postpone payment of

dividends on our shares, (iii) reduce, cancel or postpone interest payments

on our other securities, (iv) issue capital of different types or under

different terms than we would otherwise, or (v) incur a higher cost of

capital than in a more stable market environment. This would have the

potential to decrease both our profitability and our financial flexibility. Our

results, financial condition, cash flows, regulatory capital and rating

agency capital positions could be materially adversely affected by

disruptions in the financial markets.

Furthermore, regulatory liquidity requirements in certain jurisdictions in

which we operate remain stringent, undermining our efforts to maintain

centralised management of our liquidity. This may continue to cause

trapped pools of liquidity and capital, resulting in inefficiencies in the cost

of managing our liquidity and solvency, and hinder our efforts to integrate

our balance sheet. An example of such trapped liquidity includes our

operations in Germany where German regulations impose separate

liquidity requirements that restrict ING’s ability to move a liquidity surplus

out of the German subsidiary.

As a holding company, ING Groep N.V. is dependent for liquidity on

payments from its subsidiaries, many of which are subject to regulatory

and other restrictions on their ability to transact with affiliates.

ING Groep N.V. is a holding company and, therefore, depends on dividends,

distributions and other payments from its subsidiaries to fund dividend

payments to its shareholders and to fund all payments on its obligations,

including debt service obligations.

ING Groep N.V.’s ability to obtain funds to meet its obligations depends on

legal and regulatory restrictions applicable to ING Groep N.V.’s subsidiaries.

Many of ING Groep N.V.’s direct and indirect subsidiaries, including certain

subsidiaries of ING Bank N.V., may be subject to laws that restrict dividend

payments, as well as requirements with respect to capital and liquidity

levels. For example, certain local governments and regulators have taken

steps and may take further steps to 'ring fence' or impose minimum

internal total loss-absorbing capacity on the local affiliates of a foreign

financial institution to protect clients and creditors of such affiliates in the

event of financial difficulties involving such affiliates or the broader

banking group. Increased local regulation and supervision have therefore

limited and may in the future further limit the ability to move capital and

liquidity among affiliated entities and between ING Groep N.V. and its

direct and indirect subsidiaries; limit the flexibility to structure

intercompany and external activities of ING as otherwise deemed most

operationally efficient, and increase in the overall level of capital and

liquidity required by ING on a consolidated basis.

Lower earnings of a local entity may also reduce the ability of such local

entity to make dividends and distributions to ING Groep N.V. Other

restrictions, such as restrictions on payments from subsidiaries or

limitations on the use of funds in client accounts, may also apply to

distributions to ING Groep N.V. from its subsidiaries.

ING Groep N.V. has also in the past guaranteed and may in the future

continue to guarantee the payment obligations of some of its subsidiaries,

including ING Bank N.V.. Any such guarantees may require ING Groep N.V.

to provide substantial funds or assets to its subsidiaries or the creditors or

counterparties of these subsidiaries at a time when the guaranteed

subsidiary is in need of liquidity to fund its own obligations.

Finally, ING Groep N.V., as the resolution entity of ING, has an obligation to

remove impediments to resolution and to improve resolvability.

Regulatory authorities have required and may continue to require ING to

increase capital or liquidity levels at the level of the resolution entity or at

particular subsidiaries. This may result in, among other things, the

issuance of additional long-term debt issuance at the level of ING Groep

N.V. or particular subsidiaries.

Additional risks relating to ownership of ING shares

Holders of ING shares may experience dilution of their holdings and may

be impacted by any share buyback programme.

ING’s AT1 securities may, under certain circumstances, convert into equity

securities. Such conversion would dilute the ownership interests of existing

holders of ING shares and such dilution could be substantial. Additionally,

any conversion, or the anticipation of the possibility of a conversion, could

depress the market price of ING shares. Furthermore, we may undertake

future equity offerings with or without subscription rights. In case of equity

offerings without subscription rights, holders of ING shares may suffer

dilution. In case of equity offerings with subscription rights, holders of ING

shares in certain jurisdictions, however, may not be entitled to exercise

such rights unless the rights and the related shares are registered or

qualified for sale under the relevant legislation or regulatory framework.

Holders of ING shares in these jurisdictions may suffer dilution of their

shareholding should they not be permitted to, or otherwise choose not to,

participate in future equity offerings with subscription rights.

Any share repurchases could affect the price of our ordinary shares, ADRs

or other securities and increase trading price volatility. The existence of a

share buyback programme could also cause the price of our ordinary

shares, ADRs or other securities to be higher than it would be in the

absence of such a share buyback programme, and could potentially

reduce the market liquidity of our ordinary shares, ADRs or other

securities. There can be no assurance that any share buybacks will

enhance shareholder value because the market price of our ordinary

shares or ADRs may decline below the levels at which we repurchase any

ordinary shares or ADRs.

In addition, ING cannot guarantee that any future share buyback

programme will be fully consummated. The timing and amount of share

repurchases pursuant to a share buyback programme will depend upon a

number of factors, including market, business conditions, and the trading

price of our ordinary shares or ADRs. A share buyback programme may

also be suspended or terminated at any time, and any such suspension or

termination could negatively affect the trading price of, increase trading

price volatility of or reduce the market liquidity of our ordinary shares,

ADRs or other securities. Additionally, a share buyback programme could

diminish our cash reserves, which may impact our ability to finance future

growth and to pursue possible future strategic opportunities.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	27

Because we are incorporated under the laws of the Netherlands and

many of the members of our Supervisory and Executive Boards and our

officers reside outside of the United States, it may be difficult to enforce

judgments of US courts against ING or the members of our Supervisory

Board and Executive Board or our officers.

Most of our Supervisory Board members, our Executive Board members

and some of the experts named in this Annual Report, as well as many of

our officers are persons who are not residents of the United States, and

most of our and their assets are located outside the United States. As a

result, investors may not be able to serve process on those persons within

the United States or to enforce in the United States judgments obtained in

US courts against us or those persons based on the civil liability provisions

of the US securities laws.

Investors also may not be able to enforce judgments of US courts under

the US federal securities laws in courts outside the United States, including

the Netherlands. The United States and the Netherlands do not currently

have a treaty providing for the reciprocal recognition and enforcement of

judgments (other than arbitration awards) in civil and commercial matters.

Therefore, a final judgment for the payment of money rendered by any

federal or state court in the United States based on civil liability, whether

or not predicated solely upon the US federal securities laws, would not be

enforceable in the Netherlands unless the underlying claim is re-litigated

before a Dutch court. However, under current practice, the courts of the

Netherlands may be expected to render a judgment in accordance with

the judgment of the relevant US court, provided that such judgment (i) is a

final judgment and has been rendered by a court which has established its

jurisdiction on the basis of internationally accepted grounds of jurisdiction,

(ii) has not been rendered in violation of elementary principles of fair trial,

(iii) is not contrary to the public policy of the Netherlands, and (iv) is not

incompatible with (a) a prior judgment of a Netherlands court rendered in

a dispute between the same parties, or (b) a prior judgment of a foreign

court rendered in a dispute between the same parties, concerning the

same subject matter and based on the same cause of action, provided

that such prior judgment is not capable of being recognised in the

Netherlands. It is uncertain whether this practice extends to default

judgments as well.

Based on the foregoing, there can be no assurance that US investors will

be able to enforce against us or members of our board of directors, officers

or certain experts named herein who are residents of the Netherlands or

countries other than the United States any judgments obtained in US

courts in civil and commercial matters, including judgments under the US

federal securities laws.

In addition, there is doubt as to whether a Dutch court would impose civil

liability on us, the members of our board of directors, our officers or certain

experts named herein in an original action predicated solely upon the US

federal securities laws brought in a court of competent jurisdiction in the

Netherlands against us or such members, officers or experts, respectively.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	28

Item 4. Information on the Company

A.History and development of the company

General

ING Groep N.V. was established as a Naamloze Vennootschap (a Dutch

public limited liability company) on March 4, 1991. ING Groep N.V. is

incorporated under the laws of the Netherlands.

The corporate site of ING, www.ing.com, provides news, investor relations

and general information about the company.

ING is required to file certain documents and information with the United

States Securities and Exchange Commission (SEC). These filings relate

primarily to periodic reporting requirements applicable to issuers of

securities, as well as to beneficial ownership reporting requirements as a

holder of securities. The most common filings we submit to the SEC are

Forms 6-K and 20-F (periodic reporting requirements). The SEC maintains

an internet site that contains reports, proxy and information statements,

and other information regarding issuers that file electronically with the SEC

at http://www.sec.gov. ING’s electronic filings are available on the SEC’s

internet site under CIK ID 0001039765 (ING Groep NV).

The official address of ING Group is:

ING Groep N.V.

Bijlmerdreef 106

1102 CT Amsterdam

P.O. Box 1800,

1000 BV Amsterdam

The Netherlands

Telephone +31 20 563 9111

The name and address of ING Group’s agent for service of process in the

United States in connection with ING’s registration statement on Form F-3

is:

ING Financial Holdings Corporation

1133 Avenue of the Americas

New York, NY 10036

United States of America

Telephone +1 646 424 6000

Changes in the composition of the Group

There were no significant acquisitions and divestments in 2025, 2024 or

2023.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	29

B.Business Overview

Our strategy

As part of our 'Growing the difference' strategy

our ambition is to accelerate growth, increase

impact, and deliver value to become the best

European bank.

Growing the difference means expanding our scale and impact across

more markets and segments to become the most loved, most impactful

and most valued bank. We aim to increase our relevance by deepening

customer relationships, broadening services, and continuing to make

banking easier and more seamless. Our two main priorities are providing

superior customer value and putting sustainability at the heart of what we

do, supported by four key enablers.

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

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

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

net-worth and investment clients via Private Banking & Wealth

Management. Each segment has a dedicated approach aligned with our

priorities: enhancing digital engagement for younger customers, offering

personalised solutions for affluent clients, and delivering superior value

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

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

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

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

businesses realise their vision for a better future.

Providing superior value for customers

Banking relies on strong relationships, and the strongest relationships are

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

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

Growing the difference means sharpening our focus on customer value,

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

for each customer segment. In Retail Banking, this is about offering the

right services, at the right time, in the right way. In Wholesale Banking, this

means leveraging our network, expertise and sustainability leadership.

Putting sustainability at the heart of what we do

Our sustainability strategy spans climate, nature and social agendas,

recognising their interdependencies and how they affect each other, both

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

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

complex and dynamic issue, so our response needs to be dynamic as well.

As scientific understanding is continually advancing, our approach will also

keep evolving. Therefore, our climate action has evolved to encompass

both mitigation and a growing emphasis on adaptation. Increasingly, we

are also exploring how we can play a role in halting and reversing nature

degradation and regenerating natural systems, while respecting human

rights and working to advance financial health and inclusion for customers

and communities.

Four enabling priorities

Providing seamless digital services

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

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

processes, with human intervention only where needed or desired.

Using scalable technology and operations

A technology and operations foundation that is modular and scalable

brings many benefits, including superior customer experience and safety.

Staying safe and secure

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

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

maintaining this trust is essential.

Unlocking our people’s full potential

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

environment that enables employees to thrive, maximising their growth

and impact.

1 Operative customers


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	30

Superior value for customers

Providing superior value for customers is one of

our two overarching priorities, as we strive to

make banking easy, instant, personal and

relevant. For Retail Banking, delivering superior

customer value means making banking simple

and expertise accessible, offering the right

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

For Wholesale Banking, delivering superior value

for customers means building on our network

strength, sector expertise, and sustainability

leadership.

Retail Banking

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

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

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

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

specific customer needs for all of these pillars.

Private Individuals

We serve nearly 41 million Private Individual customers1 across 10

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

Türkiye, Poland, Romania and Australia.

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

individuals, including savings accounts, payments, credit cards,

mortgages, unsecured lending, investment solutions and insurance

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

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

capabilities, and anticipating customer needs to help people manage their

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

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

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

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

we define this as customers holding an active payment account with

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

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

leads to deeper loyalty, significantly higher engagement, greater

customer satisfaction and ultimately higher value, as customers choose

ING for a broader set of their financial needs.

Growing the difference means focusing even more on growing value for

customers. We continue to expand our offering by developing relevant

propositions for our various customer groups and applying a personalised

approach enabled by our digital banking capabilities. Our priorities include

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

subscription-based services that provide superior customer value,

diversifying our Private Individuals lending portfolio, and partnering to offer

full-service solutions that help homeowners make their homes more

sustainable. We are also broadening our investment and savings offering

to help customers protect and grow their wealth and manage their

financial health more effectively.

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

customers across their daily banking activities and offering personalised

products and services supported by advanced technology and data-driven

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

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

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

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

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

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

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

million.

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

increase of 6 percent compared to 2024.

Business Banking

For Business Banking clients, growing the difference means making banking

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

choice for entrepreneurs and businesses to manage and grow their

operations. We define success by delivering superior customer value

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

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

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

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

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

launch in January 2026.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	31

Our service model addresses both basic and complex needs, offering

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

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

engagement and incorporate sector-specific expertise to support informed

decision-making.

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

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

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

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

We aim to combine digital convenience with human expertise, making

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

Private Banking & Wealth Management

Private Banking, Wealth Management & Investments combines our Private

Banking & Wealth Management activities with our total Retail investments

business across Private Individuals, Private Banking and Business Banking

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

implementing across our Retail markets, designed to meet diverse client

needs.

Our Private Banking & Wealth Management offering provides tailored

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

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

and Poland. We provide clients with investment solutions focused on

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

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

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

Our strategy builds on our strong Business Banking position to serve

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

capabilities to enhance client engagement and provide actionable insights

through advanced analytics, while maintaining human expertise through

relationship managers supported by product specialists and portfolio

managers.

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

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

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

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

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

offer a hybrid model that combines digital convenience with personalised

support.

In line with our ambition to make investing personal and accessible

throughout Europe, total assets under management and e-brokerage

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

2024.

Wholesale Banking

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

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

achieving a high net promoter score (NPS), ranking in the industry’s top

quartile, leading in sustainability, digital services and employer

attractiveness, while delivering sustainable returns. Our work starts with

providing corporate clients and financial institutions with the financial

solutions they need across their value chains.

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

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

Most Innovative Bank for Trade Finance globally. Treasury Management

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

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

Impressive Investment Bank for Corporate ESG Capital Markets and Advice.

Global Reach

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

operates from 37 countries across three regions: EMEA, APAC and the

Americas.

Sector Expertise

Clients benefit from our sector knowledge of eight sectors and 29 sub-

sectors, including: commodities, food and agriculture; corporate sector

coverage; energy; financial institutions; infrastructure and real estate;

sustainable value chains; technology, media, telecom and healthcare; and

transport and logistics. By making use of our target sector research

capabilities and our client segmentation model, we aim to help clients

navigate the highs and lows of economic cycles. We provide them with

relevant advice, data-driven insights and customised, integrated solutions

that support their business ambitions.

How we aim to become the best European wholesale bank

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

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

Transaction Services, we are expanding our product foundations to offer

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

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

Financial Markets, we are harmonising our product suite and increasing

access to green and conventional instruments, enabling clients to manage

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

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

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

more relevant support.

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

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

capital and diversify funding sources.

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

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

digitalisation efforts to enhance client experience. We expanded self-

service journeys on our InsideBusiness platform, streamlined processes,

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

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

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

proactive advice and deepen engagement.

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

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

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


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	32

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

business opportunities, while continuing to manage risks prudently.

Our NPS performance

One of the ways we measure our ability to deliver superior customer value

is through the net promoter score (NPS). The NPS indicates whether

customers would recommend ING to others. We compare our NPS to

selected peers in each market.

The net promoter score is a measure for customer satisfaction and loyalty.

The measure is derived from the survey question on the scale from 0 (not

at all) to 10 (extremely likely): 'How likely is it that you would recommend

a product or brand to a friend, family member or colleague?' (RB) and 'how

likely are you to recommend ING to a colleague or business partner?' (WB).

The score is calculated as the difference between the percentage of

promoters (who rate ING as 9 or 10), and detractors (rating ING with a

score of 6 or below).

Our ambition is to achieve a number one NPS ranking in all our Retail

markets. In 2025, ING ranked number one in 5 of our Retail markets:

Australia, Poland, Germany, Romania and Spain.

We ran an NPS programme in 32 Wholesale Banking (WB) markets

throughout 2025, to ensure a broad coverage of our client base, and

achieved a 69 percent response rate. ING’s WB NPS score rose to 77 (on a

scale of -100 to +100), compared to a score of 74 in 2024. The insights

from the survey showed how our sector expertise, global reach and local

experts are highly appreciated by clients and important reasons for why

they chose ING. We also asked clients how satisfied they were with our

product areas, people, processes and digital offering, with the highest

scores going to our product offering, relationship management and client

support. Off the back of these results, we will continue to prioritise building

strong relationships with excellent execution, simplifying and automating

our KYC processes and optimising our digital offering.


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How we are growing the difference

We focus and continue to work on our four key

enablers that will help us grow the difference:

providing seamless digital services, using scalable

technology and operations, staying safe and

secure, and unlocking our people’s full potential.

Providing seamless digital services

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

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

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

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

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

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

Banking App enables customers to open accounts in minutes, manage

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

our Mijn ING Zakelijk platform helps SMEs manage payments and link

accounting packages seamlessly, while larger corporates benefit from the

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

cash management globally. For Private Banking & Wealth Management,

clients enjoy secure digital portfolio management and personalised

advisory services through our app, which offers tailored dashboards and

seamless access to expert support.

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

delivering relevant, data-driven insights that help customers make

informed financial decisions. As data becomes increasingly central to

delivering personal and relevant services, privacy and data security are

more important than ever.

Scalable technology and operations

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

market faster, achieve volume more quickly, maintain consistent and

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

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

technology but also collaborate across countries and make an impact

globally. Scalable technology enables ING to create specific, local

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

engineering, security, and data expertise.

Scalable technology

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

unified, integrated foundation. The platform hosts the IT modular

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

operate customer propositions. It allows ING countries and business lines

to introduce propositions quickly, easily, and safely.

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

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

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

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

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

years ahead:

§Operational excellence: Enhancing reliability, reinforcing cybersecurity,

and investing in our workforce to ensure resilient and secure

operations.

§Digital product governance: Advancing our digital product capabilities,

which contributes further to control, transparency, and strategic

alignment.

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

including AI-enabled coding.

§Transformation: Continuing the development and expansion of our

scalable technology platform.

§Data and AI development: Accelerating the responsible and effective

use of data and artificial intelligence to unlock new opportunities and

efficiencies.

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

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

banking technology platform.

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

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

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

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

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

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

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

allows us to optimise our infrastructure landscape by using both private

and public cloud to run our applications.

OnePipeline, our continuous integration and delivery pipeline, provides

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

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

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

applications registered in our IT management platform across all ING

entities.

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

shared services that help engineers build products – like Instant Payments

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


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	34

approximately 81 percent of customer logins used Touchpoint (2024:

approximately 75 percent)

Digital access

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

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

expectations, we strive to provide uninterrupted access to our banking

services, while allowing for scheduled maintenance and downtime. For

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

The combined digital channel availability for these three countries was

99.89 percent (2024: 99.86 percent).

For Wholesale Banking clients worldwide, the availability for our Inside

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

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

(2024: 100 percent.

Scalable operations

Our scalable operations are driven by digitalisation and capability hubs,

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

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

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

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

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

our employee journeys.

Digitalising key customer journeys allows us to enable superior customer

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

cost efficiency. In 2025, our digi index score was 81.8 percent (2024:78.1

percent). The digi index score reflects the average of STP rates of key

customer journeys that are handled without manual intervention.

Capability hubs provide shared services and solutions across ING

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

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

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

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

Through expanded and improved digital services we have reduced friction

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

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

percent).

Data analytics

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

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

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

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

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

engineering – we scaled solutions and explored new opportunities.

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

experiment and the introduction of machine learning-based client due

diligence assessments in Retail Banking. In Wholesale Banking, we

prioritised front-office productivity by embedding AI tools, including

enhancing liquidity management through machine learning and providing

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

decision‑making.

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

broader transformation objectives. The introduction of a unified data,

analytics, AI and agentic environment marked an important milestone in

strengthening our data infrastructure. The platform delivers analytics

initiatives with greater consistency and efficiency, while simplifying risk

assessments and strengthening data governance.

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

use in areas such as analytics, software development and customer

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

by establishing a dedicated central AI Risk Committee to oversee emerging

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

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

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

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

individual participants across 18 functions in 14 countries. These initiatives

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

innovative AI adoption.

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

improve customer engagement and support sales. These tools are

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

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

of GenAI for educational and awareness content, including illustrated

messaging.

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

applications automatically. We enhanced the mortgage credit decision

process in Australia by introducing machine learning-based scorecards.

This improvement enables a more digitised application experience and

ensures reliable assessments aligned with our risk appetite.

Our contact centres underwent a GenAI transformation, with chatbots

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

Italy, Romania, and Australia).

We integrated analytics and AI into KYC processes across Retail and

Wholesale Banking. Our Secondary Analytics Transaction Monitoring

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

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

the Netherlands, Romania, and Australia.

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

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

These solutions are designed to streamline processes, support compliance,

and enable dynamic risk scoring and smarter decisions globally.

In engineering, we have implemented GenAI to accelerate software

development, improve code quality, and reduce communication overhead.

Staying safe and secure

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

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


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Safeguarding these assets is essential to maintaining the confidence of our

stakeholders.

We operate within a robust risk management framework designed to

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

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

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

ensuring we meet all regulatory obligations.

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

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

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

transaction monitoring to detect and prevent suspicious activity. We also

continue to strengthen our fraud prevention capabilities, using innovative

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

Cybersecurity remains a top priority. We continuously monitor the threat

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

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

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

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

and another caused temporary interruptions in third-party service

availability within the Polish mobile payment system. Our Chief

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

actively monitoring our environment, investigating emerging threats, and

taking timely action to protect our customers and essential services.

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

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

continuously evaluate our compliance with evolving data ethics standards

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

encouraging employees to report unethical or unlawful behaviour through

secure and anonymous channels.

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

secure, see.

Unlocking our people’s full potential

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

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

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

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

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

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

create a friendly and collaborative workplace that mirrors the diverse

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

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

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

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

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

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

‘employee experience’.

Talent & leadership

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

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

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

learning into one place for all ING employees worldwide, making

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

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

to empower employees to take ownership of their growth through tools

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

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

tailored to different roles and ambitions. Employee feedback on learning

content is positive, with colleagues actively exploring topics beyond

mandatory training – showing appetite for self-driven learning.

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

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

conducted for approximately 5,000 senior employees, each domain

evaluated their contributions to growing the difference and identified the

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

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

by integrating near-term and forward-looking assessments of

organisational and people requirements, including future workforce needs,

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

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

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

where, following completion, participants are demonstrating increased

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

also look ahead with confidence: the International Talent Programme

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

cultivate professional expertise and support their personal growth. This

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

strengthening our leadership pipeline.

Our commitment to a fair and transparent performance and rewards

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

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

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

performance rating scale in our performance evaluation scheme,

introduced in 2024. Remuneration decisions are clearly linked to

performance outcomes.

ING began using a structured variable remuneration framework based on

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

remuneration have a variable remuneration target. This provides

managers with a decision framework for determining variable

remuneration rewards equitably, while having enough flexibility to

differentiate outcomes for individual performance. Employees see

increased transparency and can better understand how their personal

performance influences their variable remuneration.

Culture & organisation

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

culture where everyone has the opportunity to develop and have impact

for our customers and society.


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

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

We promote flexibility through hybrid working and have introduced

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

We have also included a Wellbeing Index in our Organisational Health

Index (OHI) survey to track how our people are doing, identify

improvement areas, and monitor the link between wellbeing and

performance. By prioritising wellbeing and leveraging these insights,

we aim to build a resilient workforce and drive a sustainable high-

performance culture.

Equally important is the role feedback plays in sustaining our Orange

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

people formal channels to provide feedback on our strategy, working

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

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

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

sustained strong organisational engagement among our employees

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

feedback showed that our people continue to value and appreciate their

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

their wellbeing.

Employee experience

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

delivering a great employee experience is essential to providing excellent

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

continued the collective efforts of the Employee Experience Design Board,

which brings together representatives from Human Resources, Facilities

Services, Operations, Information Technology, and Global Communications

to enhance the employee experience globally.

Throughout the year, this group focused on operational excellence and

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

prioritise work that matters most. Initiatives included improving the office

environment, streamlining facility management ticketing, creating a

unified portal for employee support, and empowering employees to

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

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

employee experience.

Competition

ING is a leading European universal bank with global activities. Our more

than 60,000 colleagues based in 40 countries serve nearly 41 million

individuals, corporates and financial institutions in 10 Retail Banking and

over 100 Wholesale Banking markets. ING’s purpose is to empower people

to stay a step ahead in life and in business.

Our Retail Banking business, which consists of Private Individuals, Business

Banking, and Private Banking & Wealth Management, offers individuals,

small to medium-sized businesses (SMEs) and mid-corporates a full range

of products and services covering payments, savings, insurance,

investments, mortgages, trade finance, structured finance and financial

markets solutions, among others. In Wholesale Banking we provide

corporate clients and financial institutions with specialised lending, tailored

corporate finance, debt & equity market solutions and sustainable finance

solutions. We also offer daily banking services such as payments & cash

management and trade & treasury services.

There is substantial competition in the countries in which we do business

for the types of Wholesale Banking, Retail Banking, Business Banking and

other products and services we provide. In recent years, competition has

further increased in both developed and emerging markets. Our largest

market is the Netherlands, where our main competitors are ABN AMRO

Bank and Rabobank.

Traditional banks are no longer the sole providers of financial services.

Digital innovation and AI-driven low-cost models are driving competition

from fintechs, non-bank lenders, and technology companies. Digital banks

are competing for retail customers with user-friendly platforms and low

fees, while private lenders – including big tech companies – are taking a

growing share of business lending. At the same time, innovations such as

digital tokens and stablecoins are reshaping payment systems, moving

them beyond traditional banking channels.

In this competitive landscape, where banking products and services have

mostly become commodified, the main differentiator is being able to

provide superior value for customers. For Retail Banking, delivering superior

customer value means making banking simple and expertise accessible,

offering the right products, at the right time, in the right way. Businesses

too want to benefit from gains in speed, transparency, security and

efficiency created by technologies such as blockchain and artificial

intelligence. Winners will be those with a strong trusted brand and a

superior digital experience, taking the effort out of managing finances and

offering personalised, real-time advice, products and services for all

financial needs.

Statements regarding ING’s competitive position reflect the assessment of

ING’s management about the general competitive landscape in which ING

operates.


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Sustainability

ING aims to leverage our role as a global bank to

support clients in addressing environmental

challenges, including climate-related and nature-

related risks, because it matters to our company,

our customers, society, and the environment.

For ING, ensuring the resilience and commercial success of our business

includes managing climate-related risks while also seizing the

opportunities that come with financing the transition.

Climate change mitigation

Climate change mitigation means reducing GHG emissions to limit global

warming to 1.5 °C above pre-industrial levels, in line with the Paris

Agreement. For ING, this involves managing the emissions linked to our

financing activities.

Climate change adaptation

Climate change adaptation refers to the process of adjusting to current

and anticipated climate change and its impacts. It is intrinsically linked to

physical risk, as it involves implementing strategies to manage and

mitigate the effects of climate-related physical events.

These physical risks can increase the likelihood of defaults and non-

performing loans, exposing ING to financial vulnerabilities through various

channels:

§Wholesale and Business Banking: Damage to infrastructure, operational

disruptions, rising costs, and reduced customer demand can lead to

lower borrower income and higher insurance premiums, increasing the

risk of default.

§Residential real estate: More frequent and severe climate events may

reduce property values, limit insurance availability in high-risk areas,

and impair borrowers’ ability to repay mortgages or access renovation

financing.

Policies, actions and performance

This section includes the relevant policies and guidelines to address the

material impacts, risks and opportunities and the related actions to

execute those policies and guidelines.

The Environmental, Social, and Governance (ESG) Risk Policy

The ESG Risk Framework, described in the 'ESG risk’ section, sets out ING’s

approach to managing ESG risks as drivers of existing risk types. It is

supported by the double materiality assessment (DMA) and the ESG Risk

Policy, which are designed to ensure the implementation of obligations,

processes, and control requirements from the framework.

The ESG Risk Policy explains how ING identifies, assesses, mitigates,

monitors, and reports ESG-related risks in line with our risk appetite, by

considering applicable and material risks and negative impacts across the

value chain. It applies to ING Groep N.V. and all majority-owned entities,

unless local laws require deviations. The policy considers relevant

legislation and guidance, including EBA guidelines on ESG risk

management, EBA ITS on Pillar 3 ESG disclosures, CSRD, EU Taxonomy, and

SFDR. It sets objectives, references applicable regulations, and outlines

high-level obligations and control objectives for managing ESG risks across

the value chain. The ESG Risk Department oversees implementation and

compliance.

ESG risks influence financial and non-financial risk types. Therefore, ESG

risk management is embedded in existing processes such as credit

granting, risk appetite steering, and credit risk management. Local entities

adapt global requirements to local regulations and practices, mainly

through lending criteria, loan-management systems, and sales

procedures.

Actions related to ESG Risk Policy

As part of our risk management cycle (see ‘ESG risk section’), ING

proactively mitigates identified risks and negative impacts within its risk

appetite. We apply strategies such as reducing, avoiding, accepting, or

transferring risk, embedding these measures into policy and procedure

updates across risk categories. It is ING’s policy to act in compliance with

applicable laws and regulations. The following paragraphs outline key

initiatives in business lines where climate change is a material risk.

Retail Banking: Residential mortgages

ING integrates transition and physical climate risks into its mortgage

portfolio strategy, risk appetite, lending criteria, and collateral valuation.

Local entities apply the ESG Risk Policy using global guidance, adapting to

local regulations and practices.

Key actions include:

§Customer engagement: Advisory services and duty-of-care procedures

promote interest in low-emission buildings.

§Data collection: ING implemented controls to ensure the mandatory

collection of EPC data for new loans and enhancement of existing

portfolios through proxy models.

§Risk appetite: Aligned with business strategy and metrics for managing

low-quality EPCs at origination are monitored under the Risk Appetite

Framework, with escalation to the ESG Risk Committee when needed.

Retail Banking: Business Banking lending

ING identifies sectors with higher climate-related risk exposure and

supports these through dedicated lending criteria, data controls (e.g., EPC


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	38

data for real estate), and regular monitoring. We engage with clients to

understand their business plans and transition-related risk considerations.

In line with our risk appetite, we accept certain transition risks but monitor

and manage them through client-specific assessments, exposure limits,

and key risk indicators (KRIs). Risks outside our appetite must be mitigated

or may not be accepted. Mitigation measures include insurance for

physical risks, covenants addressing risk mitigation measures, and

incorporating climate risks into collateral valuation. Sector-specific lending

policies and data collection enable accurate portfolio assessment and

active management.

Wholesale Banking lending

While climate transition-related risks may be more pronounced in certain

carbon-intensive sectors, we manage climate-related risks across the

entire Wholesale Banking portfolio through the ESG Risk Framework,

lending policies, and due-diligence processes. These efforts are supported

by quantification methodologies and advanced tools, ensuring that risks

are identified, assessed, and managed throughout the full origination-to-

monitoring cycle. Key actions include:

§Climate Risk Appetite: We assess transition risks at the client level,

considering emissions, financial capacity, and transition plans. High-risk

clients are managed through risk appetite limits and growth

constraints.

§Lending policies and steering: Sector lending policies reference the ESG

Risk Policy and apply its minimum requirements. They include ESG

factors and transmission channels relevant to each sector, detailing

acceptable mitigants to address potential financial risks from ESG

factors. Relevant sector considerations may inform lending decisions.

§ESG risk assessment tool: In 2025, we launched an enhanced ESG risk

assessment platform that integrates environmental, social, and

governance factors, replacing the previous ESR framework. The tool

improves efficiency and consistency in credit granting by enabling

users to input supplementary ESG data and automating integration

into the assessment process. Further automation and data

enhancements are planned for 2026. The assessment process includes:

–Materiality check: Determines if a client or transaction is likely to

have significant ESG impacts or dependencies based on sector data.

–Initial assessment: Evaluates ESG and reputational risks for material

factors.

–Qualitative review: Front office identifies mitigants and checks

compliance with sector standards and restricted activities.

–High-risk escalation: ESR desk performs due diligence and provides

binding advice, which may include additional conditions or a go/no-

go decision.

–Credit risk review: Experts validate ESG factor assessments and

mitigants relevant to credit risk.

§Client engagement and data infrastructure: We engage clients to

understand and manage climate-related risks and continuously

enhance ESG data infrastructure by integrating internal and external

sources. This provides granular insights for portfolio management and

supports data-driven solutions.

§Collateral valuation: Climate risks affecting property values are

embedded in valuation, monitoring, and revaluation processes for

commercial real estate.

Guidelines and actions addressing our opportunities

Our approach to sustainability-related opportunities is integrated into

ING’s business strategy. This strategic approach ensures that our actions

align with our long-term ambitions. Sustainable lending represents a key

opportunity for us to grow and differentiate in the market. It enables us to

increase sustainable volumes mobilised, expand our renewable energy

financing portfolio, and support clients in purchasing energy-efficient

homes. In addition, our green funding framework supports eligible

financing activities and funding diversification.

To help guide these opportunities and safeguard against greenwashing

risks, we have sustainable finance guidelines and implement mandatory

instructions that set clear criteria and provide practical guidance tailored

to each business line. These instructions ensure reliable and transparent

reporting. Where they are still being embedded, we apply additional

controls to maintain accuracy and prevent greenwashing.

Wholesale Banking

The Sustainable Finance Guidelines provide ING colleagues with a clear

framework for engaging with clients and offering sustainable finance

products and solutions. These guidelines are to be followed by all relevant

business units when advising clients and structuring products.

All products included in our Sustainable Finance Guidelines must comply

with the criteria set out in the mandatory instructions, which define the

conditions under which a product can be classified as sustainable. While

we are still in the process of fully embedding these instructions, the

guidelines are continuously being updated to reflect new product

developments and evolving regulatory requirements.

Wholesale Banking offers financing and advisory services tailored to client

needs in areas where sustainability-related risk considerations are

relevant.

In 2025 we recorded €166 billion of volumes mobilised (2024: €130 billion).

We also see opportunities in financing our clients meeting their energy

transition objectives, by financing renewable power generation. Volumes

mobilised refer to the total amount of financing, investment and related

financial activity that we enable for clients through our products and

services, where we plays a role in originating, structuring, coordinating or

participating in the transaction. Volumes are measured based on ING’s role

in each transaction, with full or pro‑rata recognition when acting as ESG

lead to reflect its contribution to mobilising sustainable finance, and

recognition of the bank’s own share when participating without a lead role.

Retail Banking

Retail Banking has significant opportunities related to green mortgages

and energy-efficient housing. For private individuals, by offering

preferential pricing and mortgage extensions or top-ups for properties with

better EPC ratings, we can attract customers seeking energy-efficient

homes and differentiate our offering in a growing market segment.

Moreover, we can create opportunities by financing renovations that

improve energy performance, such as insulation upgrades or installing

solar panels, enabling customers to enhance property value and reduce

emissions. This not only supports environmental goals but also

strengthens borrowers’ financial resilience, as energy-efficient homes

typically have lower energy bills contributing to a more robust credit

profile.

1Own workforce refers to our employees and non-employees (contractors and individuals engaged via employment agencies), also referred to as our 'employees'.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	40

Own workforce

As an employer, we aim to provide a safe and

inclusive workplace. We believe financially healthy

people contribute to a healthy economy and drive

social progress, which is why we aim to support

customers in meeting their financial commitments

now, while building their financial security for

tomorrow. We believe every person deserves to be

treated with dignity and have their interests

considered equally, whether it concerns people in

our own workforce or our consumers and end-

users.

Our own workforce1 is our greatest asset. Unlocking our people’s full

potential is a key enabler of our ‘Growing the difference’ strategy as we

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

when we equip our workforce with the skills and capabilities they need to

make significant contributions to the continued and sustainable growth of

our business. We seek to create a safe, non-discriminatory and inclusive

environment that reflects the world we operate in, and where our

employees feel they can belong and thrive.

Own workforce strategy – Unlocking our people’s full

potential

ING strives to provide a safe, non-discriminatory and inclusive workplace

where everyone has the potential to grow and develop. This is supported

by internal policies, controls and workforce processes, taking into account

applicable legal and regulatory frameworks in the jurisdictions in which we

operate. We consider both external and internal factors, such as

geopolitical forces, evolving technology, and changing employee

expectations, as these trends shape our business needs and,

consequently, our strategy. For more on ‘unlocking our people’s full

potential’, see our ‘How we are growing the difference'’ section.

The governance of our policies regarding harassment and violence, and of

our initiatives supporting wellbeing, employment, and the inclusion of

persons with disabilities, is structured in such a way that ING can address

its material risks and impacts in a timely and effective manner. These risks,

such as harassment and violence, can result in lower employee morale,

reduced productivity and harm to ING’s overall reputation and operational

instability, as well as potential legal claims with financial consequences. To

strengthen our adaptability and resilience, tools and the Organizational

Health Index provide valuable insights that guide the refinement of our

policies, inform strategic direction, and support the implementation of

regulatory changes. Through ongoing policy reviews, residual risk

assessments, and the alignment of processes with evolving regulations,

we continuously enhance our capacity to manage both current and

emerging risks effectively.

ING maintains policies and procedures intended to address accessibility

requirements where applicable.

Policies, actions and performance

As a globally operating bank, we are continuously navigating the

complexities of global and local regulations. In some instances, we set

general, globally applicable policies to help address the material risks and

material negative impacts our workforce may face, with consideration for

local laws and regulations which may necessitate tailored local policies to

ensure full compliance. ING maintains workforce-related policies designed

to mitigate discrimination, misconduct and other workforce-related risks. It

is ING’s policy to act in compliance with applicable laws and regulations.

At ING, we denounce all forms of discrimination. Any distinction, exclusion,

or preference not based on the inherent requirements of the job is deemed

as discrimination.

ING’s workforce policies are aligned with local labour laws and regulations

in all countries where we have operations. In countries where local

legislation goes further than the principles set out by the Universal

Declaration of Human Rights and ILO Core Conventions, we also apply

additional and stricter requirements. In addition, we seek alignment with

international standards on human rights (such as the UNGPs) through the

implementation of EU directives and the development of internal policies.

We take various actions to further understand the impacts coming from

outside ING, and we continuously inform our workforce and leaders on

best practices related to developments and learnings. This is exemplified in

our collaboration with external organisations to understand the impact of

global events, socio-economic movements, and changes in legislation.

Where appropriate, we participate in external assessments to understand

our maturity on specific areas and our need for focus and improvement in

others. In 2025, ING continued its ‘Advocate’ status in the annual

Workplace Pride global benchmark, the highest ranking possible for an

organisation.


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Actions on training and skill development

Through our engagement with our workforce, we understand that to drive

meaningful change, we must attract, develop, and retain fit-for-future

talents. That is why we offer both scalable and curated learning and

development opportunities tailored to our employees’ roles and growth,

helping us meet our current and future skills and capability needs. In 2025,

we launched our internal ING University - a global learning platform

one place for all employees, including domain-level academies,

mandatory and non-mandatory learnings (online and in-person) and both

formal and informal development opportunities. In 2025, we continued our

focus on talent development. This year, we performed strategic talent

reviews across the bank for more than 5,000 senior roles in order to better

identify and understand the leadership, skill, and capability needs of our

domains to grow the difference.

Workforce characteristics

ING has no employees with non-guaranteed working hours, as employees

with on-call agreements have agreed fixed hours and are treated as full-

time or part-time employees. We also examine other contextual

information and methodologies for data compilation to aid in

understanding our workforce characteristics. For example, we measure

turnover on a monthly basis as it has the potential to impact operational

effectiveness. In 2025 total turnover was 9 percent, no change compared

to 2024. Additional disclosures include breakdowns by region for full-time

and part-time employees, in order to obtain a comprehensive insight into

our employment practices and impacts. The related staff expenses and

the number of own employees are disclosed in note Note 25 'Staff

expenses' to the consolidated statement of profit or loss.

Actions on privacy

With regard to safeguarding our employees' wellbeing against the risk of

unauthorised access, misuse, or exposure of personal data like address,

remuneration, review assessment scores, outside interests or concerns

raised, we have a Global Personal Data Protection Internal Policy in place.

See the 'Consumers and End Users' section for more details on our policy

and actions regarding privacy.

Whistleblower Policy

Regarding the risks and negative impacts related to ‘measures against

violence and harassment’, our Whistleblower Policy provides instructions

on treating concerns in a careful and proportionate manner, aimed at

ensuring that ING takes appropriate, lawful, and timely action in case of

concerns related to human rights by or within ING. Read more about our

Whistleblower Policy in the ‘Business conduct’ section.

Our actions against violence and harassment in the workplace

We are committed to upholding both the requirements set by human

rights, laws, and regulations, as well as the exacting standards of our

Orange Code and Global Code of Conduct, through which we can fulfil our

purpose of empowering people while countering potential negative

impacts and risks related to, for example, violence and harassment. Read

more about our Global Code of Conduct in the 'Business conduct' section.

In line with our Whistleblower Policy and related control standards, we

categorise and monitor all reported concerns. This overview reflects issues

raised through our dedicated whistleblower channel concerning our own

workforce. All whistleblower reports received and addressed are reported

quarterly by the ING Group Chief Compliance Officer to the Supervisory

Board Risk Committee.

Whistleblower concerns are grouped into categories that link to

internationally recognised human rights:

§Discrimination;

§Aggression, violence, and bullying;

§Breach of confidentiality and data privacy related to an employee;

§(Sexual) Harassment;

§Work-pressure/unrealistic targets; and

§Retaliation

To understand if any of the whistleblower cases concern a severe human

rights incident, we apply three elements of severity: scale, scope, and the

remediability of the impact to the whistleblower categories mentioned

above. Based on our assessment, no severe human rights incidents

connected to our own workforce were identified in the reporting period

(2024: nil).


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Consumers and end-users

Consumers and end-users of ING’s services include companies and private

individuals who we provide our services to. We focus in this section on

private individual customers within our Retail Banking domain, also

referred to as our ‘customers’. At ING, we strive to make access to our

products fair and our communication transparent, and to respect the

rights of our customers when providing our services. This includes

mitigating impacts and risks related to access to quality information, social

inclusion, and privacy.

We are committed to ensure fair access, transparent communication, and

respect for customer rights, while mitigating risks related to information

access, social inclusion, and privacy. These topics are especially relevant

for customers in vulnerable positions, such as elderly individuals or those

with temporary or permanent disabilities, chronic illness, or reading

difficulties, who may be more susceptible to harm or exclusion without

appropriate care.

Customer strategy: Superior customer value

We strive to make banking easy, instant, personal, and relevant so

customers can stay up to date with all that ING offers. We aim to clearly

price products and services, avoid complicated jargon, and always be

accessible. And as part of our accessibility strategy of ‘Leave no one behind’,

we strive for the inclusion of all our customers, with and without disabilities.

Access to quality information and social inclusion is important in

promoting financial health and accessibility. Enhancing financial literacy is

also essential to empower customers to make informed decisions. These

topics, along with related issues such as non-discrimination, access to

products and services, and responsible marketing, are validated through

our customer-centric compliance risk assessment.

Additionally, safeguarding customer privacy and data security is a key

compliance and reputational priority, reflecting our responsibility to

protect personal information. We manage related risks by continuously

assessing the regulatory environment for updates and implementing

these in line with our governance measures. This ensures we remain

compliant while safeguarding our strategy to provide superior customer

value. The processes for managing our risks and impacts, as laid out in this

section, are integrated into existing risk management and compliance

processes.

Policies, actions and performance

Customer Centricity Policy

ING offers customers a large variety of financial products and services, so

we face different risks and are subject to a multitude of regulations. Our

Customer Centricity Policy (CCP) helps in preventing and mitigating

impacts and risks regarding the topics of social inclusion and access to

quality information, including mis-selling and unfair customer treatment.

For instance, we want all our customers to have equitable access to our

products and services, including persons with disabilities, which is why we

strive to comply with the procedures of our policies and apply controls.

After rolling out the first version of the CCP in 2024, we updated the policy

this year to bring elements such as discrimination and access to banking

into the Compliance Risk Framework. In practice, this means we apply

global minimum standards for these issues, which aim to support us in

identifying severe human-rights incidents in the future. Our governance

framework, supported by continuous policy reviews, risk assessments, and

regulatory change implementation, enables us to address material risks

related to discrimination, inclusivity, and access to information in a timely

and effective manner.

The CCP defines high-level obligations to ensure ING handles risks

appropriately and in line with regulations. We want to offer products and

services suitable for our customers throughout the whole relationship

lifecycle at a fair price, considering the market, costs, and risks. We

monitor internal controls and processes, such as our Product Review and

Approval Process (PARP), in which relevant elements of customer centricity

are considered and challenged. The CCP requires us to communicate

information on products and services in a clear and non-misleading

manner, and provide services and trusted advice through professionals

with the necessary knowledge and expertise. In doing so, we also consider

the ESG risks and impact of our products and services on customers.

Having a global CCP enables us to align and assess whether customer

centricity is applied to all products and customers across ING. Norms we

formalised into minimum standards include the need to only create and

sell products that are in the interests of customers and society, an aligned

standard on complaints processes, the provision of clear and accessible

information that is at all times fair and not misleading, and the

assessment of the needs of individual customers – both when we sell a

product and when the customer uses a product. With these, we aim to

mitigate potential and actual financial distress for individual customers,

resulting from not having access to products, services and/or quality

information.

Complaints and remediation process

In addition to our general engagement activities, we use our complaints

channels to gain a clearer picture of the impacts we have on our

customers. The insights we gain from complaints help us implement

structural improvements in our products and processes. The CCP sets out

the minimum requirements for complaints procedures across all ING

entities, including the need for transparency about the process and

keeping customers informed of the progress in handling their complaint.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	43

All complaints must be assessed regularly, and root cause analyses must

be carried out to mitigate the risks of customer harm. The CCP also aims

to ensure that customers can raise complaints about ING’s financial

products through third parties, including distributors, brokers, and

manufacturers. There are several ways our customers can file a

complaint. Within nearly all our Retail markets there is at least one

assisted channel available (e.g. call centre, branch, human chat, social

media), and at least one self-service channel (e.g. mail, e-mail, online

channels app and web) where customers can file a complaint, which will

then be handled by a human agent.

Customers are made aware of these channels via publicly available

information e.g. ING websites (FAQs and search engine) and via the Terms

& Conditions provided to customers during onboarding. Furthermore, a call

centre, branch and/or a chat agent can provide further information

regarding the complaints processes when a customer contacts ING. We

value our customers and take their concerns seriously. While this is not

embedded in our customer-focused policies, we do not tolerate retaliation

by any employee. For our anti-retaliation measures included in our

Whistleblower Policy, see the ‘Business conduct’ section.

We manage complaints primarily through contact centres and when

possible complaints are solved on initial contact. If unresolved, they

escalate to specialised teams. We evaluate the complaints handling

process, for instance, through an assessment of the time it takes to resolve

complaints and how frequently we do so. A change in products, financial

compensation, and/or apologies can help to address any negative impacts

on customers. We analyse complaints to implement structural changes in

products, processes, policies, procedures, and communication, and involve

relevant risk parties and internal stakeholders as needed. We have

established channels and procedures to ensure that customers are aware

of and have confidence in our complaints procedures. However, we do not

assess this confidence separately. Instead, if concerns about our

complaints procedures are raised, we consider these within our broader

evaluation of customer concerns.

Over the course of 2025, ING implemented a minimum set of

standardised labels on human rights (like discrimination, accessibility,

privacy), customer centricity and ESG. These labels are applied to

complaints, further enabling us to perform root-cause analyses and to

rectify service breakdowns, improve the customer journey, address

potential human rights issues and provide appropriate remedy, help

senior management better understand customer protection and further

strengthen customer trust.

An assessment for severe incidents was conducted using our internal issue

management system. Through this process no severe human rights

incidents were identified in 2025.

Actions on access to quality information and social inclusion

ING has implemented the requirements of the European Accessibility Act

and remains committed to further optimising and improving accessibility

across all customer‑facing services in our EU Retail Banking countries. This

implementation is supported by a dedicated accessibility team, whose

main objectives are to safeguard accessibility within ING, raise awareness

of this topic, and provide advice and coordination across countries.

We strive to make ING more accessible and inclusive for our customers. For

example, we have introduced voice-activated ATMs in certain countries to

help people with visual impairments to withdraw money. We also issue

bank cards with a physical notch that allows customers with visual

impairments to quickly identify the correct card by touch. In certain

countries, customers with visual impairments can also use screen readers

– software applications that read aloud on-screen information.

To further mitigate potential material negative impacts and risks related to

social inclusion, we are collaborating with the United Nations Environment

Programme Finance Initiative (UNEP FI) under the Principles for Responsible

Banking to contribute to setting a measurement standard for financial

health impact for our industry. As a founding signatory of the

Commitment to Financial Health and Inclusion, we aim to reduce

financially vulnerable or unhealthy households. We use technology to

create innovative digital tools that encourage customers to build savings

and manage their expenses, which have been implemented in multiple

European locations. For more information on financial health, see ing.com.

Compliance policies, such as the CCP, are implemented in the locations we

operate in. Outcomes of our monitoring, complaints analyses, event

analysis or regulatory interactions, are recorded as an issue in our global

database. We monitor and address issues on a local and global level. In

addition, CCP standards and compliance risks are subject to continuous

monitoring and, in line with our risk-based approach, undergo periodic

assessment and measurement. In relation to products and services, we

perform periodic reviews in the context of the Product Approval and

Review Process, which may lead to the remediation of a product if, for

example, it is considered unfit for our customers.

Global Personal Data Protection Policy

Just as we strive to enable customers to engage with ING without issue or

interruption, we aim to protect the personal data they provide to us

throughout their ING journey. In line with the EU's General Data Protection

Regulation (GDPR) and other applicable data protection requirements, ING

aims to only process personal data for a specific business purpose in a fair

and lawful manner, observing the rights and liberties of data subjects in

scope of our activities. To fulfil this ambition, ING has implemented a

Global Personal Data Protection Policy (GPDP), which reflects the

requirements based on laws and regulations, industry standards, and ING’s

internal risk appetite. This GPDP contains specific requirements and

controls, which ensure the necessity and accuracy of the personal data

ING is processing. The GPDP helps in preventing and mitigating impacts

and risks regarding the topic of (data) privacy.

It is our policy to have operational flows in place regarding data subject

rights (such as the right to access personal data, right to erase personal

data that no longer needs to be retained, right to object to data processing

etc.), and to ensure that these rights are adequately provided to all

individuals whose personal data is subject to processing. This means ING

has implemented operational flows to handle requests – such as access to

personal data, amendments/corrections, or objections to data processing –

promptly and in line with regulatory requirements.

In accordance with our policies, we strive to be transparent about what we

do with the personal data of customers, employees, suppliers and business

partners, as well as who we share personal data with and why. We want


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	44

our business entities, support functions, and the third parties we engage

with, to grant a level of protection to the data subject equivalent to that

guaranteed by the GDPR, especially if personal data is transferred outside

of the European Economic Area. Part of the data protection scope is that

personal data is managed in a safe and secure manner, in line with current

information security standards. For more information, see the Privacy

Statement on ing.com.

Actions regarding Privacy

ING manages personal data protection and retention risks and impacts via

the Global Data Protection and Global Record Retention and Deletion

frameworks and control standards. Potential material impacts are

identified and addressed by relevant data protection risk assessments

such as:

§The Data Protection Impact Assessment – performed at processing

activity level and allows for an in-depth scrutiny of personal data

processing activities in line with applicable regulations and data

protection principles;

§The Legitimate Interest Assessment – performed to assess whether ING

can rely on legitimate interest as a lawful basis in case of certain

personal data processing activities. In the case of this assessment the

legitimate interests of ING are considered and balanced against the

interests and rights of individuals in scope of the processing; and

§The Transfer Impact Assessment – performed in case personal data is

transferred to a non-EEA country. In this case the soundness of

contractual and technical protective measures and controls is

assessed.

All assessments mentioned lead to concrete risk identification and impact

mitigation measures, which are implemented on a granular level (business

process- or IT asset-level). This enables ING to continuously identify,

manage and limit relevant data protection risks, as data protection risk

assessments represent an integral part of defining new business processes

or introducing changes to existing ones.

Equally, personal data protection considerations are assessed and

documented at product level, within the PARP process. The data protection

framework includes policies and control standards that are continuously

monitored and, in line with our risk-based approach, periodically assessed

and measured.

In the case of security incidents impacting personal data (e.g. data

breaches) it is our policy to take the necessary containment and

mitigation measures as soon as possible after identifying such an

occurrence. As part of this policy we assess related data protection risks

and impacts, and determine whether external reporting to supervisors is

required, ensuring compliance with regulatory requirements. Based on the

incident’s impact and risk, we conduct ‘lessons learned’ sessions to

improve workflows and prevent similar future occurrences, strengthening

the protection of customer personal data. These lessons learned take into

account, first and foremost, the potential or actual impact of a data

breach occurrence on affected customers.

The effectiveness of our data protection and retention controls is

monitored and tested periodically as part of the ING Key Control Testing

framework. Data protection and retention controls are managed in line

with implemented data protection governance. Dedicated first- and

second-line teams, along with the Data Protection Executive Office and

Data Protection Compliance, support relevant business process, asset and

contract owners in identifying and managing data protection and

retention risks, including implementing appropriate mitigation measures.

For 2025, we delivered relevant improvements of the personal data

protection framework, focusing on implementing controls for data

retention and deletion, and enhancing the Data Protection Policy. We

continuously optimise data protection processes to ensure data protection

requirements are embedded in relevant business processes in full

compliance.

Metrics and targets

We aim to limit the number of complaints and/or breaches related to

access to quality information, social inclusion, data privacy, and associated

reputational risks. If these occur, we take actions to remediate risks and

impacts, as described in the previous paragraph. For our reputational risks,

we have a Compliance Risk Framework, which contains risk appetite

indicators used for internal monitoring.


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Business conduct

Our culture drives the way we do business and

impacts all our stakeholders. We are guided by

ING’s Orange Code, which sets our values and

behaviours and ensures we work with integrity,

transparency, and high standards of business

ethics. Our employees are encouraged to speak up

and report concerns, and have a zero-tolerance

approach to any form of bribery and corruption.

Business conduct refers to the way we do business. Our Global Code of

Conduct reflects the standards we must adhere to, and includes our

values, principles, and ethical standards. Business conduct includes

matters such as business ethics and corporate culture, including anti-

corruption and anti-bribery, and the protection of whistleblowers – and

these are the specific sustainability matters we have identified.

Policies, actions and performance

Corporate culture – integrity above all

Our operations touch many lives: customers, employees, shareholders,

and society at large. Everyone within these groups has a reasonable

expectation that we act with integrity. At ING, we all have a duty to put

integrity above all we do and to live up to the values we hold. We will not

ignore, tolerate or excuse behaviour that breaches our values. To do so

would break the trust of society and the thousands of great colleagues

who do the right thing to take this company forward every day.

Our corporate culture starts with the Orange Code – it is a declaration of

who we are, with the overarching principle of ‘integrity above all’. While

the Orange Code sets out general values and behaviours, the ING policies

and guidelines are much more specific and state the rules in more detail.

The ING Global Code of Conduct is the link between the Orange Code and

the main ING policies and guidelines.


Our values and behaviours	Main ING policies and procedures

	Business Conduct Framework

The Orange Code is a manifesto that describes our way of working. It comprises our values and behaviours	Orange Code	ING Global Code of Conduct	Whistleblower Policy
	Global Investigations Charter


Zero tolerance on corruption and bribery	Anti-bribery and Corruption Policy	ABC High-Risk Roles Guidance	Global Event Management Procedure

The table above outlines the main policies and procedures within ING's

Business Conduct Framework, with key policies highlighted in bold. All

policies are subject to Internal Control Binding Principles (ICBP), which set

the standard for the entire lifecycle of the policy and apply to all ING

Business Units (i.e. all branches and majority-owned subsidiaries of ING

Groep N.V.). In accordance with ICBP, policies are reviewed in full at a

minimum every three years (unless otherwise approved), and checked, at

least annually, for alignment with relevant laws and regulations and

current practice. Policies, procedures and guidelines are available and

easily accessible for all staff on the ING intranet. The Orange Code and

Global Code of Conduct are available for external stakeholders on ing.com.

In addition to the abovementioned policies, ING has several internal

processes and guidelines in place to provide guidance towards the actions

and monitoring of the risks and policies.

The following processes and guidelines are linked to the global policies:

§The Global Investigations Charter specifies which incidents are to be

investigated under the local or global responsibility of Corporate Special

Investigations (CSI), and how the investigation is to be initiated,

conducted, and resolved. It defines the governing principles for

organising, managing, and conducting the investigations function

within ING.

§The Global Event Management Procedure outlines the processes for the

management of operational risk events, as well as the roles and

responsibilities for mitigating the impact of such identified events and

their related reporting.

§The AB&C High-Risk Role Guidance defines job activities considered to

be at risk or vulnerable from the bribery and corruption risk perspective,

and provides the basis for enrolment to the AB&C HRR training.

Training and awareness are of great importance for policies to be effective.

To this end, we have developed global mandatory training for business

conduct-related policies.

The Orange Code

The Orange Code describes what we can expect from each other when we

turn up to work each day. It is a set of standards that we collectively value,

strive to live up to, and invite others to measure us by. The Orange Code

comprises the ING values and the ING behaviours:


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Values	Behaviours
We are honest	You take it on and make it happen.
We are prudent	You help others to be successful.
We are responsible	You are always a step ahead.

The Orange Behaviours are embedded in commitments we make to each

other and the standards by which we measure each other’s performance.

ING’s Global Code of Conduct

Building on the values and behaviours of our Orange Code, the ING Global

Code of Conduct outlines the 10 conduct principles expected from

employees. The Global Code of Conduct aims to prevent and protect our

employees from making unethical and/or illegal decisions within ING’s

day-to-day business. Prevention of bribery & corruption (AB&C), and

whistleblowing (speaking up), are among those 10 core principles. Conduct

principles are further governed via their respective policy frameworks.

ING launched a new global mandatory training on the Global Code of

Conduct in 2025, and new joiners are expected to undertake the training

upon joining ING. At the conclusion of the e‑learning module, employees

are required to acknowledge their understanding of and commitment to

complying with the Global Code of Conduct, which is actively monitored.

Risk culture

At ING, we attach great importance to a sound risk culture, which is

essential for performing our role in society responsibly and for keeping the

bank safe and secure. We determine our risk culture as: the way in which

employees identify, understand, discuss, and act on many financial and

non-financial risks we are confronted with every day. On an annual basis,

we monitor the progress of our risk culture maturity and furthermore, risk

culture is actively discussed by the Management Board Banking and the

Supervisory Board on a bi-annual basis. In 2025, ING further strengthened

its risk culture by promoting organisational learning as a bank-wide

priority with a key focus on enhancing lessons learned practices.

Behavioural risk

Behavioural risk is an increasingly important area for ING and across the

financial industry. It arises when behavioural patterns are at the root of

financial and non-financial risks in the organisation. The complexity of this

type of risk is that it is less tangible compared to other risk areas because it

focuses on behavioural patterns and their drivers. There are patterns in how

decisions are made, how people communicate, and whether they can and

are willing to take ownership. Behaviour is driven by formal and informal

mechanisms. Examples of formal drivers are the processes ING applies and

how its governance is structured. Informal drivers are less tangible, such as

group dynamics or underlying beliefs that influence behaviour.

Behavioural risk assessments

Behavioural risk assessments identify and analyse undesired behaviours

within ING and provide management with specific direction on how to

change these behaviours. They focus on the effectiveness of groups rather

than individuals, the role of leadership, and on less visible aspects such as

team dynamics and unwritten social norms. The goal is to understand and

systematically assess what drives undesired habits at ING. The behavioural

risk management framework is used as a guide across ING to identify

behavioural risks in the organisation that require deeper investigation.

Behavioural risk interventions

Based on the results of the executed behavioural risk assessments,

interventions are taken to mitigate the behavioural risks in a focused

manner. Effective mitigation requires a deep understanding of what drives

undesirable behaviours. Behavioural and organisational science theories

and evidence-based techniques and tools play an important role in

designing and facilitating interventions.

Whistleblower Policy

At ING we systematically look for ways to enhance and harmonise our

‘speak up’ channels. Speak-up concerns can be reported via a variety of

channels, in particular to managers, HR, confidential advisers,

Whistleblower Reporting Officers or via our (anonymous) whistleblower

reporting platform. We want our employees to feel safe to raise concerns

and to be confident that we will adequately address reported concerns.

We encourage and support employees in raising whistleblower concerns

through any reporting channel. All reports are handled with the highest

level of confidentiality, and we clearly communicate reporters’ rights and

responsibilities. Concerns reported via a whistleblowing channel are, when

in scope of the Whistleblower policy, reviewed by an ING Whistleblower

Reporting Officer to assess if there is sufficient ground for an investigation.

The global Whistleblower Policy and procedure, together with the Global

Investigations Charter, set out the minimum requirements to ensure

concerns are handled fairly, timely, proportionately, and with care.

Robust anti-retaliation measures are in place to protect whistleblowers.

ING does not tolerate any form of retaliation by any employee, including

(senior) management. It is strictly prohibited to retaliate against a reporter

or anyone providing information or assisting in an investigation.

External parties can report suspicions and complaints on misconduct or

behaviour via the pages ‘Whistleblower policy’ (shareholders and suppliers)

and 'Complaints about our conduct' (customers and other stakeholders)

on ing.com.

There is a global mandatory training for employees to educate them on

the whistleblower channel, anonymity and confidentiality, their rights and

responsibilities as reporters, the importance of awareness on retaliation,

and how the follow-up on concerns is handled. We actively monitor the

timely completion of the e-learning. Alongside the global support

community, a specialist learning journey provides Whistleblower Reporting

Officers with a one‑stop resource for mandatory obligations, investigative

interviewing, guidance, and templates.

ING entities have created local policy annexes where necessary in case of

specific local legal requirements based on the transposition of the EU

Directive 2019/1937 on the protection of persons who report breaches of

Union law/Whistleblowing into national law.

Anti-bribery and Corruption Policy

We are committed to doing business in an honest, prudent and

responsible manner and aim to ensure compliance with applicable AB&C

laws and regulations. ING’s AB&C Policy outlines the obligations, key risks,


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	47

and control objectives that are necessary to ensure that bribery and

corruption risks are identified, assessed, managed, and monitored

accordingly.

ING has a zero-tolerance approach to bribery and corruption in all its

relationships and business dealings. ING does not permit accepting or

paying bribes or offering improper inducements or anything that could be

perceived as such. ING expects the same from its business partners and

third parties that perform services or deliver business on its behalf.

Investigations into possible breaches of anti-bribery regulations are the

responsibility of CSI, as we want to ensure independence, objectivity,

impartiality, and confidentiality. ING entities are required to report

instances of bribery and/or corruption, in accordance with the Global Event

Management Procedure. This includes reporting to the Management Board

Banking and chairperson of the Supervisory Board.

ING has a key risk indicator in place to monitor its zero-tolerance policy on

bribery and corruption by ING employees or third parties on a monthly

basis. Reporting is based on event data from ING’s Non-Financial Risk (NFR)

Management tool, iRisk, which captures NFR-related events and provides

standard reports for risk monitoring.

During 2025, there were no instances of convictions and fines related to

violations of AB&C laws (2024: nil).

ING published an updated AB&C Policy, effective 1 July 2025, on our

intranet and on ing.com. The policy is aligned with relevant local and

international laws, including the US Foreign Corrupt Practices Act and the

UK Bribery Act.

Global mandatory training on AB&C has been designed to provide all

employees, including contingent workers, with an understanding of the

bribery and corruption risks faced by ING, the risks they may be exposed

to, and how ING manages these risks. New joiners are expected to

undertake the training on joining ING. The goal of the training is to enable

the learners to:

§recognise the importance of our role in fighting bribery and corruption;

§understand the consequences of bribery and corruption on society and

the organisation;

§recognise how we identify, manage, and mitigate potential bribery and

corruption risks; and

§escalate any suspicious behaviour or suspicions of potential bribery or

corruption risks through appropriate channels.

ING has an approach to identify the roles with an increased exposure to

bribery and corruption risks, known as High-Risk Roles (HRR's). The HRR

Guidance defines, in detail, the job activities considered to be at risk or

vulnerable from a bribery and corruption risk perspective. For more

information on the criteria, see ‘Definitions of our environment, social and

governance metrics’ in the Appendix to the Executive Board report.

Employees in a High Risk Role (HRR) are enrolled in a targeted e-learning

(updated November 2025). It covers the following key areas of activity:

§AB&C regulatory requirements relating to anti-bribery and corruption,

the risks for the financial industry, and the impact of a regulatory

breach;

§ING gifts & entertainment rules;

§enhanced risks associated with public officials; and

§bribery and corruption risks in the hiring process; and when engaging

with third parties.

Both the global mandatory and HRR training completion by employees is

monitored. In 2025 97 percentof employees completed the global

mandatory training on AB&C (2024: 98 percent and 89 percentof eligible

employees completed the HRR training (2024: 89 percent).

In 2025 the management boards and Supervisory B were offered a training

session that:

§provided an overview of global AB&C laws along with business activities

vulnerable to bribery and corruption risks;

§reinforced the critical role of leadership in upholding ING’s zero-

tolerance stance on bribery and corruption; and

§fostered interactive group discussions that highlighted bribery and

corruption risks.


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Regulation and Supervision

The banking and broker-dealer businesses of ING are subject to detailed

and comprehensive supervision in all of the jurisdictions in which ING

conducts business.

Regulatory agencies and supervisors have broad administrative power and

enforcement capabilities over many aspects of our business, which may

include liquidity, capital adequacy, permitted investments, ethical issues,

money laundering, anti-terrorism measures, privacy, recordkeeping,

product and sale suitability, marketing and sales practices, ESG,

remuneration policies, personal conduct and our own internal governance

practices. Also, regulators and other supervisory authorities in the EU, the

US and elsewhere continue to scrutinise payment processing and other

transactions and activities of the financial services industry through laws

and regulations governing such matters as money laundering, anti-

terrorism financing, tax evasion, prohibited transactions with countries or

persons subject to sanctions, and bribery or other anti-corruption

measures.

As discussed under “Item 3. Key Information - Risk Factors”, as a large

multinational financial institution we are subject to reputational and other

risks in connection with regulatory and compliance matters involving these

countries.

European Regulatory framework

The Single Supervisory Mechanism (“SSM”) is the first pillar of the Banking

Union and has been operational since 4 November 2014. The SSM consists

of the European Central Bank (“ECB”) and the national competent

authorities of the participating EU member states. The main objective of

European banking supervision is to ensure the safety and soundness of the

European banking system, enhance financial integration and stability and

ensure consistent supervision. Under the SSM, the ECB is the main

prudential supervisor of ING Group and ING Bank. The ECB's responsibilities

include tasks such as market access, compliance with capital and liquidity

requirements and governance arrangements. National competent

authorities, including the Dutch Central Bank (De Nederlandsche Bank or

“DNB”) for ING Group and ING Bank, remain responsible for supervising

tasks not transferred to the ECB such as financial crime and payment

supervision.

The SSM is complemented by the second pillar of the Banking Union, the

Single Resolution Mechanism (“SRM”), which consists of the Single

Resolution Board (“SRB”) and the national resolution authorities. The SRM

has been fully responsible for the resolution of banks within the Eurozone

since 1 January 2016.

As the third pillar of the Banking Union, the EU wants to further harmonise

the regulation for Deposit Guarantee Schemes (DGS). One of the key

elements is the creation of ex-ante funded DGS funds, financed by risk-

weighted contributions from banks. Since 2015, the EU has been

discussing a pan-European (or pan-banking union) DGS (the European

Deposit Insurance Scheme (EDIS)), which would (partly) replace or

complement national compensation schemes, but there is no EDIS yet as

political negotiations have stalled. On 18 April 2023, the European

Commission published the proposals for the revision of the common

framework for bank crisis management and deposit insurance (CMDI) that

focuses on small and medium-sized banks, but will affect all banks in the

EU. The CMDI framework consists of the Bank Recovery and Resolution

Directive (BRRD), the Single Resolution Mechanism Regulation (SRMR) and

the Deposit Guarantee Schemes Directive (DGSD). On 25 June 2025, the

Council and the European Parliament reached political agreement on the

reformed CMDI framework. The co-legislators are now expected to finalise

the legal text, after which the revised framework will be formally adopted

and enter into force.

Dutch Regulatory Framework

The Dutch regulatory system for financial supervision consists of

prudential supervision – monitoring the soundness of financial institutions

and the financial sector, and conduct-of-business supervision – regulating

institutions’ conduct in the financial markets. To the extent that prudential

supervision is not transferred to the ECB, it is carried out by the Dutch

Central Bank (De Nederlandsche Bank or “DNB”), while conduct-of-business

supervision is carried out by the Dutch Authority for the Financial Markets

(Autoriteit Financiële Markten or “AFM”).

Global Regulatory Environment

There are several legislative and regulatory proposals that could impact

ING globally, in particular the proposals of the Financial Stability Board and

the Basel Committee on Banking Supervision at the transnational level and

a growing set of supranational directives and national legislation in the

European Union (see “Item 3. Key Information - Risk Factors - We operate

in highly regulated industries. Changes in laws and/or regulations

governing financial services or financial institutions or the application of

such laws and/or regulations governing our business may reduce our

profitability"). The aggregated impact and possible interaction of all these

proposals is difficult to determine, and it may be difficult to reconcile them

if they are not aligned. The financial industry has also taken initiatives

through guidelines and self-regulatory initiatives.

Dodd-Frank Act and other US Regulations

ING Bank has a limited direct presence in the United States through the

ING Bank Representative Offices in New York, Dallas, Houston, and Los

Angeles. Although the offices’ activities are strictly limited to essentially

that of a marketing agent of lending and other similar products (i.e. the

offices may not take deposits or execute any transactions), the offices are

subject to the regulation of the State of New York Department of Financial

Services, the State of Texas Department of Banking, the California


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	49

Department of Financial Protection and Innovation, respectively, as well as

the Federal Reserve. ING Bank also has a subsidiary in the United States,

ING Financial Holdings Corporation, which through several operating

subsidiaries offers various financial products, including lending, and

financial markets products. These entities do not accept deposits in the

United States on their own behalf or on behalf of ING Bank N.V.

The ING subsidiary, ING Capital Markets LLC, is registered as a U.S. swap

dealer and subject to a statutory regulatory regime and CFTC rules and

oversight. As a result, it is subject to, among others, business conduct,

record-keeping and reporting requirements, as well as margin

requirements and capital requirements. In addition to the obligations

imposed on registrants (such as swap dealers), other requirements relating

to reporting, clearing, and on-facility trading have been imposed for much

of the off-exchange derivatives market and new risk management

requirements have been proposed focused on business continuity

generally. The proposed new risk management requirements could impose

significant compliance costs to the extent inconsistent with the existing

group-wide framework.

ING Capital Markets LLC is also registered as a security-based swap dealer

and is subject to a statutory regulatory regime and SEC rules and

oversight. The SEC has adopted regulations, among others, establishing

registration, reporting, risk management, business conduct, and margin

and capital requirements for security-based swaps. While ING Capital

Markets LLC, as a security-based swap dealer, is required to comply with

SEC rules with respect to most of these requirements, SEC rules have

permitted an “Alternative Compliance Mechanism” that allows for

compliance, subject to eligibility requirements, with CFTC capital and

margin rules applying to swap dealers in lieu of SEC capital and margin

rules applying to security-based swap dealers. ING Capital Markets LLC has

elected to use the Alternative Compliance Mechanism. However, should

ING Capital Markets LLC in the future be ineligible for the “Alternative

Compliance Mechanism”, it would be subject to SEC security-based swap

dealer rules for margin, capital, and related financial reporting instead of

the CFTC swap dealer rules applied to security-based swaps with respect to

margin, capital, and related financial reporting.

The Dodd-Frank Act also created an agency, the Financial Stability

Oversight Council (FSOC), an interagency body that is responsible for

monitoring the activities of the U.S. financial system, designating

systemically significant financial services firms and recommending a

framework for substantially increased regulation of such firms, including

systemically important non-bank financial companies that could consist of

securities firms, insurance companies and other providers of financial

services, including non-U.S. companies. ING has not been designated a

systemically significant non-bank financial company by FSOC and FSOC

initiating such a designation currently is deemed unlikely.

Dodd-Frank continues to impose significant requirements on us, some of

which may have a material impact on our operations and results, as

discussed further under “Item 3. Key Information - Risk Factors - We

operate in highly regulated industries. Changes in laws and/or regulations

governing financial services or financial institutions or the application of

such laws and/or regulations governing our business may reduce our

profitability”.

Basel III has been implemented in the EU and is currently applied

by ING

In all jurisdictions where the bank operates through a separate legal entity

that is a credit institution, ING must meet the local implementation of

Basel requirements. ING uses the Advanced and Foundation IRB Approach

for credit risk, the Internal Model Approach for its trading book exposures

and the Standardised Measurement Approach for operational risk. A small

number of portfolios including certain sovereign exposures are reported

under the Standardized Approach for credit risk.

In December 2010, the Basel Committee on Banking Supervision

announced higher global minimum capital standards for banks, and

introduced a new global liquidity standard and a new leverage ratio (LR).

The Basel Committee's package of reforms, collectively referred to as the

“Basel III” rules, among other requirements, increased the amount of

common equity required to be held by subject banking institutions,

prescribed the amount of liquid assets and the long term funding a subject

banking institution must hold at any given moment, and limited leverage.

Banks are required to hold a “capital conservation buffer” to withstand

future periods of stress. Basel III also introduced a “countercyclical buffer”

as an extension of the capital conservation buffer, which permits national

regulators to require banks to hold more capital during periods of high

credit growth (to strengthen capital reserves and moderate the debt

markets). Further, Basel III strengthened the definition of capital that had

the effect of disqualifying many hybrid securities, as well as increased

capital requirements associated with certain business conditions (for

example, for credit value adjustments (CVAs) and illiquid collateral) as part

of a number of reforms to the Basel II framework. In addition, the Basel

Committee and Financial Stability Board (“FSB”) published measures that

have had the effect of requiring higher loss absorbency capacity, liquidity

surcharges, exposure limits and special resolution regimes for, and

instituting more intensive and effective supervision of, “systemically

important financial institutions” (SIFIs), in addition to the Basel III

requirements otherwise applicable to most financial institutions. One such

measure, published by the FSB in November 2015, is the Final Total-Loss

Absorbing Capacity (TLAC) standard for G-SIFIs, which aims for G-SIFIs to

have sufficient loss-absorbing and recapitalisation capacity available in

resolution. Since 2011, ING has been designated by the Basel Committee

and FSB as a so-called “Global Systemically Important Bank” (G-SIB, or

Global Systemically Important Institution - G-SII in the European

legislation), and by DNB and the Dutch Ministry of Finance as a “other

SII” (O-SII) . Since December 2020 DNB has required ING Group to hold O-SII

Buffer in addition to the capital conservation buffer and the countercyclical

buffer described above. ING Group is subject to O-SII Buffer of 2.0% (from

31 May 2024 when DNB lowered it from 2.5% that applied previously). In

December 2025 DNB announced that it reviewed the identification and

buffer requirements for systemically important banks, and maintained

2.0% O-SII Buffer requirement for ING. The higher of G-SIB or O-SII buffers

applies, hence ING Group's risk-based capital requirements are not

affected by G-SII Buffer of 1%. However 50% of G-SII buffer increases ING's

Leverage Ratio requirement from a regular 3.0% (3.1% with 0.1% Pillar 2

requirement from 1 January 2026) that applies to non G-SII banks to 3.5%

(3.6 % including 0.1% Pillar 2 requirement from 1 January 2026).

For European banks the Basel III requirements have been implemented

through the Capital Requirement Regulation (CRR) and the Capital

Requirement Directive (CRD). The CRD IV regime entered into effect in


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August 2014 in the Netherlands, but not all requirements were

implemented all at once. Having started in 2014, the requirements have

been gradually tightened, mostly before 2019, until the Basel III migration

process was completed.

CRD IV has not only resulted in new quantitative requirements but has also

led to the setting of new standards and evolving regulatory and

supervisory expectations in the area of governance, including with regard

to topics like conduct and culture, strategy and business models,

outsourcing and reporting accuracy.

CRR II / CRD V and BRRD II

On 27 June 2019, a series of measures referred to as the Banking Reform

Package (including certain amendments to CRR and CRDIV commonly

referred to as ‘CRR II’ and CRD V’) came into force, subject to various

transitional and staged timetables. The adoption of the Banking Reform

Package concluded a process that began in November 2016 and marked

an important step toward the completion of the European post-crisis

regulatory reforms, drawing on a number of international standards

agreed by the Basel Committee, the Financial Stability Board and the G20.

CRDV was implemented in Dutch law in 2020. The Banking Reform Package

introduced changes to the CRR, CRD IV, the Bank Recovery and Resolution

Directive (BRRD) and the Single Resolution Mechanism Regulation (SRMR).

The Banking Reform Package covered multiple areas, including the Pillar 2

framework, the introduction of a leverage ratio requirement of 3% and a

leverage ratio buffer requirement of 50% of the G-SIB buffer requirement

(applicable per 1 January 2023), a binding Net Stable Funding (NSFR) ratio

based on the Basel NSFR standard (including adjustments with regard to

e.g. pass-through models and covered bonds issuance), mandatory

restrictions on distributions, permission for reducing own funds and eligible

liabilities, macroprudential tools, a new category of ‘non-preferred’ senior

debt, the minimum requirement for own funds and eligible liabilities

(MREL) and the integration of the TLAC standard into EU legislation.

Further, the EBA obtained a mandate to investigate how to incorporate

environmental, social, and governance (ESG) risks into the supervisory

process and what the prudential treatment of assets associated with

environmental or social objectives should look like.

Whilst the Banking Reform Package was being developed, the ECB

introduced the Targeted Review of Internal Models (TRIM) in June 2017 to

assess reliability and comparability between banks’ models for calculating

each bank’s risk-weighted assets (‘RWA’) used for determining certain of

such bank’s capital requirements. In July 2019, the ECB published the final

chapters of the guide to internal models, covering credit risk, market risk

and counterparty credit risk. These risk type-specific chapters are intended

to ensure a common and consistent approach to the most relevant

aspects of the regulations on internal models for banks directly supervised

by the ECB. Additionally, they provided transparency on how the ECB

understands the regulations on the use of internal models to calculate

own funds requirements for the three risk types. Impact on ING is through

more stringent regulation on the end-to-end process and governance

around internal models as well as an increase of risk weighted assets

(RWA).

In 2020, the last TRIM ECB inspection ended. Most of the remedial actions

triggered by the TRIM assessments resulted in the redevelopment of the

credit risk models and were addressed. Most remedial actions have been

implemented, with limited remaining.

CRR “quick fix” in response to the Covid‐19 pandemic

On 26 June 2020 Regulation (EU) 2020/873 of the European Parliament

and of the Council of 24 June 2020 amending Regulations CRR as regards

certain adjustments in response to the COVID-19 pandemic (commonly

referred to as CRR ”quick fix”) was published.

The CRR ‘quick fix’ introduced certain adjustments to the CRR, including

temporary measures and measures that early adopt changes in the

regulations that were intended to become effective at a future date. This

notably included reduced capital requirement for certain exposures to

small- and medium sized enterprises (SMEs), a more favourable prudential

treatment for certain software assets, one year delay in the application of

the leverage ratio buffer requirement of 50% of the G-SIB buffer (to 1

January 2023). Also, the ‘quick fix’ extended by 2 years transitional

arrangements for mitigating the impact on own funds of the introduction

of IFRS 9 (Article 473a (8) of CRR).

CRR III / CRD VI

On 27 October 2021, the European Commission published a legislative

proposal to review the EU’s CRD/CRR framework. The review consisted of

the following legislative elements: a proposal to amend CRD V ("CRD VI"), a

proposal to amend CRR II ("CRR III"), and a separate, targeted proposal to

amend CRR II in the area of resolution.

This proposed legislative review was to implement the final Basel III

framework – agreed at the end of 2017 - in the EU. The revisions mainly

related to the prudential standards for credit, market, operational and

credit valuation adjustment (CVA) risk as well as the introduction of an

output floor. Key changes comprise the reduced use of internal models

and more risk-sensitive and granular standardised approaches. It aimed to

increase consistency in risk-weighted asset calculations and improve

comparability of bank capital ratios. The Commission’s proposal remained

close to the 2017 Basel agreement, but in some areas included targeted

measures to account for specificities of the EU banking sector. These

measures mitigate until 2030-2032 the impact of the Output Floor for

lending to unrated corporates, low risk mortgages, and some other

categories.

While most CRR III amendments entered into force on 1 January 2025,

some provisions will be phased-in over subsequent year. Specifically, the

output floor will be generally phased in over 5 years with some of the

output floor and general phase-in provisions lasting until 2032. CRR III also

requires secondary legislation, much of which has yet to be finalized.

CRD VI requires EU Member States to transpose its provisions into national

law by 10 January 2026, with most measures applying from 11 January

2026. In the Netherlands, a draft legislation was published in April 2025,

followed by a revised version in October 2025. However, legislation has not

yet been finalised or enacted.

Capital requirements applicable to ING Group at a consolidated level

In accordance with the CRR the minimum Pillar 1 capital requirements

applicable to ING Group are:

§in terms of the Risk Weighted Assets (RWA): 4.5% of Common Equity

Tier 1 (CET1), 6% of Tier 1 and 8% of Total capital.

§in terms of the Leverage Exposure: 3% of Tier 1.


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For the Leverage Exposure, the overall Pillar I requirement is 3.5% of Tier 1

(including 0.50% G-SIII buffer).

In terms of the risk weighted capital requirements, ING Group is also

subject to the Combined Buffer Requirement that consists of the Capital

Conservation Buffer of 2.5%, the O-SII buffer (buffer for Other Systemically

Important Institutions) of 2.0%, the Countercyclical Buffer (CCyB) of 0.93%

and Systemic Risk Buffer (SyRB) of 0.16%. ING Group is subject to SyRB

because: 1) ING Group has exposures in Germany, Belgium and Norway

that are in scope of SyRB set in those countries, and 2) De Nederlandsche

Bank (DNB) recognised SyRB set in those countries (while initially the

recognition did not apply at the consolidated level, DNB adjusted it so that

it applies at consolidated level from December 2025).

These buffers rates may fluctuate. Specifically, the following authorities

adjusted the CCyB recently: De Nederlandsche Bank (DNB; for exposures in

the Netherlands), Narodowy Bank Polski (NBP; for exposures in Poland)

Bundesanstalt für Finanzdienstleistungsaufsicht (BaFin; for exposures in

Germany) and National Bank of Belgium (NBB; for exposures in Belgium).

DNB increased the CCyB to 2% from May 2024. NBP increased the CCyB to

1% from September 2025 (planned increase to 2% from September 2026).

DNB and NBP intend to apply a 2% CcyB in a standard risk environment.

BaFin decided to set the CCyB at 0.75% from February 2023. NBB increased

the CCyB to 1% from October 2024 (planned increase to 1.25% from July

2026). Other authorities announced increases too.

For more information reference is made to Note 46 ‘Capital management’

and ‘Capital management’ in Additional Information.

In accordance with the CRD IV, ING Group is also subject to Pillar 2 capital

requirements that supplement Pillar I capital requirements. Pillar 2

requirements are bank specific and for ING Group they are determined by

the ECB. As of 31 December 2025, Pillar II capital requirement for ING

Group are in terms of the Risk Weighted Assets (RWA) is 0.93% of Common

Equity Tier 1 (CET1), 1.24% of Tier 1, 1.65% of Total capital. As of 1 January

2026, these will increase to 0.96%, 1.28%, 1.70%, respectively.

Additionally, from 1 January 2026, ING group will be subject to Pillar II

requirement in terms of the Leverage Exposure of 0.1% of Tier 1. The ECB

reviews Pillar II requirements every year.

Bank recovery and resolution directive

The BRRD aims to safeguard financial stability and minimise the use of

public funds in case banks face financial distress or fail to comply with the

BRRD. Since 2014 banks across the EU need to have recovery plans in place

and need to cooperate with resolution authorities to determine, and make

feasible, the preferred resolution strategy. The banking reform which came

into force on 27 June 2019 includes changes to the minimum requirement

for own funds and eligible liabilities (MREL) to ensure an effective bail in

process. It also includes new competences for resolution authorities and

requires G-SIBs and other banks to build up loss-absorbing and

recapitalization capacity.

In April 2023 the European Commission published a legislative proposal to

review the EU’s existing bank crisis management and deposit insurance

(CMDI) framework, with a focus on medium-sized and smaller banks. Based

on the political agreement of co-legislators from June 2025: 1) DGS or

resolution funds could be used to finance the resolution as a last resort, 2)

criteria for assessment whether the resolution can be initiated would be

broadened, 3) assessment to determine whether a bank should be able to

use the resources of the DGS will be harmonised, 4) current preference of

DGS protected deposits is maintained with a second tier of deposits of

households and SME depositors not covered by the DGS. Based on the

initial draft proposal, majority of the changes would apply from 18 months

from the date of entry into force. Final legislation is yet to be published.

ING has had a recovery plan in place since 2012. The plan includes

information on crisis governance, recovery indicators, recovery options,

and operational stability and communication measures. The plan

enhances the bank’s readiness and decisiveness in case of a financial crisis.

The plan is updated annually to make sure it stays fit for purpose. The

completeness, quality and credibility of the updated plan is assessed each

year by ING’s regulators.

The Single Resolution Board (SRB) confirmed to ING in 2017 that a single-

point-of-entry (SPE) strategy is ING’s preferred resolution strategy, with

ING Groep N.V. as the resolution entity.

In July 2025, ING Group received an updated formal notification from De

Nederlandsche Bank (DNB) of its MREL requirements. The MREL

requirement has been established to ensure that banks in the European

Union have sufficient own funds and eligible liabilities to absorb losses and

to recapitalize bank in the case of a resolution. The MREL requirement is

set for ING Group at a consolidated level, as determined each year by the

Single Resolution Board (SRB). The following MREL requirements for ING

Group were applicable on 31 December 2025: 22.62% of RWA, and 7.24%

of LR exposure. MREL requirements are updated every year.

CRR II implements the Financial Stability Board’s total loss absorbing (TLAC)

requirement for Global Systemically Important Institutions (G-SII), which is

the EU equivalent of a G-SIB. The transitional requirement - the higher of

16% of the resolution group’s RWA or 6% of the leverage ratio exposure

measure - applied immediately. The higher requirement - 18% and 6.75%,

respectively - came into effect as of 1 January 2022. ING is required to

meet both the TLAC and requirement.

On top of MREL and TLAC RWA requirements, ING Group is required to

meet the Combined Buffer Requirement (CBR) of 5.60% of CET1 (as of 31

December 2025). Fully loaded CBR (that reflects measures already known

on 31 December 2025 but not yet applicable) would amount to 5.63%. ING

Group meets these requirements. If ING Group breaches the CBR on top of

MREL/TLAC (M-MDA), ING may face restrictions on dividend payments, AT1

instruments coupons and payment of variable remuneration.


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In addition to the requirements for the Group on a consolidated level,

internal MREL requirements are also set for individual ING subsidiaries in

the EU.

Regulatory liquidity ratios

In line with the CRR, ING Group is required to comply with:

§the Liquidity Coverage Requirement (LCR) that is designed to ensure

that banks hold enough liquidity assets to cover for net liquidity

outflows under stressed conditions over 30 days. The required LCR ratio

is 100%.

§The Net Stable Funding Requirement (NSFR) that is designed to ensure

that banks hold sufficient stable funding to meet their funding needs

over a one-year horizon under both normal and stressed conditions.

The required NSFR ratio is 100%.

For more information reference is made to "Funding and liquidity risk"

section in Additional Information.

Simplification of EU banking rules

In December 2025 the European Central Bank published recommendations

on how to simplify the EU banking rules: 1) to reduce the numbers of

elements in the framework, 2) to introduce a simpler regime for smaller

banks, 3) to introduce a new European governance with holistic view of the

capital requirements, and 4) to finalise the saving and investment union,

including completion of the banking union. These recommendations are

not binding, but might be considered by legislators. The European

Commission is expected to publish a Report on possible simplification

measures in 2026.

Stress testing

Stress testing is an important risk management tool that provides input for

strategic decisions and capital planning. The purpose of stress testing is to

assess the impact of plausible but severe stress scenarios on ING’s capital

and liquidity position. Stress tests provide complementary and forward-

looking insights into the vulnerabilities of certain portfolios, with regards to

adverse macroeconomic circumstances, stressed financial markets, and

changes in the (geo)political climate. In addition to assessing P&L, capital

and liquidity positions of ING for a range of different scenarios,

idiosyncratic risks are also included. The outcome of these stress tests help

management get insight into the potential impact and define actions to

mitigate this potential impact.

In addition to running internal stress test scenarios to reflect the outcomes

of the annual risk assessment, ING also participates in regulatory stress

test exercises. ING participated in the 2025 EU-wide stress test. The

exercise has been coordinated by the European Banking Authority (EBA)

and carried out in cooperation with the European Central Bank (ECB), the

European Systemic Risk Board (ESRB), the European Commission (EC) and

the Competent Authorities (CAs) from all relevant national jurisdictions.

The baseline macro-financial scenario is based on the projections from the

EU national central banks, IMF and OECD. The adverse stress test scenario

was developed by the ESRB. Both the scenario covers the three years from

2025 to 2027 in line with the EBA methodology.

The 2025 EU-wide stress test exercise was carried out applying a static

balance sheet assumption as of December 2024, and therefore does not

take into account current or future business strategies and mitigating

actions. The results of the EBA stress test shows that even under the

severe but hypothetical scenario ING’s is able to withstand these

circumstances even when no mitigating actions have been taken into

account. Under the hypothetical baseline scenario and EBA’s

methodological instructions, ING Group would have a transitional common

equity Tier 1 capital ratio (CET1) of 12.90% in 2027 and a fully loaded CET1

ratio of 11.85% in 2027. Under the hypothetical adverse scenario and

EBA’s methodological instructions, ING Group would have a transitional

CET1 ratio of 10.63% in 2027 and a fully loaded CET1 ratio of 10.41% in

2027. Our commitment to maintain a robust, fully loaded Group common

equity Tier 1 (CET1) ratio in excess of prevailing requirements remains. ING

Group published an actual CET1 ratio of 13.56% per 31 December 2024

(the reference date for the stress test), and 13.08% per 31 December 2025.

The next EBA EU-wide stress test will be held in 2027.

Deposit Schemes

In the Netherlands and other jurisdictions, deposit guarantee schemes and

similar funds (‘Compensation Schemes’) have been implemented to ensure

depositor pay-out to customers if a deposit taking institution is unable, or

unlikely to pay, claims against it. These Compensation Schemes are

funded, directly or indirectly, by financial services firms operating and/or

licensed in the relevant jurisdiction.

Dutch Deposit Guarantee Scheme (‘DGS’):, ING Bank participates in the

Dutch Deposit Guarantee Scheme (DGS) which guarantees an amount of

EUR 100,000 per person per bank, regardless of the number of accounts

held. Based on the EU Directive on deposit guarantee schemes, ING pays

quarterly risk-based contributions into a DGS-fund. The Dutch DGS fund

reached its target size of 0.8% of all deposits guaranteed under the DGS in

July 2024.

In the event of a Dutch bank's failure, depositor compensation is paid from

the DGS-fund. If the available financial means of the fund are insufficient,

Dutch banks, including ING, may be required to pay extraordinary ex-post

contributions not exceeding 0.5% of their covered deposits per calendar

year. In exceptional circumstances and with the consent of the competent

authority, higher contributions may be required. However, extraordinary

ex-post contributions may be temporarily deferred if they would

jeopardise the solvency or liquidity of a bank.

Since 2015, the EU has been discussing the introduction of a pan-European

Deposit Guarantee Scheme (EDIS), but no political agreement has been

reached on its creation.

Instant Payments and the Payment Services Regulation/PSD3

In January and October 2025, key provisions of the EU instant payments

regulation entered into force. The regulation aims to ensure that instant

payments in euro are affordable, secure and without hindrance across the

European Union. Instant Payments are to be credited to the account of the

beneficiary within 10 seconds after receipt of the payment order by the

payer’s payment service provider and shall be available 24 hours a day all

year round. The regulation has introduced a service to be provided by

payment service providers to payers to verify the match between the bank

account number and the name of the beneficiary provided by the payer to

prevent mistakes or fraud.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	53

In June 2023 the European Commission launched its proposal for the

Payment Services Regulation (PSR) and Payment Services Directive 3,

which together will succeed the current directive for payment services

(PSD2). The main proposed changes relate to fraud, further development

of open banking, the granting of access to payment systems by non-bank

payment service providers, and further improving consumer rights and

obligations.

The PSR is in the final stages of negotiation among the European

Parliament and EU member states. The combat of fraud stands out and

addresses new fraud types, such as impersonation fraud. To that end

priorities emerging from PSR negotiation include: an obligation for

electronic communications services providers to contribute to the

collective fight against fraud, the IBAN/name check, a legal basis for

payment service providers to share fraud related data, and intensified

transaction monitoring. Political consensus is emerging that all actors in

the ecosystem must contribute to the combat of fraud. PSR may grant

certain refund rights to consumers that suffered damages from the failure

of the IBAN/name verification or that are a victim of specific types of fraud.

Agreement on final texts has not yet been reached.

The single currency package: the digital euro and access to cash

In October 2025 the ECB’s governing council concluded its preparation

phase for the digital euro, and announced further preparations, in

anticipation of a political agreement on the digital euro. In June 2023 the

European Commission launched its legislative proposal establishing the

legal framework for such euro. It will ensure that people and business

when paying with central bank money also have the possibility to pay

digitally, online and/or offline, in addition to coins and banknotes. The

legislative proposal on the legal tender status of euro cash safeguards the

role of cash, it shall continue to be a means of payment and should

continue to be easily accessible. If enacted, the digital euro could have an

impact on ING’s deposit funding, as a portion of our clients may transfer

part of their deposits held at ING, to digital euros. In addition, depending

on the set-up of the digital euro, which is still being negotiated by

European co-legislators, it could have an impact on the competitive

landscape between banks and non-bank financial services providers, as

well as on private sector-provided payment solutions.

Benchmarks Regulation

The EU Benchmarks Regulation (BMR), adopted in 2016 and effective since

January 2018, was amended in May 2025, effective as per 01.01.2026, to

streamline its scope and strengthen governance. Under the revised

framework, only critical and significant benchmarks, EU Climate Transition

and Paris-Aligned benchmarks, and certain commodity benchmarks

remain subject to the regulation, while non-significant benchmarks have

largely been removed, reducing compliance complexity. The ESMA

Benchmarks Register will serve as the single authoritative source for

benchmark and administrator information.

Benchmarks based on contributor input must have a code of conduct in

place to safeguard data integrity, address key areas such as conflicts of

interest management, internal controls, and benchmark methodologies.

Financial contracts and instruments referencing benchmarks are required

to include clear fallback provisions to ensure continuity in case of

benchmark cessation.

ING has established a Global Benchmarks Transition Office to oversee

benchmark transitions with global impact (e.g. WIBOR), ensuring controlled

execution of all transition elements. For qualitative and quantitative

disclosures on IBOR transition refer to “Additional information – ING Group

Risk Management – Market Risk”.

KYC Requirements

Financial institutions continue to face new and increasingly complex

regulatory requirements, contributing to increasing costs of compliance, in

the context of heightened regulatory scrutiny. Generally, we expect the

scope and extent of regulations in the jurisdictions in which we operate to

continue to increase.

The evolving regulatory landscape drives the need for continuous change

in the various processes, procedures and systems of the bank. Where the

timeline for implementation of new or revised requirements is sometimes

quite short, this presents challenges to financial institutions in general. In

addition, in some instances, the complexity of the regulatory landscape

gives rise to potential tension between applicable laws and regulations at a

local and/or global level. For example, there is the potential tension

between data privacy (GDPR) and AML/CFT and anti-corruption laws and

regulations; including the requirement to share information relating to

financial crime concerns to manage risk exposure across the group, while

complying with the legislative requirements relating to data, which can

differ significantly depending on the jurisdiction. In contrast, the European

Union’s proposed Anti-Money Laundering Regulation (AMLR) seeks to

create a harmonized framework across EU member states, enhancing

consistency in anti-money laundering and counter-terrorist financing

efforts when it is implemented in 2027.

ING is focused on continuing to embed applicable requirements in our

processes and procedures, including in our IT systems and data sources, in

a robust and sustainable way; driving a business environment which is

compliant by desire and design. The bank also executes ongoing training

and awareness to develop its people to have the right knowledge and

skills.

In addition, ING aims to continuously monitor regulatory developments, as

well as considering emerging and evolving risks. This supports assessment

of the risks that ING may be exposed to and of the associated controls and

processes ING has in place, so we can appropriately manage these risks in

accordance with our risk appetite.

AML/CTF-related developments

The Authority for Anti-Money Laundering and Countering the Financing of

Terrorism (AMLA) is the newly established EU agency tasked with

transforming AML/CFT supervision across the European Union. Following its

formal adoption in mid-2024, AMLA officially commenced operations on 1

July 2025, headquartered in Frankfurt. Its mandate includes harmonising

enforcement, coordinating national authorities, and enhancing

collaboration among financial intelligence units (FIUs).

AMLA’s 2025 Work Programme outlines its phased operational rollout, with

full supervisory powers expected by 1 January 2028. The agency will

directly supervise up to 40 high-risk financial institutions operating across

multiple EU member states, with selection criteria to be finalised by the

end of 2025. ING continues to monitor developments closely, as its cross-


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	54

border footprint and risk profile suggest a strong likelihood of being

designated for direct supervision.

Policy with respect to certain countries

As a result of frequent evaluation of all businesses from economic,

strategic and risk perspective ING continues to believe that for business

reasons doing business involving certain specified countries should be

discontinued. In that respect, ING has a policy not to enter into new

relationships with clients from these countries and processes remain in

place to discontinue existing relationships involving these countries. At

present these countries are Cuba, Iran, North Korea, Sudan and Syria, as

well as the Crimea region.

ING Group maintains a limited legacy portfolio of guarantees, accounts,

and loans that involve various entities with a connection to Iran. These

positions remain on the books but certain accounts related thereto are

‘frozen’ where prescribed by applicable laws and procedures and in all

cases subject to increased scrutiny within ING Group. ING Group may

receive loan repayments, duly authorised by the relevant competent

authorities where prescribed by applicable laws. For the calendar year

2025, ING Group had limited revenues and no net profit is made as there

were no repayments made in 2025.

Sanctions related developments

With respect to sanctions, as a result of Russia’s continued occupation of

parts of Ukraine and the associated conflict there has been a continued

focus of the EU, US, and other governments to impose additional sanctions

and combat the potential circumvention of sanctions against Russia. In

addition to several new sanctions packages there has been an increased

focus on the roles of third countries and companies in facilitating the

circumvention or undermining of such sanction’s measures.

Accordingly, as part of ING’s Know Your Customer and compliance risk

governance and procedures, ING is continuously monitoring the situation

to stay abreast on all relevant updates to implement effective and

appropriate additional control measures and to manage the increased risk

and financial impacts of these developments.

Operationally, the impact of these enhancements has resulted in the need

for additional staff members to review and apply greater scrutiny of

transactions alerted for heightened risk of non-compliance with applicable

sanctions.

For additional information regarding regulatory developments, see also

this Form 20-F 2025, under “Additional Information – ING Group Risk

Management- Compliance Risk”.

ESG Reporting Regulations

Environmental, Social and Governance (ESG) metrics and disclosures are

an increasing focus for businesses as they respond to a wave of scrutiny

from all manner of stakeholders, from investors and regulators to

employees and customers. There’s an expectation that ESG disclosures will

comply with mandatory and voluntary reporting requirements and be

reliable, verifiable and comparable to allow those stakeholders to make

decisions that matter to them.

There is currently a legislative initiative ongoing at the European

Commission level (i.e the EU Omnibus Regulation) which aims to

streamline and simplify certain sustainability regulations, such as the

CSDDD, CSRD and EU Taxonomy. The outcome of this initiative may impact

the interpretation and implementation of these regulations in the future.

Non-Financial Reporting Directive (NFRD)

Since 2018, companies like ING within the scope of the NFRD (Directive

2014/95/EU) have been required to disclose information on non-financial

matters (environmental, social and employee matters, human rights,

bribery and corruption). The objective of the NFRD is to improve the quality

and quantity of corporate non-financial information reporting.

Under the NFRD, large, listed companies, banks and insurance companies

('public interest entities') with more than 500 employees are required to

publish reports on the policies they implement in relation to social

responsibility and treatment of employees; respect for human rights; anti-

corruption and bribery; and diversity on company boards (in terms of age,

gender, educational and professional background). In particular, the NFRD

requires companies to disclose information about their business models,

policies (including implemented due diligence processes), outcomes, risks

and risk management, and Key Performance Indicators relevant to the

business.

Corporate Sustainability Reporting Directive (CSRD)

The CSRD (directive (EU) 2022/2464) was published in December 2022 in

the Official Journal of the European Union and should have been

transposed into national law by 6 July 2024. Currently several European

Union Member States, including the Netherlands, have not yet notified the

European Commission on the full transposition of the CSRD into national

law and missed the deadline of July 6, 2024. This situation creates an

ambiguity in terms of legal enforcement of the CSRD in local context(s). On

26 September, 2024, the European Commission has opened infringement

procedures for those countries by sending a letter of formal notice due to

the absence of measures taken to transpose EU directives into national

law. Legislative initiatives are currently underway in the Netherlands, as

well as in other jurisdictions that have yet to adopt the regulation;

however, the implementation timelines remain uncertain at this stage.

CSRD profoundly revises the ESG reporting requirements, and it is designed

to bring sustainability reporting on par with financial reporting over time

and monitor the progress of companies’ activities in relation to

sustainability matters. With the CSRD, the existing sustainability matters of

ESG reporting will be expanded and standardized. Its aims are to:

§harmonize and improve the quality of information published by

undertakings, particularly information on ESG (sustainability-related

information);

§provide financial undertakings, investors, relevant stakeholders and the

general public with relevant, comparable and reliable sustainability

information;

§encourage investment that supports the transition to a sustainable

economy in line with the European Green Deal.

Undertakings falling within its scope are required to report detailed

disclosure requirements that are specified under the European

Sustainability Reporting Standards (ESRS).


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CSRD introduced a phased-in approach for the application, where

undertakings that are subject to the NFRD were required to provide

sustainability related information for financial years beginning on or after

1 January 2024. These companies would be later joined by large non-listed

companies (2025), listed SMEs (2026) and certain European subsidiaries of

non-EU groups. ING Group, as well as some of its subsidiaries in scope,

have disclosed their sustainability related information in their 2024

Management Board report for the first time in 2025.

Subsequently, the European Commission introduced an Omnibus

Simplification Package which includes simplification measures on the

CSRD. The first component, known as the Stop-the-Clock Directive

(Directive (EU) 2025/794), published in the Official Journal on 16 April 2025,

postpones CSRD reporting by two years for companies scheduled to start

in 2026 and 2027. This measure prevents reporting obligations from taking

effect while simplification efforts are ongoing. The second component

introduces major amendments to CSRD which includes amongst other

narrowing the scope of undertakings required to report (incl. removing in

scope subsidiaries from reporting obligations), removing sector-specific

standards and removing the future move to reasonable assurance from

limited assurance. On 9 December 2025, a political agreement was

reached between the European Parliament and Council on the legislative

package introducing these amendments, which is currently awaiting its

publication in the Official Journal of the EU. Besides these, the Commission

has also adopted a quick-fix regulation (Delegated Regulation (EU)

2025/1416) to extend transitional provisions of specific disclosures

requirements to avoid additional burden during regulatory change. ING is

closely monitoring regulatory developments.

European Sustainability Reporting Standards (ESRS)

In July 2023, the European Commission has adopted the final delegated

act of the European Sustainability Reporting Standards (ESRS). Companies

subject to the CSRD shall report according to the ESRS, starting from 2025,

over financial year 2024, based on a phased-in approach.

The ESRS specify the sector-agnostic sustainability reporting requirements

based on the CSRD, covering the full range of sustainability matters

(Environment, Social and Governance). The overall architecture of the ESRS

is designed to ensure that sustainability information is reported in the

companies’ management report based on a double materiality

assessment (i.e. impact and financial materiality) and is based on the

following reporting structure:

1.Governance: the governance processes, controls and procedures used

to monitor and manage impacts, risks and opportunities

2.Strategy: how the undertaking’s strategy and business model(s)

interact with its material impacts, risks and opportunities, including the

strategy for addressing them

3.Impact, risk and opportunity management: the process(es) by which

impacts, risks and opportunities are identified, assessed and managed

through policies and actions

4.Metrics and targets: how the undertaking measures its performance,

including progress toward the targets it has set.

The cross-cutting standards consist of:

§ESRS 1 which prescribes the mandatory concepts and principles to be

applied when preparing sustainability statements under the CSRD.

§ESRS 2 is on general, strategy, governance, and materiality assessment

disclosure requirements.

The topical standards consist of:

§Environment topical standards (ESRS E1–E5) outline disclosure

requirements for companies to report on matters related to climate

change, pollution, water and marine resources, biodiversity and

ecosystems, and resource use and circular economy.

§Social topical standards (ESRS S1–S4) provide a framework for entities

to report on topics related to their own workforce, the workers in their

value chains, the communities impacted by their operations and the

consumers and end-users of their products or services.

§Governance topical standards (ESRS G1) set out disclosure

requirements that seek to enhance users’ understanding of a

company’s governance structure, its internal control and risk

management system, the company’s strategy and approach, and the

processes, procedures and performance in relation to their business

conduct.

As part of the Omnibus initiative, the European Commission aims to revise

the ESRS to reduce the reporting burden while maintaining consistency

with the EU sustainability objectives and ensuring interoperability with

global frameworks. The European Commission has mandated the EFRAG to

provide a technical advice on this initiative. EFRAG has consulted the public

and submitted its work to the Commission by the end of November 2025.

The key changes include the reduction of mandatory data points, removal

of majority of voluntary data points, simplification of the double

materiality assessment and enhanced alignment with the ISSB. Adoption

of the revised ESRS by the Commission is expected by the of the first half

of 2026 with mandatory application for the reporting year 2027.

EU Taxonomy

The EU Taxonomy Regulation (EU Taxonomy), published in the Official

Journal of the EU in 2020, is a classification system, establishing a list of

‘environmentally sustainable’ economic activities and introducing

reporting requirements. The EU Taxonomy provides companies, investors

and policymakers with appropriate definitions for which economic

activities can be considered ‘environmentally sustainable’ and can be

reported accordingly. In this way, it creates security for investors and

protects private investors from greenwashing. For economic activities to be

recognized as ‘environmentally sustainable”, they should meet the

following criteria:

§Substantially contributing to one of the six EU environmental

objectives:

–Climate change mitigation

–Climate change adaptation

–Sustainable use and protection of water and marine resources

–Transition to a circular economy

–Pollution prevention and control

–Protection and restoration of biodiversity and ecosystems

§Do not significantly harm to any of the other 5 objectives

§Meeting minimum safeguards, including OECD Guidelines for

Multinational Enterprises and the UN Guiding Principles on Business, ILO

standards and Human Rights.

For disclosure requirements under the EU Taxonomy, a delegated act

supplementing Article 8 of the Taxonomy is applicable since January 2022.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	56

Article 8 of the EU Taxonomy aims to increase transparency in the market

and help prevent greenwashing by providing information to investors

about the environmental performance of assets and economic activities of

financial and non-financial undertakings in scope. This delegated act

specifies the content, methodology and presentation of information to be

disclosed concerning the proportion of environmentally sustainable

economic activities in their businesses, depending on the type of the

company (i.e. non-financial/financial). Within the scope of Article 8

delegated act, in-scope credit institutions are required disclose the Green

Asset Ratio (GAR) which measures the share of a credit institution's

taxonomy-aligned exposure against total covered assets, amongst other

detailed disclosures.

As part of the Omnibus Simplification Package, the European Commission

has adopted a delegated act introducing amendments to improve the

effectiveness of EU Taxonomy disclosures by reducing complexity and

burden. The amendment introduces key changes such as recalibrating the

GAR to ensure symmetry within the numerator and denominator,

introducing materiality thresholds and removing or simplifying certain

templates to ease administrative burden. Revised rules have entered into

force and can already be applied from 1 January 2026 per the delegated

act.

Pillar 3 ESG Disclosures

Article 449a of Regulation (EU) No 575/2013 (CRR) requires institutions to

disclose prudential information on environmental, social and governance

risks, including physical risks and transition risks, as defined in Article 4 of

the same regulation. Under CRR III, the scope of application has been

extended beyond large and listed institutions to cover all institutions,

including large subsidiaries of parent institutions. Article 434a CRR

mandates the EBA to develop draft implementing technical standards (ITS)

specifying uniform formats and associated instructions for these

disclosures.

The current ITS on Pillar III disclosures on Environmental, Social and

Governance (ESG) risks, which is applicable to large and listed institutions,

was adopted by the European Commission in November 2022, published in

the Official Journal of the EU in December 2022 with a first reporting date

in 2023 (reference date: 31 December 2022). The ESG Pillar 3 requires

credit institutions such as ING to disclose the following information:

§Climate risks: how climate change may exacerbate other risks within

banks' balance sheets.

§Mitigating actions: what mitigating actions banks have in place to

address those risks, including financing activities that reduce carbon

emissions.

§Green Asset ratio and Banking Book Taxonomy Alignment ratio: to

understand how banks are financing activities that will meet the

publicly agreed Paris agreement objectives of climate change

mitigation and adaptation based on the EU taxonomy of green

activities.

The EBA ESG Pillar 3 requirements features (i) a set of 10 quantitative

templates that request banks to disclose climate-related risks and actions

to mitigate them, together with exposure to assets that support the

climate change mitigation and adaptation and (ii) qualitative information

on their ESG strategies, governance and risk management arrangements

with regard to ESG risk.

As the CRR III extends the scope of application to all institutions, including

large subsidiaries on an individual, or where applicable on a sub-

consolidated basis, the EBA launched a consultation on 22 May 2025

proposing amendments to the current ITS as mandated by the CRR III in

order to lay down proportionate requirements for new in-scope entities, as

well as modifying certain requirements for already in-scope entities.

Proposed amendments include, amongst others, reduced templates and

frequency for newly in-scope entities, certain modifications and

simplifications on current templates, allowing annual reporting for certain

templates subject to materiality assessment and the full alignment with

the EU Taxonomy Regulation. In addition, amendments include

transitional provisions that suspend disclosures of certain templates until

31 December 2026 and defer disclosures by newly in-scope entities to the

same date. EBA has published a no-action letter advising supervisors not

to enforce these suspended requirements to provide regulatory certainty

during the transition.

Sustainable Finance Disclosure Regulation

The Sustainable Finance Disclosure Regulation (SFDR) is a European

regulation intended to improve financial sector transparency for certain

sustainable investment products, via website and pre-contractual

disclosures. It also aims to prevent greenwashing and to increase

transparency around sustainability claims made by financial sector

participants. The SFDR imposes sustainability disclosure requirements on

certain financial actors who are offering certain type of financial products

or investment advice in the EU covering a broad range of environmental,

social and governance (ESG) metrics at both entity- and product-level.

Subsidiaries of ING Groep N.V. in the European Union are, or may be,

subject to the SFDR through certain products or services they provide. The

SFDR came into effect on 10 March 2021, with certain disclosure

requirements being in effect at a later stage.

In 2025, the European Commission launched a review of the SFDR aimed at

simplifying the framework and improving legal clarity. The initiative seeks

to reduce complexity, address overlaps with other EU sustainable finance

regulations, and introduce clearer product categories to enhance

comparability and mitigate greenwashing risks. A legislative proposal for

these revisions is published in November 2025, which will be followed by

the standard EU legislative process.

California Climate Disclosure Bills

California has enacted climate disclosure laws (SB 253 & SB 261) which

require companies that has business activities in California and meet

certain revenue thresholds to provide; (1) annual greenhouse gas (GHG)

emissions reporting in accordance with the GHG Protocol in 2026 for fiscal

year 2025; and (2) biennial climate-related financial risk reporting in line

with the recommendations of the Task Force on Climate-Related

Disclosures (TCFD) or with another framework that is consistent with the

recommendations by the beginning of 2026. There are phased in

requirements in relation to GHG emissions reporting where scope 3

emissions are only to be disclosed in 2027. In addition, scope 1 and scope

2 emissions are subject to limited assurance in 2026 and to reasonable

assurance in 2030; whereas scope 3 emissions are subject to limited

assurance only in 2030. Authorities issued further guidance in relation to

implementation of disclosure laws during the second half of 2025.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	57

Subsequently, on 18 November 2025, the U.S. Court of Appeals for the

Ninth Circuit temporarily suspended enforcement of SB 261 pending

appeal, while SB 253 remains in effect for the time being. This suspension

introduces a degree of regulatory uncertainty and ING will continue to

monitor legal developments closely.

Additional information regarding regulatory developments

For additional information regarding regulatory developments, see also

this Form 20-F 2025, under “Additional Information – ING Group Risk

Management - Environmental, social and governance Risk”.

For a description of our segments including a breakdown of total revenues

by category for the last three financial years, refer to "Item 5. Operating

and financial review and prospects - Segment reporting”.

C. Organisational structure

ING Groep N.V., a publicly listed company, is the parent of one main legal

entity: ING Bank N.V. (ING Bank). ING Bank is the parent company of

various Dutch and foreign banking and other subsidiaries.

Reference is made to Exhibit 8 “List of subsidiaries of ING Groep N.V.” for a

list of principal subsidiaries of ING Groep. N.V. For the majority of ING’s

principal subsidiaries, ING Groep N.V. has control because it either directly

or indirectly owns more than half of the voting power. For subsidiaries in

which the interest held is below 50%, control exists based on the

combination of ING’s financial interest and its rights from other contractual

arrangements which result in control over the operating and financial

policies of the entity.

D.Property, plants and equipment

ING predominantly leases the land and buildings used in the normal

course of its business. In addition, ING has invested in land and buildings.

Management believes that ING’s facilities are adequate for its present

needs in all material respects.

For information on property, plants and equipment, reference is made to

Note 9 'Property and equipment', for information on lease liabilities

reference is made to Note 16 'Other liabilities' and for information on

investment properties reference is made to Note 11 'Other assets' in the

consolidated financial statements.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	59

Item 5. Operating and Financial Review and Prospects

The following operating and financial review and

prospects should be read in conjunction with the

consolidated financial statements and the related

Notes thereto included elsewhere herein. The

consolidated financial statements have been

prepared in accordance with IFRS-IASB. Unless

otherwise indicated, financial information for ING

Group included herein is presented on a

consolidated basis under IFRS-IASB.

A.Operating results

In a fast-changing world, it is essential for our business to adapt, evolve

and remain resilient. We need to stay ahead of changing consumer

preferences, technological advances, shifts in the banking sector, evolving

views on sustainability, talent shortages, and economic and geopolitical

uncertainty. Change is constant, so we stay agile and ready for what’s

next.

As a global bank, we constantly anticipate and adapt to change so we can

continue to grow our scale, impact and relevance across the markets and

segments we serve. By responding proactively to shifts around us, we not

only manage risks more effectively but also turn challenges into

opportunities, with the aim of delivering superior value for our customers.

Technological change reshapes consumer experience

In recent years, rapid advances in generative AI have transformed how

people use technology in their daily lives – from searching for information

to receiving personalised products, services, and experiences in real time.

The impact on banking is profound, as AI and scalable technology

platforms redefine consumer expectations for speed, personalisation, and

reliability.

Among other applications, AI tools enable faster customer support,

improve customer protection and compliance, and help assess and

process mortgage applications. Our digital-first approach positions us

strongly to adapt to this landscape. We continue to invest in AI and digital

infrastructure to ensure we can scale our technology to reach the market

faster, enhance productivity, and keep our customers safe. As AI moves

from the pilot stage to large-scale deployment, its dependability and

reliability faces real-world testing. Only AI tools that solve specific business

challenges and clear consumer needs will prove their value at scale.

Banking landscape is fragmenting, competition intensifying

The banking world is changing fast. Traditional banks are no longer the

sole providers of financial services. Digital innovation and AI-driven low-

cost models are driving competition from fintechs, non-bank lenders, and

technology companies. Digital banks are competing for retail customers

with user-friendly platforms and low fees, while private lenders – including

big tech companies – are taking a growing share of business lending. At

the same time, innovations such as digital tokens and stablecoins are

reshaping payment systems, moving them beyond traditional banking

channels. In this transformed competitive environment, we strive to make

banking easier and seamless. Continuous innovation and adaptation help

us broaden our services, increase our relevance, and deepen our customer

relationships.

Keeping course in a shifting sustainability landscape

We see shifts in the global sustainability agenda, with economic pressure,

geopolitical uncertainty and energy security concerns changing some

areas of sustainability regulation. National policies and attitudes to

sustainability priorities are increasingly dispersed. We continue to monitor

these developments as part of our strategic and risk management

processes.

Complex and changing regulatory environment

The regulatory landscape we operate in is becoming increasingly complex,

driven by inconsistent rules, rapid technological change, and rising

expectations in data privacy, cybersecurity and ESG. In particular, the

banking and financial landscape in Europe is marked by a fragmented

regulatory landscape. Diverging global and European standards require

stronger controls, clearer disclosures, and significant investment in

compliance. Fintech innovation and geopolitical volatility further

accelerate regulatory shifts, while the complexity of navigating both EU-

level and individual country requirements places additional demands on

governance and risk management. To stay resilient, we adapt quickly to

evolving requirements, strengthening our governance and risk

management capabilities to remain competitive and compliant.

Battle for talent in specialist roles

International companies face an intensifying global battle for talent,

particularly in technology and AI. To attract, develop and retain the talent

we need, we invest in skills development, flexible work models, and

continuous learning.

Dynamic geopolitical environment

In 2025 the international business climate was marked by rising

geopolitical tensions and economic uncertainty. Political changes,

unpredictable policy shifts, tariffs, trade disputes, changing international

alliances and supply-chain restrictions all combined disrupt global business

and trade. This heightened uncertainty contributed to increased volatility


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	60

in the financial markets. Global conflicts continue to shape the geopolitical

landscape, with the war in Ukraine ongoing, persistent tensions in the

Middle East, and new areas of instability emerging in other regions. These

developments contribute to an environment of heightened uncertainty

and potential risk for international businesses.

For further information on other factors that can impact ING Group’s

results of operations, reference is made to “Item 3. Key information - Risk

Factors”.

For further information on regulatory changes reference is made to “Item

4. Information on the Company – Regulation and Supervision”.

Fluctuations in markets

Fluctuations in equity markets

Our banking operations are exposed to fluctuations in equity markets. ING

maintains an internationally diversified and mainly client-related trading

portfolio. Accordingly, market downturns are likely to lead to declines in

securities trading and brokerage activities which we execute for customers

and therefore to a decline in related commissions and trading results. In

addition to this, ING also maintains equity investments in its own non-

trading books. Fluctuations in equity markets may affect the value of

these investments.

Fluctuations in interest rates

Our banking operations are exposed to fluctuations in interest rates.

Mismatches in the interest re-pricing and maturity profile of assets and

liabilities in our balance sheet can affect the future interest earnings and

economic value of the bank's underlying banking operations. In addition,

changing interest rates may impact the (assumed) behavior of our

customers, impacting the interest rate exposure, interest hedge positions

and future interest earnings, solvency and economic value of the bank’s

underlying banking operations. The stability of future interest earnings and

margin also depends on the ability to actively manage pricing of customer

assets and liabilities. Especially, the pricing of customer savings portfolios

in relation to re-pricing customer assets and other investments in our

balance sheet is a key factor in the management of the bank’s interest

earnings.

Fluctuations in exchange rates

ING Group is exposed to fluctuations in exchange rates. Our management

of exchange rate sensitivity affects the results of our operations through

the trading activities (which includes local country versus international

transactions) and because we prepare and publish our consolidated

financial statements in Euros. Because a substantial portion of our income,

expenses and foreign investments is denominated in currencies other than

Euros, fluctuations in the exchange rates can impact our reported results

of operations, cash flows and reserves from year to year. Fluctuations in

exchange rates will also impact the value (denominated in Euro) of our

investments in our non-Euro reporting subsidiaries. The impact of these

fluctuations in exchange rates is mitigated to some extent by the fact that

income and related expenses, as well as assets and liabilities, of each of

our non-Euro reporting subsidiaries are generally denominated in the

same currencies. FX translation risk is managed by taking into account the

effect of translation results on the Common Equity Tier 1 ratio (CET1).

Consolidated result of operations

ING Group monitors and evaluates the performance of ING Group at a

consolidated level and by segment using results based on figures

according to IFRS as adopted by the European Union (IFRS-EU). The

Executive Board and the Management Board Banking consider this

measure to be relevant to an understanding of the Group’s financial

performance, because it allows investors to understand the primary

method used by management to evaluate the Group’s operating

performance and make decisions about allocating resources. In addition,

ING Group believes that the presentation of results in accordance with

IFRS-EU helps investors compare its segment performance on a

meaningful basis by highlighting result before tax attributable to ongoing

operations and the profitability of the segment businesses. IFRS-EU result

is derived by including the impact of the IFRS-EU ‘IAS 39 carve out’

adjustment compared to IFRS-IASB.

The IFRS-EU ‘IAS 39 carve-out’ adjustment relates to fair value portfolio

hedge accounting strategies for the mortgage and savings portfolios in the

Benelux, Germany and Other Challengers that are not eligible under IFRS-

IASB. As no hedge accounting is applied to these mortgage and savings

portfolios under IFRS-IASB, the fair value changes of the derivatives are not

offset by fair value changes of the hedge items (mortgages and savings).

For a reconciliation to IFRS-IASB of non-GAAP measures 'Net core lending

growth', 'Net core deposits growth' and 'Commercial net interest income',

please refer to Alternative performance measures at the end of this

section.

Our financial performance

The published 2025 financial statements of ING Group includes financial

information in accordance with International Financial Reporting

Standards as adopted by the European Union (IFRS-EU). The segment

reporting in the annual report on Form 20-F has been reconciled with

International Financial Reporting Standards as issued by the International

Accounting Standards Board (IFRS-IASB) for consistency with the other

financial information contained in this report. The difference between the

accounting standards is reflected in the Wholesale Banking segment, and

in the geographical split of the segments in the Netherlands, Belgium,

Germany, Other Challengers, Growth Markets and Wholesale Banking Rest

of World. Reference is made to Note 1 ‘Basis of preparation and material

accounting policy information’ for a reconciliation between IFRS-EU and

IFRS-IASB.

For further information on the segments by line of business and the main

sources of income of each of the segments, reference is made to Note 30

‘Segments’.

Total Operations

The following table sets forth the contribution of ING’s business lines and

the corporate line to the net result for each of the years 2025, 2024 and

2023.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	61


Total operations
1 January to 31 December 2025 in EUR million	Retail Banking Netherlands	Retail Banking Belgium	Retail Banking Germany	Retail Other	Wholesale Banking	Corporate Line	Total
Income:
Net interest income	3,115	1,786	2,457	3,892	2,997	434	14,681
Net fee and commission income	1,128	692	632	717	1,433	1	4,602
Total investment and other income	726	197	-98	299	2,579	49	3,752
Total income	4,968	2,674	2,991	4,908	7,009	484	23,035

Expenditure:
Operating expenses	2,089	1,878	1,362	2,905	3,837	512	12,583
Additions to loan loss provision	107	153	171	323	549	1	1,304
Total expenditure	2,196	2,031	1,533	3,228	4,386	513	13,887

Result before taxation	2,773	644	1,457	1,680	2,624	-30	9,148
Taxation	733	178	472	398	673	92	2,545
Non-controlling interests			2	225	48		275
Net result IFRS-EU	2,040	466	983	1,058	1,902	-121	6,327
Adjustment of the EU 'IAS 39 carve- out'					1,996		1,996
Net result IFRS-IASB	2,040	466	983	1,058	3,899	-121	8,324


Total operations
1 January to 31 December 2024 in EUR million	Retail Banking Netherlands	Retail Banking Belgium	Retail Banking Germany	Retail Other	Wholesale Banking	Corporate Line	Total
Income:
Net interest income	3,027	1,959	2,647	3,817	3,259	315	15,023
Net fee and commission income	1,049	603	433	609	1,317	-3	4,008
Total investment and other income	835	189	-173	263	2,405	66	3,584
Total income	4,910	2,751	2,906	4,688	6,981	378	22,615

Expenditure:
Operating expenses	2,124	1,811	1,303	2,792	3,558	533	12,121
Additions to loan loss provision	-8	134	149	291	627	1	1,194
Total expenditure	2,117	1,944	1,452	3,083	4,185	534	13,315

Result before taxation	2,793	807	1,455	1,605	2,796	-156	9,300
Taxation	723	210	505	381	693	138	2,650
Non-controlling interests			1	221	35		258
Net result IFRS-EU	2,070	597	949	1,002	2,068	-294	6,392
Adjustment of the EU 'IAS 39 carve- out'					-1,058		-1,058
Net result IFRS-IASB	2,070	597	949	1,002	1,010	-294	5,334


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	62


Total operations
1 January to 31 December 2023 in EUR million	Retail Banking Netherlands	Retail Banking Belgium	Retail Banking Germany	Retail Other	Wholesale Banking	Corporate Line	Total
Income:
Net interest income	3,096	2,063	2,862	3,437	4,028	489	15,976
Net fee and commission income	959	502	357	519	1,259	-1	3,595
Total investment and other income	945	117	-67	277	1,771	-38	3,005
Total income	5,001	2,683	3,152	4,233	7,057	450	22,575

Expenditure:
Operating expenses	2,135	1,852	1,243	2,479	3,313	542	11,564
Additions to loan loss provision	5	169	119	313	-92	5	520
Total expenditure	2,140	2,022	1,362	2,792	3,222	547	12,084

Result before taxation	2,861	661	1,790	1,441	3,836	-97	10,492
Taxation	740	182	631	359	900	158	2,970
Non-controlling interests				174	61		235
Net result IFRS-EU	2,121	479	1,159	908	2,875	-255	7,287
Adjustment of the EU 'IAS 39 carve- out'					-3,147		-3,147
Net result IFRS-IASB	2,121	479	1,159	908	-272	-255	4,140

Year ended 31 December 2025 compared to year ended 31 December

2024

Without application of the EU ‘IAS 39 carve-out’, ING’s net result rose by

EUR 2,990 million, or 56%, to EUR 8,324 million compared with EUR 5,334

million in 2024. The net result was affected by a EUR 1,996 million positive

contribution of fair value changes on derivatives related to asset-liability-

management activities for the mortgage and savings portfolios in the

Benelux, Germany, France, Spain, Italy and Romania, versus a EUR 1,058

million negative contribution in 2024. These fair value changes were

mainly caused by changes in market interest rates. No hedge accounting

is applied to these derivatives under IFRS-IASB.

ING’s IFRS-EU net result (when applying the EU ‘IAS 39 carve-out’) declined

to EUR 6,327 million from EUR 6,392 million in 2024.

In 2025, we again achieved higher revenues. Total income rose 1.9% to

EUR 23,035 million, supported by growth in our customer base and a 15%

increase in fee income. Customer lending increased by EUR 41.5 billion.

Adjusted for currency impacts and excluding Treasury and run-off

portfolios, the net core lending growth was EUR 56.9 billion (more than

double the amount recorded in the previous year).

Total net interest income decreased 2.3% to EUR 14,681 million.

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

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

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

decline was partly attributable to the ongoing expansion of our residential

mortgage portfolio, which delivers higher returns on equity but carries

lower average margins than other lending products. Liability net interest

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

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

Payments & Cash Management in Wholesale Banking. Other net interest

income primarily comprises interest income from Financial Markets and

Treasury.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	63

Net fee and commission income totalled EUR 4,602 million, an increase of

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

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

growth in the number of investment accounts and higher customer

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

growth in primary customers and updated pricing for payment packages,

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

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

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

banking fees.

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

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

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

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

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

Corporate Investments. The previous year had included EUR 77 million as

our share in the one-off profit of an associate in Belgium and a EUR 53

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

the Netherlands.

Operating expenses increased 3.8% to EUR 12,583 million, including EUR

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

previous year. Expenses in 2025 also included EUR 297 million of incidental

items, primarily related to restructuring, versus EUR 178 million of

incidental items in 2024.

Expenses excluding regulatory costs and incidental items rose 3.2%,

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

continued investments to support business growth. These impacts were

partially mitigated by further increasing scalability and efficiency in our

operations, including enhanced client interactions in our contact centres,

and ongoing optimisation of our footprint across several retail countries.

Net additions to loan loss provisions amounted to EUR 1,304 million

compared with EUR 1,194 million in 2024. Risk costs for 2025 were

equivalent to 19 basis points of average customer lending, remaining

below our through-the-cycle average of 20 basis points.

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

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

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

during 2025.

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

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

primarily due to a partial release of management overlays.

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

amounted to EUR 6,327 million, slightly below the net profit of EUR 6,392

million achieved in 2024. The effective tax rate for 2025 was 27.8%

compared with 28.5% in the previous year.

Year ended 31 December 2024 compared to year ended 31 December

2023

Without application of the EU ‘IAS 39 carve-out’, ING’s net result rose by

EUR 1,195 million, or 29%, to EUR 5,334 million compared with EUR 4,140

million in 2023. The net result was affected by a EUR 1,058 million negative

contribution of fair value changes on derivatives related to asset-liability-

management activities for the mortgage and savings portfolios in the

Benelux, Germany, France, Spain, and Italy, versus a EUR 3,147 million

negative contribution in 2023. These fair value changes were mainly

caused by changes in market interest rates. No hedge accounting is

applied to these derivatives under IFRS-IASB.

ING’s IFRS-EU net result (when applying the EU ‘IAS 39 carve-out’) declined

to EUR 6,392 million from EUR 7,287 million in 2023. The total income in

2024 was supported by double-digit growth in fee income and strongly

increased customer lending and customer deposit volumes. Higher

expenses show the continued investments in the growth of our business,

as well as inflationary effects on staff expenses. Risk costs remained below

our through-the-cycle average.

Total income rose to EUR 22,615 million. This was supported by continued

growth of our customer base, double-digit growth in fee income and

sharply increased lending and deposit volumes.

We recorded outstanding commercial growth in 2024. Customer lending

rose by EUR 38.0 billion. The net core lending growth - which is the

increase in customer lending adjusted for currency impacts and excluding

Treasury and the run-off portfolios - was EUR 27.7 billion. We were

particularly successful in increasing our residential mortgages portfolio, by

EUR 18.9 billion, spread across all our retail countries. In addition, we also

grew our consumer lending and business lending books (by EUR 6.9 billion

in total). And we recorded a net growth in Wholesale Banking of EUR 1.8

billion, while we continued to optimise our capital usage.

Customer deposits increased by EUR 41.4 billion in 2024. Net core deposits

growth (which excludes FX impacts and movements in Treasury deposits)

was EUR 47.4 billion in 2024, with strong contributions from both Retail

Banking and Wholesale Banking. At the end of 2024, 68% of our balance

sheet was funded by customer deposits.

Net interest income (NII) from lending and liabilities held up well; however,

total NII declined 6.0% to EUR 15,023 million due to lower NII in Financial

Markets and Treasury. Lending NII rose by EUR 139 million, reflecting

volume growth at a stabilising margin. Liability NII declined by EUR 318

million as deposit growth could not entirely offset the impact of

normalising margins. Financial Markets NII was EUR 494 million more

negative than in 2023 as higher interest rates led to an increase in funding

costs. This impacted NII while the income from related positions is

reflected in other income due to accounting asymmetry. NII in Treasury

dropped by EUR 335 million, primarily impacted by the ECB’s adjustment in

September 2023 of the remuneration on the minimum reserve

requirements to zero basis points as well as by less favourable conditions

in the money markets. Other NII included a one-off income of EUR 70

million in Wholesale Banking and a EUR -39 million impact from the Polish

mortgage moratorium. The net interest margin was 1.45% in 2024, which

is 11 basis points lower than in 2023, mainly due to a lower NII in Financial

Markets and Treasury.

Net fee and commission income strongly increased in line with our

ambition to diversify our income and was up 11% to over EUR 4 billion. Fee

income from retail investment products was significantly up, reflecting an

increase in accounts, in assets under management and customer trading


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	64

activity. Daily banking fees rose on the back of strong growth in the

number of customers and an updated pricing for payment packages. The

increase in fee income for Wholesale Banking was mainly attributable to a

higher income from Capital Markets issuance.

Total investment and other income increased 19% to EUR 3,584 million.

This was mainly due to the positive effect of accounting asymmetry in

Financial Markets, as well as to a smaller IAS 29 impact (reflecting lower

inflation in Türkiye). Furthermore, in 2024 we recorded EUR 77 million as

our share in the one-off profit of an associate in Belgium and a EUR 53

million receivable (recorded in the Corporate Line) related to a prior

insolvency of a financial institution in the Netherlands.

Operating expenses increased 4.8% to EUR 12,121 million. Expenses in

2024 included EUR 882 million of regulatory costs, a decline of EUR 160

million year-on-year, mainly because no contribution to the eurozone’s

Single Resolution Fund was required in 2024 and because the Dutch

deposit guarantee fund reached its target level in 2024. Furthermore,

expenses in 2024 included EUR 178 million of incidental items (largely

related to restructuring provisions) compared with EUR 247 million of

incidental items in 2023.

Expenses excluding regulatory costs and incidental items rose 7.6%,

mainly attributable to the impact of inflation on staff expenses and the

implementation of the ‘Danske Bank’ ruling on VAT in the Netherlands. In

Retail Banking, this was coupled with investments in digitalisation and in

client acquisition to support growth. Wholesale Banking expenses also

reflect front office growth in Capital Markets & Advisory and Transaction

Services, as well as investments to enhance the digital experience and the

scalability of our systems. The cost/income ratio came out at 53.6% in

2024 compared with 51.2% a year earlier.

Net additions to loan loss provisions increased to EUR 1,194 million

compared with EUR 520 million in 2023. This is equivalent to 18 basis

points of average customer lending, and below our through-the-cycle

average of 20 basis points.

The increase year-on-year was largely due to additions for a number of

Stage 3 files in Wholesale Banking. This was partly compensated by a net

release from loan loss provisions in Stage 1 and 2, mainly reflecting a

partial release of management overlays.

The net result (attributable to shareholders of the parent) in 2024 was EUR

6,392 million compared with EUR 7,287 million in 2023. The effective tax

rate in 2024 was 28.5% compared with 28.3% in 2023.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	65

Retail Netherlands


Retail Netherlands
in EUR million	2025	2024	2023
Income:
Net interest income	3,115	3,027	3,096
Net fee and commission income	1,128	1,049	959
Investment income and other income	726	835	945
Total income	4,968	4,910	5,001

Expenditure:
Operating expenses	2,089	2,124	2,135
Additions to the provision for loan losses	107	-8	5
Total expenditure	2,196	2,117	2,140

Result before tax	2,773	2,793	2,861
Taxation	733	723	740
Non-controlling interests	0	0	0
Net result IFRS-IASB	2,040	2,070	2,121

Year ended 31 December 2025 compared to year ended 31 December

2024

The net result of Retail Netherlands decreased by EUR 30 million, or 1.4%,

to EUR 2,040 million in 2025 from EUR 2,070 million in 2024. Retail

Netherlands posted a result before tax of EUR 2,773 million compared with

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

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

operating expenses showed a small decline.

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

base and customer balances. Customer lending rose by EUR 14.9 billion in

2025. Net core lending growth (which is the increase in customer lending,

excluding movements in Treasury and in the WestlandUtrecht Bank run-

off portfolio) was EUR 16.2 billion. This was fuelled by sustained strong

mortgage production (EUR 11.1 billion) and further expansion across both

business and consumer lending portfolios. Customer deposits increased by

EUR 8.5 billion. Excluding Treasury, customer deposits grew by EUR 11.5

billion, primarily driven by a solid net inflow from private individuals.

Net interest income rose 2.9% to EUR 3,115 million. This mainly reflected

higher Treasury-related interest income, which was partly offset within

‘total investment and other income’. Interest income from lending

products also increased, with the expansion of the lending portfolio more

than offsetting margin compression. Net fee and commission income rose

7.5%, with growth across all product categories — most notably in

investment products, supported by an increase in assets under

management. Investment and other income totalled EUR 726 million

(compared with EUR 835 million in 2024) and included lower Treasury-

related income.

Operating expenses decreased slightly to EUR 2,089 million. Regulatory

costs declined by EUR 47 million, as no contribution to the Dutch deposit

guarantee fund was required in 2025, and we benefited from an

adjustment to our DGS contribution related to previous years. Expenses

excluding regulatory costs remained broadly stable year-on-year, as

salary increases under the collective labour agreement and higher

restructuring costs were almost fully offset by operational efficiencies and

savings on external staffing.

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

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

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

mortgages.

Year ended 31 December 2024 compared to year ended 31 December

2023

The net result of Retail Netherlands decreased by EUR 51 million, or 2.4%,

to EUR 2,070 million in 2024 from EUR 2,121 million in 2023. Retail

Netherlands posted a result before tax of EUR 2,793 million compared with

EUR 2,861 million in 2023. The 2.4% decline was due to lower Treasury-

related income, while expenses were broadly flat and risk costs showed a

small net release.

Net interest income was EUR 3,027 million, or 2.2% lower than a year

earlier. The decline was attributable to lower Treasury-related interest

income, reflecting the impact of the ECB’s adjustment of the remuneration

on the minimum reserve requirement to zero basis points in September

2023 as well as less favourable money market conditions. Net interest

income from lending increased, supported by significant growth in the

mortgage portfolio. Net fee and commission income was strong and rose

9.4% to EUR 1,049 million. This was driven by growth in the number of

customers, higher fees for payment packages and a double-digit increase

in assets under management. Other income decreased due to lower other

income from specific money market and FX transactions in Treasury.

Customer lending rose by EUR 11.4 billion. The net core lending growth

(which excludes movements in Treasury and in the WestlandUtrecht Bank

run-off portfolio) was EUR 9.6 billion, driven by strong growth of the

mortgage portfolio. Customer deposits were EUR 1.0 billion higher but

excluding Treasury grew by EUR 5.0 billion.

Operating expenses slightly decreased to EUR 2,124 million. Regulatory

costs declined by EUR 98 million because no contribution to the Single

Resolution Fund was required in 2024 and because the Dutch deposit

guarantee fund in the Netherlands reached its target level in 2024. This

more than compensated for a higher bank tax in the Netherlands.

Expenses excluding regulatory costs rose 4.6% to EUR 2,011 million. This

included higher internal staff expenses due to collective labour agreement

(CLA) increases, partly offset by savings on external staff.

In 2024, a net release from loan loss provisions was recorded of EUR -8

million. This was attributable to a net release for mortgages, driven by a

strong improvement in the housing market and a partial release of

management overlays.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	66

Retail Belgium


Retail Belgium
in EUR million	2025	2024	2023
Income:
Net interest income	1,786	1,959	2,063
Net fee and commission income	692	603	502
Investment income and other income	197	189	117
Total income	2,674	2,751	2,683

Expenditure:
Operating expenses	1,878	1,811	1,852
Additions to the provision for loan losses	153	134	169
Total expenditure	2,031	1,944	2,022

Result before tax	644	807	661
Taxation	178	210	182
Net result IFRS-IASB	466	597	479

Year ended 31 December 2025 compared to year ended 31 December

2024

The net result of Retail Belgium (including ING in Luxembourg) decreased

by EUR 131 million, or 22%, to EUR 466 million in 2025 from EUR 597

million in 2024. The result before tax for Retail Belgium (which includes our

retail activities in Luxembourg) declined to EUR 644 million (from EUR 807

million in the prior year), mainly due to a lower margin on liabilities and

higher regulatory costs. However, fee income increased significantly, and

expenses excluding regulatory costs remained well-contained.

Customer lending rose by EUR 1.8 billion year-on-year. Net core lending

growth (which is the increase in customer lending excluding Treasury) was

EUR 2.0 billion, with growth in both mortgages and other lending.

Customer deposits declined by EUR 0.6 billion, following the conclusion of a

successful promotional campaign originated in the third quarter of 2024.

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

majority of term deposits and facilitating their conversion into investment

products, thereby enhancing long-term customer value.

Net interest income declined 8.8% to EUR 1,786 million, primarily due to

reduced liability margins. Treasury-related net interest income also

decreased year-on-year, although this was fully offset by higher

investment and other income within Treasury. Investment and other

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

2025, while 2024 had included EUR 77 million relating to our share in the

one-off profit of another associate. Net fee and commission income was

strong, rising 15% to EUR 692 million. This growth was primarily driven by

higher fees from investment products, reflecting the success of campaigns

to attract new customers for investment solutions, as well as from daily

banking services.

Operating expenses amounted to EUR 1,878 million, including EUR 261

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

DGS contribution) and EUR 79 million in incidental restructuring costs

(compared with EUR 59 million for this in 2024). These restructuring costs

are part of broader multi-year transformation programmes across

Belgium and Luxembourg, aimed at simplifying operations, increasing

commercial focus and improving long-term profitability, though they

temporarily impact reported returns. Expenses excluding regulatory costs

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

indexation was offset by lower accommodation and IT expenses.

The net addition to the provision for loan losses amounted to EUR 153

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

million in 2024. Risk costs were mainly related to business lending.

Year ended 31 December 2024 compared to year ended 31 December

2023

The net result of Retail Belgium (including ING in Luxembourg) increased

by EUR 118 million, or 25%, to EUR 597 million in 2024 from EUR 479

million in 2023. The result before tax for Retail Belgium rose 22% to EUR

807 million. The increase was attributable to higher income, coupled with

lower operating expenses and a decline in risk costs.

Net interest income decreased by EUR 104 million or 5.0%, mainly due to

lower Treasury-related interest income. In addition, net interest income

was impacted by higher funding costs for mortgages. Net fee and

commission income rose by EUR 101 million or 20%, supported by an

increase in assets under management and lower commissions paid.

Investment and other income was strongly up because 2024 included EUR

77 million for our share in the one-off profit of an associate.

Customer lending was up by EUR 4.0 billion. Net core lending (which

excludes Treasury) rose by EUR 3.7 billion, reflecting a EUR 2.7 billion

increase in business lending and EUR 1.0 billion of growth in the mortgage

portfolio. Customer deposits grew by EUR 5.9 billion. Net core deposits

(which excludes Treasury) increased by EUR 6.4 billion, driven by a EUR 5.5

billion inflow from our successful term deposit campaigns (exceeding the

EUR 2.6 billion outflow we saw in 2023 when customers bought bonds

issued by the Belgian government).

Operating expenses amounted to EUR 1,811 million, including EUR 206

million of regulatory costs (versus EUR 211 million in 2023) and EUR 59

million of incidental item costs related to restructuring and a further

optimisation of the branch network (compared with EUR 76 million for this

in 2023). Expenses excluding regulatory costs and incidental items

declined 1.3%, as the impact of automatic salary indexation was offset by

FTE reductions.

The net addition to the provision for loan losses amounted to EUR 134

million, or 14 basis points of average customer lending, down from EUR

169 million in 2023. Risk costs for mortgages and consumer lending

declined while risk costs for business lending were stable.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	67

Retail Germany


Retail Germany
in EUR million	2025	2024	2023
Income:
Net interest income	2,457	2,647	2,862
Net fee and commission income	632	433	357
Investment income and other income	-98	-173	-67
Total income	2,991	2,906	3,152

Expenditure:
Operating expenses	1,362	1,303	1,243
Additions to the provision for loan losses	171	149	119
Total expenditure	1,533	1,452	1,362

Result before tax	1,457	1,455	1,790
Taxation	472	505	631
Non-controlling interests	2	1	0
Net result IFRS-IASB	983	949	1,159

Year ended 31 December 2025 compared to year ended 31 December

2024

The net result of Retail Germany increased by EUR 35 million, or 3.6%, to

EUR 983 million in 2025 from EUR 949 million in 2024. Retail Germany

recorded a result before tax of EUR 1,457 million, stable year-on-year

despite higher risk costs.

The business continued to demonstrate strong commercial momentum,

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

customers. Customer lending showed a EUR 6.4 billion increase. Net core

lending growth (which is the increase in customer lending excluding the

Treasury portfolio) was EUR 6.9 billion, with mortgages remaining the

principal driver of growth. Customer deposits increased by EUR 6.6 billion,

reflecting the success of a promotional savings campaign, with a portion of

these funds subsequently channelled into investment products during the

second half of the year.

Net interest income declined 7.2% to EUR 2,457 million, as the positive

impact of volume growth was outweighed by narrower margins on

liabilities and mortgages, and by lower Treasury-related interest income,

the latter largely offset by an increase in investment and other income.

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

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

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

banking services.

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

32 million in regulatory costs, down from EUR 88 million a year earlier,

reflecting a lower contribution to the deposit guarantee scheme. Expenses

excluding regulatory costs in both years, as well as EUR 14 million of

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

predominantly due to higher internal staff expenses (related to annual

salary increases) and investments in business growth and scalability.

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

points of average customer lending) and were primarily related to

consumer lending and portfolio sales.

Year ended 31 December 2024 compared to year ended 31 December

2023

The net result of Retail Germany decreased by EUR 210 million, or 18%, to

EUR 949 million in 2024 from EUR 1,159 million in 2023. The result before

tax for Retail Germany was EUR 1,455 million, a decline of 19% year-on-

year, which was mainly due to lower income from liabilities.

Net interest income decreased 7.5% to EUR 2,647 million, as higher client

rates on savings led to a narrowing of the liability margin in comparison to

the elevated levels we had seen in 2023. This was partly offset by volume

growth in both lending and deposits. Net fee and commission income

increased 21% to EUR 433 million, mainly fuelled by investment products,

where we recorded a higher number of trades and exceeded the milestone

of EUR 100 billion in assets under management in 2024. The increase in fee

income was also attributable to higher fees from daily banking and

mortgage brokerage. Total investment and other income declined,

reflecting lower Treasury-related income.

Customer lending was up by EUR 7.3 billion year-on-year. Net core lending

growth (which excludes Treasury) was EUR 4.4 billion. Next to EUR 3.6

billion in mortgages we grew our other lending portfolio by EUR 0.8 billion,

with an increase in both our consumer lending and business lending

portfolio.

Customer deposits increased by EUR 7.5 billion following a successful

campaign to attract new savings and private customers, as well as a net

inflow of EUR 0.8 billion in Business Banking.

Operating expenses rose 4.8% to EUR 1,303 million. Excluding EUR 88

million of regulatory costs (down from EUR 96 million in 2023) and EUR 20

million of incidental items for restructuring costs and staff allowances

recorded in 2023, cost growth was 7.8%. This was due to higher staff

expenses and investments in business growth.

Net additions to loan loss provisions amounted to EUR 149 million (14 basis

points of average customer lending) and were primarily related to

consumer lending.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	68

Retail Other


Retail Other
in EUR million	2025	2024	2023
Income:
Net interest income	3,892	3,817	3,437
Net fee and commission income	717	609	519
Investment income and other income	299	263	277
Total income	4,908	4,688	4,233

Expenditure:
Operating expenses	2,905	2,792	2,479
Additions to the provision for loan losses	323	291	313
Total expenditure	3,228	3,083	2,792

Result before tax	1,680	1,605	1,441
Taxation	398	381	359
Non-controlling interests	225	221	174
Net result IFRS-IASB	1,058	1,002	908

Year ended 31 December 2025 compared to year ended 31 December

2024

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

Poland, Romania and Türkiye. The net result of Retail Other increased to

EUR 1,058 million in 2025 from EUR 1,002 million in 2024. The result before

tax for Retail Other was EUR 1,680 million compared with EUR 1,605 million

in 2024, with income growth more than offsetting a modest increase in

expenses and higher risk costs.

Customer lending rose by EUR 11.2 billion. Net core lending growth (which

reflects the increase in customer lending, adjusted for currency impacts

and Treasury) reached EUR 13.4 billion. This was led by an EUR 11.1 billion

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

Spain, and Poland — alongside continued growth in business and

consumer lending. Customer deposits grew by EUR 10.2 billion. Net core

deposits growth (which is the increase in customer deposits excluding

currency impacts and Treasury) amounted to EUR 12.6 billion, reflecting

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

Net interest income rose 2.0% to EUR 3,892 million, as the favourable

impact of higher lending and deposit volumes more than compensated for

lower liability margins and negative FX impacts. In addition, net interest

income in the prior year had included a EUR -39 million impact from the

Polish mortgage moratorium. Net fee and commission income increased

significantly to EUR 717 million, representing an 18% year-on-year rise.

Fee income from investment products grew substantially, driven by net

inflows and a higher number of trades. This was complemented by

markedly higher fee income from daily banking services and insurance,

reflecting both customer growth and successful cross-selling initiatives.

Investment and other income also rose year-on-year, thanks to an

increase in Treasury-related income.

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

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

higher contribution to the deposit guarantee scheme and increased bank

taxes in Poland. The previous year’s expenses had included EUR 17 million

in incidental restructuring costs (versus EUR 6 million in 2025) and a EUR

35 million legal provision. Excluding regulatory costs and these one-off

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

ongoing investments in future business growth.

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

points of average customer lending, with additions mainly in Poland.

Year ended 31 December 2024 compared to year ended 31 December

2023

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

Poland, Romania and Türkiye. The net result of Retail Other increased to

EUR 1,002 million in 2024 from EUR 908 million in 2023. For Retail Other,

result before tax increased 11% to EUR 1,605 million, mainly thanks to

higher income.

Total income rose 11% to EUR 4,688 million. Net interest income was up

11% to EUR 3,817 million, supported by growth in both lending and deposit

volumes in all countries, coupled with higher margins on liabilities outside

the eurozone. Net interest income in 2024 included a EUR -39 million

impact from the Polish mortgage moratorium, following amendments to

the regulation that offers some customers the right to suspend up to four

instalment payments on their mortgage loan. Net fee and commission

income increased 17% to EUR 609 million. This was driven by higher fees in

daily banking, reflecting an increase in the number of customers and an

updated pricing for payment packages, combined with higher fee income

from investment products. Other income decreased due to lower

Treasury-related income.

Customer lending rose by EUR 7.4 billion. Net customer lending growth

(which is the change in customer lending adjusted for currency effects and

Treasury) was EUR 8.2 billion in 2024, with growth in all countries, but

particularly in Australia, Poland, Spain and Italy. Customer deposits were

up by EUR 12.1 billion. Net core deposits growth (excluding currency

impacts and movements in Treasury deposits) was EUR 12.7 billion,

primarily driven by net inflows in Poland, Spain and Australia.

Operating expenses in 2024 amounted to EUR 2,792 million. Excluding

regulatory costs (which were slightly up on 2023) and restructuring costs

and impairments (EUR 17 million in 2024 versus EUR 36 million in 2023),

expenses increased by 15%. This was due to inflationary pressure

(particularly in Türkiye), higher client acquisition expenses and

investments in further business growth.

The net addition to loan loss provisions was EUR 291 million, or 26 basis

points of average customer lending, compared with EUR 313 million in

2023. Risk costs in 2024 were primarily attributable to net additions in

Poland and Spain.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	69

Wholesale Banking


Wholesale Banking
in EUR million	2025	2024	2023
Income:
Net interest income	2,997	3,259	4,028
Net fee and commission income	1,433	1,317	1,259
Investment income and other income	2,579	2,405	1,771
Total income	7,009	6,981	7,057

Expenditure:
Operating expenses	3,837	3,558	3,313
Additions to the provision for loan losses	549	627	-92
Total expenditure	4,386	4,185	3,222

Result before tax	2,624	2,796	3,836
Taxation	673	693	900
Non-controlling interests	48	35	61
Net result IFRS-EU	1,902	2,068	2,875
Adjustment of the EU 'IAS 39 carve-out'	1,996	-1,058	-3,147
Net result IFRS-IASB	3,899	1,010	-272

Year ended 31 December 2025 compared to year ended 31 December

2024

Without application of the EU ‘IAS 39 carve-out’, ING’s net result of

Wholesale Banking was EUR 3,899 million in 2025, compared with EUR 1,010

million in 2024. The adjustment of the EU ‘IAS 39 carve-out’, included in the

net result, was EUR 1,996 million in 2025, compared with EUR -1,058 million

in 2024, due to fair value changes on derivatives related to asset-liability-

management activities for the mortgage and savings portfolios in the

Benelux, Germany, France, Spain, Italy, and Romania. These fair value

changes were mainly a result of changes in market interest rates. No hedge

accounting is applied to these derivatives under IFRS-IASB.

The IFRS-EU net result (when applying the EU ‘IAS 39 carve-out’) decreased

to EUR 1,902 million from EUR 2,068 million in 2024. Wholesale Banking

delivered a robust performance in 2025, with a result before tax of EUR

2,624 million, compared with EUR 2,796 million in the previous year. Total

income grew slightly amid ongoing geopolitical uncertainties, and was

supported by a 9% rise in fee income, reflecting our strategic focus on

diversifying income streams. This growth helped to mitigate the impact of

margin compression in Payments & Cash Management and EUR -200

million in negative currency impacts. Earnings were also impacted by

elevated investment costs aimed at supporting future growth and EUR 90

million in restructuring provisions.

Customer lending IFRS-EU increased by EUR 7.3 billion. Net core lending

growth (which is the change in customer lending IFRS-EU, excluding

currency impacts and movements in the Treasury and run-off portfolios)

was significant at EUR 18.3 billion. This was driven by higher volumes in

Working Capital Solutions and short-term trade-related financing,

alongside a recovery in long-term loan demand in the second half of the

year. Customer deposits were up by EUR 5.0 billion. Net core deposits

growth (which excludes currency impacts and movements in the Treasury

portfolio) was EUR 8.0 billion, reflecting net inflows in Payments & Cash

Management and Financial Markets.

Total income from Lending increased slightly, supported by higher

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

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

strength of our client relationships and advisory capabilities. Through

disciplined capital management, we reduced risk-weighted assets within

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

and currency movements also contributing.

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

Higher revenues from increased client demand in Working Capital

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

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

in Payments & Cash Management.

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

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

Capital Markets issuance, all benefiting from healthy client flows and

favourable market conditions.

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

higher income from Corporate Investments almost fully offset a EUR 70

million one-off income recorded in 2024.

Operating expenses for 2025 included EUR 90 million in restructuring costs

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

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

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

regulatory costs (which increased slightly to EUR 219 million), expenses

rose 5.8% year-on-year, driven by targeted, multi-year investment

initiatives — focused on digital foundations, platforms, and product

capabilities — that are required to structurally improve long-term

profitability.

Net additions to loan loss provisions declined to EUR 549 million

(equivalent to 28 basis points of average customer lending), down from

EUR 627 million in 2024. Individual Stage 3 risk costs fell sharply due to

lower inflows, repayments and recoveries. Risk costs in Stage 1 and 2 were

higher, as 2024 had included releases from collective provisions, including

a partial release of management overlays.

Year ended 31 December 2024 compared to year ended 31 December

2023

Without application of the EU ‘IAS 39 carve-out’, ING’s net result of

Wholesale Banking turned to EUR 1,010 million in 2024, compared with a

loss of EUR -272 million in 2023. The adjustment of the EU ‘IAS 39 carve-out’,

included in the net result, was EUR -1,058 million in 2024, compared with

EUR -3,147 million in 2023, due to fair value changes on derivatives related

to asset-liability-management activities for the mortgage and savings

portfolios in the Benelux, Germany, France, Spain, and Italy. These fair value

changes were mainly a result of changes in market interest rates. No hedge

accounting is applied to these derivatives under IFRS-IASB.

The IFRS-EU net result (when applying the EU ‘IAS 39 carve-out’) decreased

to EUR 2,068 million from EUR 2,875 million in 2023. Total income was

resilient, supported by increased lending and deposit volumes and strong

results in Financial Markets, which compensated for margin compression in

Payments & Cash Management. Expenses rose, primarily due to the


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	70

impact of collective labour agreements, inflation and investments in

business growth and in our product foundations. We remained disciplined

in capital management, with a modest increase of EUR 1.9 billion in risk-

weighted assets, fully due to the strengthening of the US dollar, and

income over average risk-weighted assets was resilient at 458 basis points.

The net result declined 28% to EUR 2,068 million, mainly due to higher risk

costs versus a net release in 2023. The return on equity came out at 11.0%

in 2024.

Customer lending IFRS-EU rose by EUR 7.8 billion. Net core lending growth

(which is the increase in customer lending IFRS-EU, adjusted for currency

impacts and changes in the Treasury and run-off portfolios) was EUR 1.8

billion in 2024, with the increase being softened by loan sales and other

ongoing efforts to optimise our capital usage. Customer deposits were EUR

14.9 billion higher year-on-year. Net core deposits growth (which excludes

currency impacts and movements in Treasury deposits) was EUR 15.8

billion in 2024, mainly attributable to strategic initiatives in Payments &

Cash Management and Money Markets.

Total income in 2024 amounted to EUR 6,981 million and was almost

stable year-on-year. Our focus on income diversification yielded positive

results, as evidenced by higher income from Financial Markets and an

increase in fee income. Our Capital Markets & Advisory business continued

to grow, following investments to further build on our expertise. Income

from Payments & Cash Management declined, reflecting lower margins.

Total income in Lending rose 1.7% to EUR 3,278 million, with an increase in

both net interest income and in fee income. We further optimised our

capital efficiency and kept our risk-weighted assets flat despite the

strengthening of the US dollar, leading to an improvement in income over

average risk-weighted assets.

In Daily Banking & Trade Finance we were successful in attracting deposit

balances. Income declined year-on-year, reflecting lower margins for

Payments & Cash Management. This was partly offset by income growth

for Trade Finance Services, on the back of higher margins and increased

fee income.

Financial Markets had a strong year, with income increasing 11% to EUR

1,417 million. This was primarily driven by increased Capital Markets

issuance income and an enhanced performance in Global Securities

Finance products.

Income from Treasury & Other declined, largely due to a lower

remuneration on the ECB minimum reserve requirement, while Treasury

had also benefited from the rapid increase in interest rates in 2023. This

was coupled with lower results from Corporate Investments, and partly

offset by a EUR 70 million one-off income.

Total operating expenses increased 7.4% to EUR 3,558 million. Regulatory

costs were lower, mainly because no contribution to the eurozone’s Single

Resolution Fund was required in 2024. Excluding regulatory costs and

incidental item costs (EUR 10 million in 2024 versus EUR 17 million in the

year before), expenses increased 10%. This was due to the impact of

collective labour agreements, inflation and front office growth in Capital

Markets & Advisory and Transaction Services, as well as investments to

enhance the digital customer experience and the scalability of our

systems.

The net addition to loan loss provision amounted to EUR 627 million in

2024 (33 basis points of average customer lending). This compares to a net

release of EUR 92 million in 2023, when EUR 218 million of provisions for

our Russia-related portfolio could be released, mainly due to a reduction of

our exposure. Risk costs in 2024 were primarily related to individual Stage

3 provisioning. Additions for a number of unrelated files in Stage 3 were

partly offset by releases from collective provisions in Stage 1 and 2

(including a partial release of management overlays).


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	71

Alternative performance measures

Our financial information is prepared in accordance with IFRS as detailed out in the financial statements of our Annual Report. In addition, in the discussion of our financial performance, we use a number of alternative performance

measures, including resilient net profit, commercial net interest income and net core lending and net core deposits growth. Resilient net profit is defined as net profit adjusted for significant items not linked to the normal course of

business, reference is made to 'Capital Management' for a reconciliation. We consider commercial net interest income, and the derived commercial net interest margin, to be useful information because the scope is restricted to those

products that are mainly interest driven and excludes the interest on products where performance measurement is primarily done based on fee income or at the total income level (including Financial Markets and Treasury).

Commercial net interest income also excludes significant volatile items in lending and liability net interest income, thus removing items that distort period-on-period comparisons. We consider net core lending and net core deposits

growth as useful information to track our real commercial growth in customer balances. It measures the development of our customer lending and deposits adjusted for currency impacts and changes in the Treasury and run-off

portfolios.

The tables below show how net core lending growth and net core deposits growth can be reconciled to the nearest IFRS-IASB measure.


Reconciliation commercial net interest income (NII)
	Retail Netherlands			Retail Belgium			Retail Germany			Retail Other			Wholesale Banking			Corporate Line			Total
in EUR million	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023
Net interest income IFRS-IASB	3,115	3,027	3,096	1,786	1,959	2,063	2,457	2,647	2,862	3,892	3,817	3,437	3,273	3,524	4,214	434	315	489	14,957	15,288	16,162
IFRS-EU 'IAS 39 carve-out' impact													-276	-265	-187				-276	-265	-187
Net interest income IFRS-EU	3,115	3,027	3,096	1,786	1,959	2,063	2,457	2,647	2,862	3,892	3,817	3,437	2,997	3,259	4,028	434	315	489	14,681	15,023	15,976
Exclude: Other NII (excl. significant volatile items)1	-572	-621	-535	93	142	198	205	298	151	195	213	207	-972	-693	-171	434	315	489	-618	-346	338
Exclude: Significant volatile items2							-18	-51			-39			70					-18	-20
Commercial net interest income	3,687	3,647	3,631	1,692	1,816	1,866	2,270	2,400	2,711	3,698	3,643	3,231	3,969	3,882	4,199	0	0	0	15,316	15,389	15,638

1Other NII mainly includes NII for Financial Markets and Treasury. In Financial Markets this primarily reflects the funding costs of positions for which associated revenue is reported in 'other income'. For Treasury, it includes the funding costs of specific money market and FX transactions where an offsetting revenue is

recorded in 'other income', as well as interest income from other Treasury activities (such as foreign currency ratio hedging) that are not allocated to Retail or Wholesale. Furthermore, other NII includes the funding costs for our equity stakes, the NII related to investment portfolios, as well as the effect of indexation

of NII required by IAS 29 due to hyperinflation in Türkiye.

2Significant volatile items in lending and liability NII are lending- and liability-related interest items that management would consider as outside the normal course of business and large enough to distort a proper period-on-period comparison. For the years 2025 and 2024, it includes EUR -18 million (2025) and

EUR -51 million (2024) for incentives to attract new customers (Retail Germany), EUR -39 million for the Polish mortgage moratorium (2024), and a EUR +70 million one-off in Wholesale Banking (2024).


Customer lending IFRS-IASB versus Customer lending IFRS-EU and Net core lending growth by business line
	Retail Netherlands			Retail Belgium			Retail Germany			Retail Other			Wholesale Banking			Corporate Line			Total
in EUR billion	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change
Customer lending IFRS-IASB 1	179.2	164.3	14.9	100.1	98.3	1.8	116.6	110.2	6.4	128.4	117.2	11.2	209.1	199.2	10.0	0.3	0.3	0.0	733.6	689.4	44.2
IFRS-EU 'IAS 39 carve out' impact													-6.0	-3.4	-2.6				-6.0	-3.4	-2.6
Customer lending IFRS-EU	179.2	164.3	14.9	100.1	98.3	1.8	116.6	110.2	6.4	128.4	117.2	11.2	203.1	195.8	7.3	0.3	0.3	0.0	727.6	686.1	41.5
Exclude: FX impact			0.0			0.0			0.0			2.3			8.9						11.2
Exclude: Change in fair value macro hedged loans															2.6						2.6
Exclude: Treasury, run-off portfolios and other			1.3			0.3			0.5			-0.1			-0.5			0.0			1.5
Net core lending growth			16.2			2.0			6.9			13.4			18.3			0.0			56.9

1Loans and advances to customers excluding loan loss provision.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	72


Customer deposits IFRS-IASB versus Customer deposits IFRS-EU and Net core deposits growth by business line
	Retail Netherlands			Retail Belgium			Retail Germany			Retail Other			Wholesale Banking			Corporate Line			Total
in EUR billion	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change	2025	2024	change
Customer deposits IFRS-IASB	209.1	200.7	8.5	96.5	97.1	-0.6	157.7	151.1	6.6	173.4	163.2	10.2	84.6	79.6	5.0	0.0	0.0	0.0	721.4	691.7	29.7
IFRS-EU 'IAS 39 carve out' impact													0.0	0.0	0.0				0.0	0.0	0.0
Customer deposits IFRS-EU	209.1	200.7	8.5	96.5	97.1	-0.6	157.7	151.1	6.6	173.4	163.2	10.2	84.6	79.6	5.0	0.0	0.0	0.0	721.4	691.7	29.7
Exclude: FX impact			0.0			0.0			0.0			2.3			1.4						3.7
Exclude: Change in fair value macro hedged deposits															0.0						0.0
Exclude: Treasury, run-off portfolios and other			3.1			-0.1			0.0			0.1			1.6			0.0			4.7
Net core deposits growth			11.5			-0.6			6.6			12.6			8.0			0.0			38.1


Customer lending IFRS-IASB versus Customer lending IFRS-EU and Net core lending growth by business line
	Retail Netherlands			Retail Belgium			Retail Germany			Retail Other			Wholesale Banking			Corporate Line			Total
in EUR billion	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change
Customer lending IFRS-IASB 1	164.3	152.8	11.4	98.3	94.3	4.0	110.2	102.9	7.3	117.2	109.8	7.4	199.2	192.9	6.3	0.3	0.3	0.0	689.4	652.9	36.5
IFRS-EU 'IAS 39 carve out' impact													-3.4	-4.9	1.5				-3.4	-4.9	1.5
Customer lending IFRS-EU	164.3	152.8	11.4	98.3	94.3	4.0	110.2	102.9	7.3	117.2	109.8	7.4	195.8	188.0	7.8	0.3	0.3	0.0	686.1	648.0	38.0
Exclude: FX impact			0.0			0.0			0.0			0.9			-4.7						-3.8
Exclude: Change in fair value macro hedged loans															-1.5						-1.5
Exclude: Treasury, run-off portfolios and other			-1.9			-0.4			-2.9			-0.2			0.2			0.0			-5.1
Net core lending growth			9.6			3.7			4.4			8.2			1.8			0.0			27.7

1Loans and advances to customers excluding loan loss provision.


Customer deposits IFRS-IASB versus Customer deposits IFRS-EU and Net core deposits growth by business line
	Retail Netherlands			Retail Belgium			Retail Germany			Retail Other			Wholesale Banking			Corporate Line			Total
in EUR billion	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change	2024	2023	change
Customer deposits IFRS-IASB	200.7	199.7	1.0	97.1	91.2	5.9	151.1	143.6	7.5	163.2	151.0	12.1	79.6	64.8	14.9	0.0	0.0	0.0	691.7	650.3	41.4
IFRS-EU 'IAS 39 carve out' impact													0.0	0.0	0.0				0.0	0.0	0.0
Customer deposits IFRS-EU	200.7	199.7	1.0	97.1	91.2	5.9	151.1	143.6	7.5	163.2	151.0	12.1	79.6	64.8	14.9	0.0	0.0	0.0	691.7	650.3	41.4
Exclude: FX impact			0.0			0.0			0.0			0.6			-0.4						0.3
Exclude: Change in fair value macro hedged deposits															0.0						0.0
Exclude: Treasury, run-off portfolios and other			4.0			0.5			0.0			-0.1			1.3			0.0			5.8
Net core deposits growth			5.0			6.4			7.5			12.7			15.8			0.0			47.4


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	73

B.Liquidity and capital resources

ING believes that its working capital is sufficient for its present

requirements.

For information regarding our material short and long- term cash

requirements from known contractual and other obligations, see

“Additional information – ING Group Risk Management section Funding and

liquidity risk”, "Additional information - ING Capital management" and

Note 46 'Capital management' in the consolidated financial statements.

For information on legal or economic restrictions on the ability of

subsidiaries to transfer funds to the company in the form of cash

dividends, loans or advances, see Note 19 'Equity' in the consolidated

financial statements.

For information on the maturity profile of borrowings and a further

description of the borrowings, please see Note 17 'Debt securities in issue',

Note 18 'Subordinated loans' and Note 38 'Liabilities and off-balance sheet

commitments by maturity' in the consolidated financial statements.

For information on currency and interest rate structure, see “Additional

information – ING Group Risk Management section Market risk” and

“Additional information – ING Group Risk Management section Funding and

liquidity risk”.

For information on the use of financial instruments for hedging purposes,

please see Note 36 'Derivatives and hedge accounting' in the consolidated

financial statements.


ING Group Consolidated Cash Flows

cash and cash equivalents
in EUR million	2025	2024	2023
Treasury bills and other eligible bills included in securities at AC	–	37	–
Deposits from banks	-7,065	-6,303	-5,132
Loans and advances to banks	8,324	4,982	7,931
Cash and balances with central banks	52,889	70,353	90,214
Cash and cash equivalents at end of year	54,148	69,069	93,012

Year ended 31 December 2025 compared to year ended 31 December

2024

Net cash flow from operating activities amounts to EUR -6,380 million for

the year-end 2025, compared to EUR -22,544 million for the year-end

2024. The increase in cash flow from operating activities of EUR 16,164

million in 2025 is explained by higher cash inflows for trading assets and

liabilities (EUR 20,009 million), Loans and deposits from banks (EUR 20,192

million) and higher result before tax, after adjustment for non-cash items

(EUR 2,605 million) and is partly offset by higher cash outflows from loans

and deposits to/from customers (EUR -28,845 million).

Net cash flow from investing activities amounts to EUR -15,697 million for

the year-end 2025 compared to EUR -6,033 million in 2024. The net cash

flow from investing activities decreased by EUR -9,663 million and is

explained by a net decrease from Financial assets at fair value through OCI

of EUR -6,057 million and net decrease from Securities at amortised costs

of EUR -3,673 million.

Net cash flow from financing activities amounts to EUR 8,245 million in

2025, compared to EUR 5,374 million in 2024. The increase of EUR 2,871

million is explained by a net increase of EUR 3,502 million of debt securities

and is partly offset by a net decrease of EUR -746 million of Subordinated

loans.

The operating, investing and financing activities described above result in a

decrease of EUR -14,921 million in cash and cash equivalents to EUR

54,148 million at year end 2025 including negative exchange rate effect

on cash and cash equivalents of EUR -1,089 million.

Year ended 31 December 2024 compared to year ended

31 December 2023

Net cash flow from operating activities amounts to EUR -22,544 million for

the year-end 2024, compared to EUR -11,340 million for the year-end

2023. The decrease in cash flow from operating activities of EUR -11,204

million in 2024 is explained by higher cash outflows for trading assets and

liabilities (EUR -9,400 million), assets and liabilities mandatorily and

designated at fair value through profit or loss (EUR -4,515 million), other

assets and liabilities (EUR -4,326 million), non-trading derivatives (EUR

-2,463 million) and is partly offset by higher cash inflows from loans and

deposits to/from customers (EUR 3,992 million), loans and deposits to/from

banks (EUR 3,558 million) and higher result before tax, after adjustment for

non-cash items (EUR 2,224 million).

Net cash flow from investing activities amounts to EUR -6,033 million for

the year-end 2024 compared to EUR -8,545 million in 2023. The net cash

flow from investing activities increased by EUR 2,511 million and is

explained by a net increase from Financial assets at fair value through OCI

of EUR 3,939 million and net decrease from Securities at amortised costs

of EUR -1,231 million.

Net cash flow from financing activities amounts to EUR 5,374 million in

2024, compared to EUR 18,404 million in 2023. The decrease of EUR

-13,030 million is explained by a net decrease of EUR -14,175 million of

debt securities and higher dividend paid of EUR -911 million partly offset

by a net increase of EUR 2,341 million of Subordinated loans.

The operating, investing and financing activities described above result in a

decrease of EUR -23,944 million in cash and cash equivalents to EUR

69,069 million at year end 2024 including exchange rate effect on cash

and cash equivalents of EUR -740 million.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	75

Item 6. Directors, Senior Management and Employees

A.Directors and senior management

Executive Board

Roles and responsibilities

The Executive Board (EB) is entrusted with the management of ING Group

and its subsidiaries and is responsible for the continuity and long-term

value creation of ING. This includes the day-to-day management of the

business and setting ING’s strategy, the responsibility of which is vested in

the members of the EB collectively. The organisation, main roles and

responsibilities of the EB are set out in the Management Board Charter,

which is available on ing.com.

The EB performs its activities under the supervision of the Supervisory

Board (SB). The Articles of Association, the Management Board Charter and

the Supervisory Board Charter, which are available on ing.com, outline

which resolutions of the EB are subject to approval by the SB.

ING Group indemnifies the members of the EB to the extent permitted by

law against direct financial losses in connection with claims from third

parties. This applies to claims filed, or threatened to be filed, against them

in connection with their service as a member of the EB in accordance with

the Articles of Association and their commission contract. ING Group has

taken out liability insurance for the members of the EB.

Appointment and reappointment

The SB is responsible for selecting and nominating candidates to be

appointed or reappointed to the EB by the General Meeting, based on,

among other factors, the EB profile, which is available on ing.com. The SB

regularly assesses the composition and functioning of the EB.

The following two topics form part of this process:

1.Bench strength and succession planning for EB positions are continuous

attention points. Potential internal candidates for such roles may be

complemented with potential talent from outside ING.

2.A long-term view is taken on the composition of the EB in line with

strategic priorities.

Members of the EB are appointed, suspended and dismissed by the

General Meeting. The SB may draw up a binding list of candidates for

appointment and may propose the dismissal and suspension of EB

members. Candidates for appointment to the EB are assessed by the DNB

and the ECB for suitability and integrity and must continue to meet these

criteria while in function.

A resolution of the General Meeting to render this list non-binding, or to

suspend or dismiss EB members without this being proposed by the SB,

requires an absolute majority of the votes cast. Additionally, this majority

must represent more than half of the issued share capital. In a second

general meeting, such a resolution also requires an absolute majority of

the votes cast, and this majority must represent more than half of the

issued share capital. This ensures that such significant resolutions can only

be adopted with substantial support of ING Group’s shareholders.

Composition of the Executive Board

On 24 July 2025, it was announced that Tanate Phutrakul will step down

from his position as chief financial officer, member of the Management

Board Banking and member of the Executive Board as of the 2026 General

Meeting. On 29 October 2025, it was announced that Ida Lerner will be

appointed as chief financial officer and member of the Management Board

Banking effective 1 April 2026. The Supervisory Board will propose to

shareholders to appoint her as member of the Executive Board and as CFO

of ING Group at the 2026 General Meeting.

Furthermore, on 23 October 2025, it was announced that Ljiljana Čortan

will step down as CRO and will succeed Andrew Bester as head of

Wholesale Banking. It has since been announced that Ljiljana will start as

head of Wholesale Banking and leave her position as CRO on 24 February

2026. She will remain a member of the EB until a successor is appointed as

CRO.

Remuneration and share ownership

Details of the remuneration of members of the EB, including shares

granted to them, are set out in the ‘Remuneration report’.

Members of the EB are permitted to hold shares in the share capital of ING

Group for long-term investment purposes. Transactions by members of

the Executive Board in these shares need to comply with the ING

regulations for insiders, which are available on ing.com.

Relevant positions pursuant to CRD IV/conflicting interests

Members of the EB may hold other positions outside ING. No member of

the EB had corporate directorships relevant under CRD IV outside ING

throughout 2025.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	77

Members of the Executive Board and Management Board Banking

Steven van

Rijswijk

(CEO)

Born 1970

Nationality Dutch

Tanate

Phutrakul

(CFO)

Born 1965

Nationality Thai

Ljiljana

Čortan

(CRO)

Born 1971

Nationality Croatian

Pinar

Abay

Born 1977

Nationality Turkish

Steven has been a member of the EB since May 2017. He

has been CEO and chairperson of this board since July

2020. Prior to his appointment as CEO and chairperson of

this board, he was the chief risk officer.

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

sustainability, leading governance including the decision-

making process, results, culture, branding, reputation and

people.

Tanate was appointed as chief financial officer and a

member of the MBB in February 2019. Subsequently,

Tanate was appointed a member of the EB at the Annual

General Meeting in April 2019.

Tanate is responsible for ING's financial strategy,

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

Ljiljana was appointed as chief risk officer and a member

of the MBB effective January 2021. Ljiljana was appointed

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

2021.

Ljiljana is responsible for ING's risk activities, including

formulating our risk management framework and risk

appetite, risk culture and awareness, risk governance and

policies and compliance.

Pinar was appointed a member of the MBB in January

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

Challengers & Growth Markets.

Pinar is responsible for ING's retail banking activities

globally.

Relevant CRD IV position(s)

§CEO and chairperson of the EB and MBB

Other ancillary positions

§Member of the management board of the Nederlandse

Vereniging van Banken (NVB)

§Member of the Cyber Security Council (CSR)

Relevant CRD IV position(s)

§CFO and member of the EB and the MBB

Other ancillary positions

§None

Relevant CRD IV position(s)

§CRO and member of the EB and the MBB

Other ancillary positions

§None

Relevant CRD IV position(s)

§Member of the MBB

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

S.A.

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

§Member of the board of EPI Company SE

Other ancillary positions

§None


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	79

Supervisory Board

Roles and responsibilities

The SB members are collectively responsible for supervising and advising

the EB and for overseeing the activities of ING and the business connected

with it. The organisation, powers and modus operandi of the SB are set out

in the Charter of the Supervisory Board, available on ing.com.

In performing their duties, members of the SB are required to:

§be guided by the interests of ING and the business connected with it,

thereby carefully balancing the interests of all stakeholders of ING and

in this consideration give paramount importance to customers'

interests, as set out in the Dutch Banker’s Oath;

§foster a culture focused on sustainable long-term value creation,

financial and non-financial risk awareness, compliance with ING’s risk

appetite, and responsible and ethical behaviour;

§stimulate openness and accountability within ING and its subsidiaries;

§act without mandate from third parties and independent of any

interest in the business of ING; and

§ensure that the Supervisory Board functions effectively.

The articles of association of ING Group (Articles of Association), the

Management Board Charter and the Supervisory Board Charter outline

which resolutions of the EB are subject to approval by the SB.

ING Group indemnifies the members of the SB as far as legally permitted

against direct financial losses in connection with claims from third parties

filed, or threatened to be filed, against them by virtue of their service as a

member of the SB in accordance with the Articles of Association.

Composition

ING Group aims to have an adequate and balanced composition of its SB,

with a mix of persons with knowledge, skills and executive experience,

preferably gained in the banking sector, experience in corporate

governance of large stock-listed companies, and experience in the political

and social environment in which such companies operate. In the selection

of the members of the SB, consideration is given to a range of professional

qualifications and backgrounds, including experience, skills, education and

business judgment. In addition, there should be a balance of experience

and affinity with the nature and culture of the business of ING. ING believes

that a range of professional background and experience at the level of the

SB fosters a diversity of views and experiences and facilitates independent

opinions and sound decision-making, which has a positive impact on ING’s

business and stakeholders. According to the Dutch Gender Diversity Act,

ING is required to comply with a gender-diversity quota of at least one

third male and at least one third female for its SB. ING meets this criterion.

As from 1 July 2025, the SB consisted of seven male members and four

female members.

The SB is responsible for selecting and nominating candidates for

appointment or reappointment to the SB, based on, among other factors,

the SB profile, which is available on ing.com. The SB regularly assesses its

composition.

On 20 January 2026, it was announced that Herna Verhagen will resign

from the Supervisory Board as of the 2026 General Meeting. As of this

date, Herna will also step down as chairperson of the Remuneration

Committee and as member of the Nomination and Corporate Governance

Committee and the Risk Committee.

Appointment, suspension and dismissal

Members of the SB are appointed, suspended and dismissed by the

General Meeting. The SB may draw up a binding list of candidates for

appointment and may propose the dismissal and suspension of SB

members. Candidates for appointment to the SB are assessed by the DNB

and ECB for suitability and reliability, and must continue to meet these

criteria while in function.

A resolution of the General Meeting to render this list non-binding, or to

suspend or dismiss SB members without this being proposed by the SB,

requires an absolute majority of the votes cast. In addition, this majority

must represent more than half of the issued share capital. In a second

general meeting, such a resolution also requires an absolute majority of

the votes cast, and this majority must represent more than half of the

issued share capital. This ensures that such significant resolutions can only

be adopted with substantial support of ING Group’s shareholders.

Term of appointment of the Supervisory Board members

As a general rule, SB members step down from the SB after the fourth

anniversary of their last appointment or reappointment term. SB members

are appointed for four years and may be reappointed once for another

four-year term. Thereafter, they may be reappointed for an additional

two-year term, which may be extended by no more than two years. The

SB may deviate from this general rule under special circumstances and

with explanation, for instance to maintain a balanced composition of the

SB and/or to preserve valuable expertise and experience. The retirement

schedule is available on ing.com.

Relevant positions pursuant to CRD IV / conflicting interests

Members of the SB may hold other positions outside ING, including

directorships, either paid or unpaid. CRD IV restricts the total number of SB

positions or non-executive directorships with predominantly commercial

organisations that may be held by an SB member to four. If an SB member

also has an executive position, the number of positions is restricted to two.

The ECB may, under special circumstances, permit an SB member to fulfil

an additional SB position or non-executive directorship. Positions with, inter

alia, subsidiaries or qualified holdings are not taken into account in the

application of these restrictions. Such positions may not conflict with the

interests of ING Group. It is the responsibility of the individual member of

the SB and the SB collectively to ensure that the directorship duties are

performed properly and are not affected by any other positions that the

individual may hold outside ING Group.

Members of the SB are to report any conflict of interest (including potential

conflicts of interest) to the chairperson of the SB (or, in the case of the

chairperson, to the vice-chairperson) and to the other SB members, and

shall provide all relevant information. The SB, excluding the member

concerned, decides whether a conflict of interest exists.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	80

In the case of a conflict of interest, the relevant member of the SB abstains

from discussions and decision-making on the topic or the transaction in

relation to which they have a conflict of interest with ING Group.

Transactions involving actual or potential conflicts of interest

There were no transactions reported in 2025 in which there were conflicts

of interest with SB members that are of material significance to ING Group

and/or to the relevant board members.

If a member of the SB obtains financial products and services, other than

loans, which are provided by ING Group subsidiaries in the ordinary course

of business on terms that apply to employees, this is not considered to be

a material conflicting interest. Banking and financial products in which the

granting of credit is of a secondary nature, e.g. credit cards and overdrafts

in a current account, are not considered a loan for this purpose and are

therefore not disclosed in the ‘Remuneration report’. For an overview of

loans granted to members of the SB, see the ‘Remuneration report’.

Independence

All SB members, with the exception of no more than one person, should

qualify as independent as defined in the best practice provision 2.1.8 of the

Dutch Corporate Governance Code. The members of the SB are therefore

requested to assess annually whether or not they are independent as set

out in the Code and to confirm this in writing. On this basis, the SB confirms

that all members of the SB are to be regarded as independent on 31

December 2025. On this date all members of the SB were also to be

regarded as independent within the meaning of the NYSE listing standards.

Committees of the Supervisory Board

On 31 December 2025, the SB had six committees: the Risk Committee, the

Audit Committee, the Nomination and Corporate Governance Committee,

the Remuneration Committee, the ESG Committee and the Technology &

Operations Committee.

Separate charters have been drawn up for these committees, which are

available on ing.com.

Remuneration and share ownership

Remuneration of the members of the SB is determined by the General

Meeting and does not depend on the results of ING Group. Members of the

SB are permitted to hold shares in the share capital of ING Group for long-

term investment purposes. Details are given in the ‘Remuneration report’.

Transactions by members of the SB in these shares need to comply with

the ING insider regulations, which are available on ing.com.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	81

Members of the Supervisory Board

Karl

Guha

(chairperson)

Born 1964

Nationality Dutch

Term expires 2027

Mike

Rees

(vice-chairperson)

Born 1956

Nationality British

Term expires 2027

Juan

Colombás

Born 1962

Nationality Spanish

Term expires 2028

Stuart

Graham

Born 1967

Nationality British/German

Term expires 2029

Karl was appointed chairperson of the SB at the General

Meeting in April 2023.

Karl is chairperson of the Nomination and Corporate

Governance Committee and a member of the

Remuneration Committee, the Risk Committee, the Audit

Committee, the ESG Committee and the Technology &

Operations Committee.

Mike was appointed a member of the SB at the General

Meeting in April 2019.

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

Committee and a member of the Nomination and

Corporate Governance Committee and the Audit

Committee.

Juan was appointed a member of the SB at the General

Meeting in April 2020.

Juan is chairperson of the Technology & Operations

Committee and a member of the Risk Committee, the

Audit Committee and the ESG Committee.

Stuart was appointed a member of the SB at the General

Meeting in April 2025.

Stuart is a member of the Risk Committee, the ESG

Committee, the Technology & Operations Committee and

the Audit Committee.

Former position

CEO of Van Lanschot Kempen N.V.

Relevant CRD IV position(s)

§Chairperson of the SB

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

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

Other ancillary positions

§Member of the supervisory board of Rijksmuseum Fonds

Former position

Deputy CEO of Standard Chartered Bank PLC

Relevant CRD IV position(s)

§Vice-chairperson of the SB

§Non-executive chairperson of the board of directors of

Midlands Mindforge

Other ancillary positions

§Non-executive chairperson of the board of directors of

Mauritius Africa FinTech Hub

Former position

Chief operations officer and executive board member of the

board of directors of Lloyds Banking Group PLC

Relevant CRD IV position(s)

§Member of the SB

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

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

Azora Gestion SGIIC

§Non-executive chairperson of the board of directors of

Bluserena Spa Unipersonale

Other ancillary positions

§Member of the global alumni advisory board of the

Institute de Empresa (IE) Business School

Former position

Co-founder and CEO of Autonomous Research

Relevant CRD IV position(s)

§Member of the SB

Other ancillary positions

§None


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	82

Margarete

Haase

Born 1953

Nationality Austrian

Term expires 2027

Lodewijk Hijmans

van den Bergh

Born 1963

Nationality Dutch

Term expires 2029

Petri

Hofsté

Born 1961

Nationality Dutch

Term expires 2029

Herman

Hulst

Born 1955

Nationality Dutch

Term expires 2028

Margarete was appointed a member of the SB at the

General Meeting in May 2017.

Margarete is chairperson of the Audit Committee and a

member of the Risk Committee and the Remuneration

Committee.

Lodewijk was appointed a member of the SB at the

General Meeting in April 2021.

Lodewijk is chairperson of the ESG Committee and a

member of the Risk Committee.

Petri was appointed a member of the SB at the General

Meeting in April 2025.

Petri is a member of the Risk Committee and the Audit

Committee.

Herman was appointed a member of the SB at the General

Meeting in April 2020.

Herman is a member of the Audit Committee, the Risk

Committee and the ESG Committee.

Former position

CFO of Deutz AG

Relevant CRD IV position(s)

§Member of the SB

§Chairperson of the supervisory board of ams-OSRAM AG

§Member of the supervisory board of Fraport AG

Other ancillary positions

§Chairperson of the employers association of Kölnmetall

§Member of the German Corporate Governance

Commission

Former position

Partner/member of the management committee of De

Brauw Blackstone Westbroek N.V.

Relevant CRD IV position(s)

§Member of the SB

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

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

Other ancillary positions

§Chairperson of the executive committee of Vereniging

Aegon

Former position

Member of the supervisory board of Coöperatieve Rabobank

U.A.

Relevant CRD IV position(s)

§Member of the SB

§Member of the supervisory board of Royal Friesland

Campina N.V.

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

Other ancillary positions

§Chair of the foundation board of the Nyenrode

Foundation

§Member of the board of Oranje Fonds

§Member of the NBA Stakeholders Forum

§Member of the committee of reporting & accountancy

(Commissie Verslaggeving & Accountancy) of AFM

Former position

Global vice-chairperson EY Japan

Relevant CRD IV position(s)

§Member of the SB

Other ancillary positions

§None


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	83

Harold

Naus

Born 1969

Nationality Dutch

Term expires 2028

Alexandra

Reich

Born 1963

Nationality Austrian

Term expires 2027

Herna

Verhagen

Born 1966

Nationality Dutch

Term expires 2027

Harold was appointed a member of the SB at the General

Meeting in April 2020.

Harold is a member of the Remuneration Committee, the

Risk Committee and the Technology & Operations

Committee.

Alexandra was appointed a member of the SB at the

General Meeting in April 2023.

Alexandra is a member of the Risk Committee, the

Technology & Operations Committee and the ESG

Committee.

Herna was appointed a member of the SB at the General

Meeting in April 2019.

Herna is chairperson of the Remuneration Committee and

a member of the Nomination and Corporate Governance

Committee and the Risk Committee.

Former position

Global head of Trading Risk Management and general

manager Market Risk of ING Bank and CEO of various

Cardano entities.

Relevant CRD IV position(s)

§Member of the SB

§Chairman of the advisory board of Cardano Nederland

B.V.

§Member of the supervisory board and chair of the Audit

Committee and the Appointment & Remuneration

Committee of N.V. Eneco

Other ancillary positions

§None

Former position

CEO of Telenor Thailand

Relevant CRD IV position(s)

§Member of the SB

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

Telecom S.A.

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

Fiber

§Non-executive director on the board of the Connecting

Europe Broadband Fund

Other ancillary positions

§None

Former position

CEO of PostNL N.V.

Relevant CRD IV position(s)

§Member of the SB

§Member of the supervisory board of Koninklijke Philips

N.V.

Other ancillary positions

§None



		Supervisory Board in numbers


				Board members 11

				Average age 62

				Nationalities 5

				Average board tenure (years) 4

				Female 36%

				Independent board members* 100%


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	84

B. Compensation

Remuneration report

FOR ADVISORY VOTE AT 2026 ING GROEP N.V. ANNUAL GENERAL

MEETING (AGM)

This Remuneration report is based on the

remuneration policies for the Executive Board (EB)

and Supervisory Board (SB). This section of the

report is the Remuneration report as referred to in

the Dutch Act implementing the EU Shareholder

Rights Directive II (SRD II). It will be presented to

shareholders at the 2026 AGM for an advisory

vote. An explanation of how the results of this vote

are taken into account will be included in the 2026

Remuneration report.

This Remuneration report includes, under section 2025 Executive Board

performance and remuneration, further alignment with prescribed tables

from the draft (non-binding) ‘Guidelines on the standardised presentation

of the remuneration report’ from the European Commission. In addition,

we comply with the European Sustainability Reporting Standards (ESRS)

related to the GOV-3 requirements, which are incorporated by reference.

The services of the following external consultants were used with regards

to remuneration: Stibbe, Willis Towers Watson, Aon, Korn Ferry Hay Group,

and PricewaterhouseCoopers. These are independent consultants who, at

the request of ING, provide advice.

2025 AGM

The 2024 Remuneration report was presented for an advisory vote at the

AGM held on 22 April 2025 (2025 AGM). The outcome was an advisory vote

of 95.25 percent in favour, reflecting strong shareholder support for our

remuneration practices. During the 2025 AGM, shareholders raised

questions regarding the integration of climate-related targets and their

linkage to variable remuneration. These targets are embedded in the non-

financial performance metrics, which are used to determine variable

remuneration outcome. In addition, our SB RemCo Chair emphasised the

importance of market-competitive pay to attract and retain high-calibre

talent and noted that a remuneration review would be conducted in 2025,

with stakeholder engagement. This review has been carried out

extensively, including broad stakeholder involvement.

Board changes in 2025

Steven van Rijswijk and Ljiljana Čortan were reappointed as members of the EB

at the 2025 AGM for another four-year term, lasting until the end of the 2029

AGM. On 23 October 2025, it was announced that Ljiljana Čortan would step

down from her role as CRO and succeed Andrew Bester as head of Wholesale

Banking. Ljiljana Čortan will leave her position as CRO on 24 February 2026 but

remain a member of the EB until a successor is appointed. On 24 July 2025, it

was announced that Tanate Phutrakul would step down from his role as CFO

as of the 2026 AGM. In accordance with the Executive Board Remuneration

Policy and with due observance of applicable legal requirements, a severance

payment equal to one year's base salary has been granted and his previous

deferred variable remuneration awards will continue to vest over time

according to the schedule. On 29 October 2025, we announced that Ida Lerner

will be appointed as a member of the Management Board Banking as of 1 April

2026. Subsequently, she will be proposed to be appointed as a member of the

EB and as CFO at the AGM in April 2026. Her remuneration package will be in

line with the current Executive Board Remuneration Policy and the proposed

new Executive Board Remuneration Policy, and is similar to the remuneration

package of the previous CFO. The main elements of Ida Lerner’s contract will be

published on ING’s website.

Shareholders at the 2025 AGM approved the appointment of Petri Hofsté

and Stuart Graham as new members of the SB for a four-year term. In

addition, shareholders approved the reappointment of Margarete Haase

for a two-year term and of Lodewijk Hijmans van den Bergh for another

four-year term on the SB.

Main decisions on the remuneration of the Executive

Board and Supervisory Board for 2026

The following decisions were taken in relation to remuneration for 2026:

§Updates to the Executive Board and Supervisory Board remuneration

policies will be proposed;

§From 1 January 2026, the base salary of the EB members is proposed

to be increased by 5 percent for the CEO, 7 percent for both the CFO

and CRO, see '2026 Executive Board remuneration'. 50 percent of the

increase will be delivered in fixed shares, subject to a five-year

retention period. The proposed increase for the CEO is broadly in line

with the Dutch CLA and wider workforce increases.

§The SB fees will be increased in line with the proposed updated

Supervisory Board Remuneration Policy, subject to a positive binding

vote by the AGM on 14 April 2026, see '2026 Supervisory Board

remuneration'.


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Alignment of Executive Board remuneration to stakeholder expectations

The table below provides a non-limitative overview of the main stakeholders for EB remuneration.

Stakeholder alignment

Our people

Shareholders

Regulators

Our customers

Society at large

§The Executive Board

Remuneration Policy is

aligned with the

remuneration principles that

apply to all ING employees.

§Salaries for the EB are

reviewed in the context of

salary developments across

ING's wider workforce and

benchmark data from ING's

core peer group.

§EB members' variable

remuneration is determined

using a multi-step and

integrated process, which is

closely aligned to the

approach used to determine

variable remuneration for

the wider workforce.

§We communicate with our

employees through our

ongoing engagement with

the Works Council in the

Netherlands on EB

remuneration. In recent

years, this stakeholder group

has focused on ensuring EB

remuneration levels and

decisions are acceptable to

society at large.

§Remuneration outcomes

take into account

performance against

financial and non-financial

targets that are consistent

with ING's strategy.

§Variable remuneration for EB

members is awarded fully

into ING Group shares. The

shares are deferred.

§In recent years, shareholders

continuously expressed their

concerns about the low

variable remuneration and

low total remuneration levels

of EB members.

§Alignment of EB

performance targets and

variable remuneration serves

as an important driver of

ING’s strategic priorities and

long-term shareholder value

creation.

§Variable remuneration

outcomes reflect ex-ante

and ex-post risk

performance.

§Variable remuneration pay

structures are in accordance

with regulatory

requirements, including

deferral, malus and

clawback.

§Through a qualitative survey

conducted by a third-party

provider, we gathered and

listened to customer views

on a range of executive

compensation topics, which

helped inform our

Remuneration Policy and

decision-making.

§Total remuneration is

designed with appropriate

consideration of the views

and interest of customers

and clients, ensuring this is

represented in the Executive

Board Remuneration Policy

and decision-making.

§Through a qualitative survey

conducted by a third-party

provider, we gathered and

listened to customer views

on a range of executive

compensation topics, which

helped inform our

Remuneration Policy and

decision-making.

§In recent years, there has

been increased interest in

the way EB remuneration is

linked to environmental and

social objectives.

§Environmental and social

objectives within variable

remuneration for the EB

reflects ING's wider purpose

and strategy.

§Variable remuneration

includes measures to drive

our ambitions to ensure an

inclusive workforce.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	87

Executive Board remuneration

Executive Board Remuneration Policy

The EB Remuneration Policy presents the remuneration approach

designed to attract, motivate, and retain leaders. Retention is an

important goal since this contributes to long-term performance. In

addition, delivery of both financial and non-financial KPIs, including ESG

performance targets, contributes towards sustainable long-term value

creation for stakeholders.

The current EB Remuneration Policy was approved by shareholders at the

2024 AGM and became effective retroactively from 1 January 2024.

In 2025, ING engaged with its stakeholders in an open dialogue on

proposed changes to the EB and SB remuneration policies, and updates

are being put forward for 2026. These updated EB and SB remuneration

policies will be presented for shareholder approval at the 2026 AGM. For

more information on the updated policies, see the '2026 Executive Board

remuneration'.

The remuneration decisions for the EB are a result of the application of the

remuneration principles as included in the EB Remuneration Policy in

respect of 2025. A summary of the remuneration components under the

current policy for the EB is provided in the table on this page. The full

policy, including arrangements for recruitment and leaver provisions, is

published on ING.com/about-us/corporate-governance/remuneration.

Executive Board Remuneration Policy summary


Remuneration component		Operation

	Base salary	§Base salary is set to reflect the individual's role, responsibilities, and experience, and to reward ongoing contribution to the role. Base salary is fully paid out in cash.

	Variable remuneration	§In compliance with regulatory requirements, the maximum annual variable remuneration opportunity is capped at 20 percent of annual base salary. §Variable remuneration is delivered fully in ING Group shares, of which 40 percent upfront and 60 percent is deferred. The deferred portion vests in equal annual tranches over five years. The vested shares have a retention period of five years from date of grant with a minimum of 12 months post vest. §The amount of variable remuneration is based on performance as measured against agreed financial, non-financial and risk objectives. At least 50 percent of variable remuneration metrics must be based on non-financial targets.

	Benefits	§Benefits are offered if considered appropriate by the SB in the context of the executive’s role, specific individual circumstances and benefits offered to the wider workforce, and for comparable roles in ING’s peer group.

	Pension	§Participation in ING's general collective defined contribution (CDC) pension plan is aligned with all employees in the Netherlands. As with other Dutch CDC participants earning above the pensionable salary cap, EB members receive a monthly individual savings allowance to compensate for the lack of pension accrual.

Delivery of Executive Board variable remuneration

Illustrated below is the pay-out scheme of variable remuneration for EB members.



	Variable remuneration is awarded taking into consideration performance over the prior year.	100% of variable remuneration


Delivery fully in shares	Upfront shares are awarded and vest on the same date and have a five-year retention period.	40%
			60%

	Deferred shares are awarded on the same date but vest in five tranches. There is a holding period requirement of five years from the award date plus a minimum retention period of 12 months post vesting.	12%

		12%

		12%

		12%

		12%

Holdback	Unvested tranches are subject to holdback provision.

Clawback	Vested tranches remain subject to clawback provision. Clawback provision applies during the maximum limitation period as permitted by applicable law.

1The benchmark approach used for CFO and CRO functions is aligned to ING's EB Remuneration Policy and our principle to pay the CFO and CRO the same. This approach takes into account observations in the market, where most peer firms outside the financial services industry do not have a comparable CRO

function and the remit of the CRO in other peer firms is materially different from the responsibilities ING's CRO has as a member of the Executive Board. (Benchmark source data: Willis Towers Watson)


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Executive Board benchmark approach

ING competes for executive talent in a global marketplace, with many of

our key competitors based outside the Netherlands, predominantly in the

United Kingdom and Continental Europe. In line with the Dutch Banking

Code, we review the actual total direct compensation of EB members

against a peer group of Dutch and international organisations – in both the

financial services and general industry sectors – to ensure it remains

balanced and appropriately competitive. Our peer group includes Dutch

firms and other UK and European banks, recognising our broader

international footprint where we largely compete for talent. Market data

used in benchmarking is based on total direct compensation, which is the

total of fixed and variable remuneration, excluding benefits such as

pension and allowances.

The peer group is based on five guiding principles that reflect ING’s current

profile and is further explained in the Executive Board Remuneration

Policy. These principles are described in the table below:


Guiding principle	Short description
Size	ING acknowledges the importance of including companies that are broadly comparable in terms of size and complexity.
Governance framework	ING is subject to the Dutch (financial services) regulatory framework and operates within a Dutch stakeholder environment.
Geography	ING is a leading European universal bank with a global presence and is headquartered in the Netherlands.
Talent market	ING is increasingly experiencing a cross-pollination of talent across sectors/industries, not limited to traditional banking competitors.
Balancing	ING acknowledges the importance of not losing sight of relevant peer companies that do not match on the other criteria.

The peer group is aligned to ING in terms of size, business profile, and the

changing landscape in the markets in which ING competes for executive

talent (as defined by the peer group guiding principles).

The peer group comprises:


§ABN AMRO §Ahold Delhaize §ASR Nederland §ASML §Banco Santander §BBVA §BNP Paribas §Commerzbank §Crédit Agricole §Deutsche Bank	§Heineken §Intesa Sanpaolo §KBC §Lloyds Banking Group §NatWest §NN Group §Philips §Rabobank §Société Générale §UniCredit

In line with the requirements laid out in the Dutch Banking Code, the actual

earned total direct compensation of members of the EB under the

Executive Board Remuneration Policy should be below the market median

of the peer group. The calculation of pay positioning of the EB members

against the peer group is performed on this basis (i.e. actual fixed salary

plus actual variable remuneration). The latest available survey data shows

that the current actual total direct compensation earned by ING's EB

members remains well below the market median, even though ING's size,

complexity, and performance place the company between the median

and upper quartile levels of our peers as shown in the chart on the right.

The CEO is positioned 59 percent below the median on total compensation,

the CFO is positioned 37 percent below the median, and the CRO is

positioned 37 percent below the median on total compensation.1

As outlined in the letter from the Chairperson of the Supervisory Board

Remuneration Committee (SB RemCo), the further widening gap between

EB remuneration and that of our peers is the reason the SB concluded that

action is needed and is therefore proposing an updated EB Remuneration

Policy at the 2026 AGM.

The next two visuals show that ING is positioned between the median and

upper quartile based on market capitalisation (size and complexity) and

financial performance (Profit before Tax) relative to our core peer group,

while EB pay is around or below the market lower quartile.

ING's relative size & financial performance vs. peer group (€ bln)

g 1st Quantile g 2nd Quantile g 3rd Quantile g 4th Quantile ING (2025) Median

Source: Refinitiv / Thomson Reuters

1Market Capitalisation is averaged over one year (September 1, 2024 to September 1, 2025).

2Profit before Tax as per last reported financial year (as of 31 December 2024).

EB Actual total direct compensation vs. peer group (€ mln)

g 1st Quantile g 2nd Quantile g 3rd Quantile g 4th Quantile ING (2025) Median


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	89

Annual review of the Executive Board remuneration

The SB annually reviews and determines EB members' actual

remuneration, in accordance with the Executive Board Remuneration

Policy and advice from the Remuneration Committee of the SB.

The Remuneration Committee’s responsibilities include preparing and

advising the SB for decisions regarding the individual remuneration of

members of the EB. In performing its tasks, the Remuneration Committee

takes note of the views of individual EB members with regard to the

amount and structure of their own remuneration. Fixed remuneration

proposals for individual EB members are drawn up in accordance with the

Executive Board Remuneration Policy and cover the following aspects:

remuneration structure, external benchmark results based on an annual

review, validation of the EB peer group, the performance criteria used and,

if and when considered appropriate, stakeholder engagement and the pay

ratios within the company and its affiliated enterprises. In performing its

tasks, the Remuneration Committee works with the Risk Committee.

The EB variable remuneration proposals were determined based on a

scenario analysis performed against different performance standards and

payout levels – including threshold, target and maximum – and presented

to the SB for consideration. In conclusion, the proposed variable

remuneration awards for the EB members were considered fair,

appropriate, and in line with legislative requirements of maximum of 20

percent of base salary. The scenario analysis did not identify any issues or

new insights that would warrant further adjustments to the proposed

variable remuneration awards by the SB.

2025 Executive Board performance management and reward

process

The EB performance management and reward process includes a number

of key steps. This process serves as the foundation to determine the

variable remuneration for EB members.


1		Target-setting before the start of the year

2		Quarterly check-ins during the financial year

3		Mid-year review

4		Year-end review after the end of the financial year

5		Risk assessment after the end of the financial year

Performance measures and targets

At the start of each performance year, the SB approves performance

measures and targets to ensure alignment with strategic priorities and

support the delivery of ING’s strategy. The target areas cover:

§Financial performance target areas, including profit-based and return-

based targets; and

§Non-financial and risk performance target areas, including customer-

related factors (except the CRO), risk & regulatory matters, strategy,

and environment and social (sustainability) targets.

Each performance target area is weighted and when combined, all

weightings total 100 percent. The CEO is aligned fully to Group

performance, while for the CFO, it is a mix of both Group and functional

performance targets. The non-financial targets for the CRO are

predominantly based on performance targets that are linked to the

function and role.

The applicable non-financial performance targets are based on ING's

strategy, with customers and sustainability as the core pillars. The

performance targets for the EB members reflect ING's priorities for the

financial year, aiming to drive sustainable outcomes, including financial

returns that drive shareholder returns in both the short and longer term. In

addition, non-financial targets, including ESG-related targets, are taken

into account and contribute towards sustainable long-term value creation

for both ING and society. ING's remuneration approach is strongly linked to

a robust and transparent performance-management process, which aims

to reward sustainable performance.

The target areas, targets and weightings are included in the performance

target cards for each EB member (see table '2025 variable remuneration

outcome'). The performance target card consists of both quantitative- and

qualitative-based targets to achieve a balanced and holistic assessment.

The qualitative-based targets are assessed using a standard five-point

rating scale, which is the same as ING's Step Up Performance rating

approach used for the wider workforce. The overall outcome of the

performance target card assessment described above is the starting point

for determining the variable remuneration of the EB members.

Throughout the year, regular conversations take place between the SB and

EB members to review their performance. Progress against performance

measures is formally tracked and discussed at least twice a year in the

mid-year and year-end reviews. The Nomination and Corporate

Governance Committee takes an active role in assessing the performance

of individual EB members and informs both the Risk Committee and the

Remuneration Committee.

At the end of the year, the Risk Committee and Remuneration Committee

provide input and assess the performance of EB members to determine

the variable remuneration to be awarded. They jointly advise the SB on the

recommendations to obtain final approval of the awards.

There is strong alignment and cross-participation between the

Remuneration Committee, Risk Committee, Nomination and Corporate

Governance Committee and ESG Committee to support effective

performance and remuneration decision-making.

Managing risk and conduct (including holdback and clawback)

The integrated performance assessment process for determining variable

remuneration also takes into account financial and operational

performance, risk and compliance, and the behaviour and conduct of each

EB member. This is supported by a robust framework for considering risk

and conduct with potential adjustments to their variable remuneration

awards. This is in line with regulations and the wider workforce. It includes

the following elements:

1A holdback is the forfeiture of up to 100 percent of the awarded and unvested variable remuneration, and a clawback is an arrangement under which staff have to return ownership of up to 100 percent of the paid and/or vested variable remuneration.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	90

§Performance hurdles – EB members are only eligible for consideration

of their variable remuneration if both the performance hurdles are met.

This is in line with all employees who are eligible for discretionary

variable remuneration. For more information, see Step 2 of the

'Variable Remuneration Accrual Model'.

§Risk and regulatory adjustments – Performance against risk and

regulatory targets within the core performance target cards are made,

including an assessment of financial risk and non-financial risk targets

measured on an ex-ante basis. The targets and ranges are set at the

beginning of the financial year, taking into account ING’s risk appetite

statement framework. Performance against these risk and regulatory

targets may lead to a downward or upward adjustment in variable

remuneration.

§Additional risk adjustments – Further downward risk adjustments may

also be made to variable remuneration based on broader risk

management performance not within risk appetite, including additional

ex-ante risk performance that needs to be considered and/or ex-post

risk events that may lead to a financial or reputational impact on ING.

Finally, the Risk function assesses individual risk requirements that

apply to identified staff, including EB members, who are considered risk

takers, which can also lead to a downward adjustment in variable

remuneration, also known as a risk modifier. In the most serious of

incidents, additional risk adjustments in the form of holdbacks or

clawbacks1 can also impact individual variable remuneration in line

with regulatory requirements.

The CRO is responsible for recommending any risk adjustments to variable

remuneration awards for the CEO and CFO. The Risk Committee is

responsible for recommending this for the CRO. The SB, based on the

advice of the Remuneration Committee and Risk Committee, decides on

any risk adjustments to variable remuneration (potentially to zero) for EB

members. As a final step in the process, and only in exceptional

circumstances, the SB may exercise its discretion to adjust the variable

remuneration of EB members, either upwards or downwards.

2025 Executive Board performance and remuneration

This section provides more details on the financial and non-financial performance of the EB members in 2025. Key financial and non-financial achievements against the 2025 predefined target areas are summarised in the table for

each of the EB members. The SB has discussed and approved this. The individual performance against non-financial performance targets for each EB member is further summarised in a separate overview per board member in the

following pages.


2025 variable remuneration outcomes
		Target – Minimum	Target	Target – Maximum	Performance	Steven van Rijswijk (CEO)			Tanate Phutrakul (CFO)			Ljiljana Čortan (CRO)
		Target – Minimum	Target	Target – Maximum	Performance	Weighting	Assessment	Outcome	Weighting	Assessment	Outcome	Weighting	Assessment	Outcome
Financial	Profit before tax	6,664	8,330	9,997	9,148	16.7%	90%	15%	16.7%	90%	15%	8.3%	90%	7%
	Return on equity	9.7%	12.1%	14.5%	13.2%	16.7%	89%	15%	16.7%	89%	15%	8.3%	89%	7%
	Operational expenses	13,306	12,672	12,038	12,583	16.7%	83%	14%	16.7%	83%	14%	8.3%	83%	7%
Non-financial	Customer	Performance against non-financial measures are organised around these target areas. Please see the following pages for more details on the non-financial performance of each Executive Board member.				7.5%	86%	6%	5.0%	86%	4%	NA	NA	NA
	Risk & Regulatory					15.0%	100%	15%	17.5%	100%	18%	45.0%	92%	41%
	Strategy					12.5%	80%	10%	12.5%	100%	13%	15.0%	83%	13%
	Environment					10.0%	95%	10%	10.0%	80%	8%	10.0%	90%	9%
	Social					5.0%	87%	4%	5.0%	80%	4%	5.0%	88%	4%
Total						100%		89%	100%		90%	100%		89%
Final 2025 variable remuneration outcomes								89%			90%			89%
Payout of 20 percent variable remuneration cap (16 percent is at target variable remuneration)								18%			18%			18%

*Due to rounding, percentages presented in the table may not add up precisely to the total percentages provided.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	91

Steven van Rijswijk

CEO

Customer

Risk & Regulatory

Strategy

Environment

Social

§Increase number of mobile primary

customers as this leads to deeper

relationships, greater customer

satisfaction, and ultimately customers

choosing ING for more of their financial

needs

§Increase customer satisfaction of Retail

and Wholesale customers by increasing

NPS

§Manage financial risk within risk appetite,

with a specific focus on the revision of the

use of internal models

§Manage non-financial risk within risk

appetite with a specific focus on the IT risk

management

§Maintain operational effectiveness of KYC

§Increase digitisation and straight-through-

processing (STP) rate of customer

processes

§Increase sustainable volume mobilised

§Support the transition of the most carbon-

intensive sectors in Wholesale Banking

towards a better carbon performance, in

line with our 2030 decarbonisation target

§Strengthen organisational health with a

focus on five priority areas:

–Strategic clarity

–Role clarity

–Customer orientation

–Data-driven decision-making

–Talent development

§Increase gender balance in ING's leadership

cadre

§In 2025, as part of the mobile-first

ambition, the mobile primary customer

base increased by over one million to 15.4

million, in line with the target.

§In 2025, ING ranked number one in five of

our Retail markets on NPS: Australia,

Poland, Germany, Romania and Spain,

which was slightly below target. ING ranks

in the top three in four markets.

§In Wholesale Banking the NPS score

exceeded target, as it increased to 77, up

from 74 in 2024, with clients recognising

ING's sector expertise, global reach and

local experts.

§Despite the dynamic geopolitical

environment credit, financial and non-

financial risk were managed well within

ING’s risk appetite.

§The delivery of credit risk models in 2025

was in line with the defined multi-year plan

for redevelopment of credit models.

§Solid development of technology resilience

capabilities including the delivery of

enhancements in measuring and reporting

on IT risk.

§The bank’s KYC activities maintained a

sustainable level of Operational

Effectiveness during 2025 with enhanced

oversight and challenge from the second

line of defence.

§In 2025 the digitalisation of key customer

journeys continued in line with target to

create the foundation for providing a

superior customer experience. This is

measured by the percentage of customer

journeys that is handled without manual

intervention, which went up from 77.2%

year-end 2024 to 81.8% year-end 2025.

§Through expanded and improved digital

services, customer friction was further

reduced and self service options increased,

including GenAI chatbots. In 2025, the

number of inbound contacts to contact

centres was further reduced, to an overall

decline of 23 percent (versus 2021).

§Building on the targeted AI approach in five

priority domains – contact centres, Know

Your Customer (KYC), hyper-

personalisation in marketing, Wholesale

Banking Lending, and software engineering

– solutions were further scaled and new

opportunities explored.

§Increased the WB financing for clients in

order to allow them to pursue their

sustainability objectives, as reflected in the

volume mobilised methodology. In 2025

€166 billion of volumes mobilised was

recorded compared to €130 billion in 2024.

§In 2025, ING became the first global

systemically important bank to receive

1.5°C-aligned science-based target

validation from the Science Based Targets

initiative (SBTi) in relation to Terra.

§ING uses the 'Terra' approach to manage

climate-related risks within the most

carbon-intensive parts of our lending

portfolio ultimately to converge towards

net-zero by 2050. The transition of the

most carbon-intensive Wholesale Banking

sectors was measured using eight sector

indicators. Overall, we demonstrated good

progress, and two of the most carbon-

intensive sectors showed a significant

advance.

§In 2025, two OHI surveys were held and

from 80 percent of our workforce feedback

was received. There is sustained

engagement among ING's employees and

feedback showed that employees continue

to value and appreciate their colleagues,

the ability to work hybrid, and the

opportunities that support their wellbeing.

§Female representation in senior

management exceeded expectations with

an increase from 32% at the end of 2024

to 35% at the end of 2025 with progress in

nearly all domains.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	92

Tanate Phutrakul

CFO

Customer

Risk & Regulatory

Strategy

Environment

Social

§Increase number of mobile primary

customers as this leads to deeper

relationships, greater customer

satisfaction, and ultimately customers

choosing ING for more of their financial

needs

§Increase customer satisfaction of Retail

and Wholesale customers by increasing

NPS

§Manage financial risk within risk appetite

with a specific focus on the revision of the

use of internal models

§Manage non-financial risk within risk

appetite with a specific focus on the IT risk

management

§Increase efficiency of finance processes

while maintaining the effectiveness of

controls

§Continuous refinement of CSRD disclosures

§Strengthen organisational health with a

focus on five priority areas:

–Strategic clarity

–Role clarity

–Customer orientation

–Data-driven decision-making

–Talent development

§Increase gender balance in ING's leadership

cadre

§In 2025, as part of the mobile-first

ambition, the mobile primary customer

base increased by over one million to 15.4

million, in line with the target.

§In 2025, ING ranked number one in five of

our Retail markets: Australia, Poland,

Germany, Romania and Spain, which was

slightly below target. ING ranks in the top

three in four markets.

§In Wholesale Banking the NPS score

exceeded target, as it increased to 77, up

from 74 in 2024, with clients recognising

ING's sector expertise, global reach and

local experts.

§Despite the dynamic geopolitical

environment credit, financial and non-

financial risk were managed well within

ING’s risk appetite.

§The delivery of credit risk models in 2025

was in line with the defined multi-year plan

for redevelopment of credit models.

§Solid development of technology resilience

capabilities including the delivery of

enhancements in measuring and reporting

on IT risk.

§Increased effectiveness of the financial

reporting control environment while

facilitating accelerated closing timelines,

with continued focus on efficiency across

Finance and IT processes.

§Continued improvement of the governance

and internal controls supporting the

preparation of the 2025 sustainability

disclosures, structurally embedding the

related control standard in ING’s overall risk

governance.

§Refined environmental disclosures to

enhance readability, reflecting stakeholder

feedback on 2024 reporting.

§In 2025, two OHI surveys were held and

from 80 percent of our workforce feedback

was received. There is sustained

engagement among ING's employees and

feedback showed that employees continue

to value and appreciate their colleagues,

the ability to work hybrid, and the

opportunities that support their wellbeing.

§Female representation in senior

management exceeded expectations with

an increase from 32% at the end of 2024

to 35% at the end of 2025 with progress in

nearly all domains.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	93

Ljiljana Čortan

CRO

Risk & Regulatory

Strategy

Environment

Social

§Manage financial risk within risk appetite

with a specific focus on the revision of the

use of internal models

§Manage non-financial risk within risk

appetite with a specific focus on the IT risk

management

§Maintain operational effectiveness of KYC

§Increase efficiency of risk processes while

maintaining the effectiveness of controls

§Continuous refinement of ESG risk

assessment methodology

§Strengthen organisational health with a

focus on five priority areas:

–Strategic clarity

–Role clarity

–Customer orientation

–Data-driven decision-making

–Talent development

§Increase gender balance in ING's leadership

cadre

§Despite the dynamic geopolitical

environment credit, financial and non-

financial risk were managed well within

ING’s risk appetite.

§The delivery of credit risk models in 2025

was in line with the defined multi-year

plan for redevelopment of credit models.

§Solid development of technology

resilience capabilities including the

delivery of enhancements in measuring

and reporting on IT risk.

§The bank’s KYC activities maintained a

sustainable level of Operational

Effectiveness during 2025 with enhanced

oversight and challenge from the second

line of defence.

§Increased the efficiency of non-financial

risk control processes in line with

expectation while maintaining the

effectiveness.

§Strengthened governance to scale AI

responsibly by establishing a dedicated

central AI Risk Committee to oversee

emerging risks in new domains such as

voicebots and agentic AI capabilities.

§Contributed to the digitalisation of lending

processes by delivering on the defined

automation milestones in risk processes of

the retail and business banking lending

journeys beyond target.

§Strengthened ING's climate stress-testing

framework to assess the impact of physical

and transition risks on corporate and

mortgage exposures under multiple

climate scenarios, using both short-term

and long-term methodologies.

§Launched an enhanced ESG risk

assessment platform that integrates

environmental, social, and governance

factors, replacing the previous ESR

framework.

§In 2025, two OHI surveys were held and

from 80 percent of our workforce feedback

was received. There is sustained

engagement among ING's employees and

feedback showed that employees continue

to value and appreciate their colleagues,

the ability to work hybrid, and the

opportunities that support their wellbeing.

§Female representation in senior

management exceeded expectations with

an increase from 32% at the end of 2024

to 35% at the end of 2025 with progress in

nearly all domains.

1The IRRF consists of the most important regulatory requirements with respect to remuneration, to which all remuneration policies of majority-owned entities have to adhere. Furthermore, it consists of our general remuneration principles that apply to all staff globally working under the responsibility of ING.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	94

2025 variable remuneration and total direct compensation

outcomes

In 2025, we continued to deliver strong results and executed consistently

on our strategy to accelerate growth, increase impact and deliver value for

all stakeholders, despite ongoing macroeconomic and geopolitical

uncertainty. Our net result of €6.3 billion, corresponding with a return on

equity of 13.2 percent reflects solid commercial momentum, as we did

more business with more customers. Total income rose to €23 billion,

driven by a 15 percent increase in fee income and substantial growth in

lending and deposits. Operating expenses increased year-on-year in line

with guidance, reflecting continued investment in the business, while risk

costs remained below the through-the-cycle average.

The number of mobile primary customers increased by over one million,

bringing us to 15.4 million out of nearly 41 million total customers. Net

core lending has risen by €56.9 billion, of which 38.6 billion in Retail, mainly

driven by €28.5 billion of mortgage growth and €6.6 billion in Business

Banking, as we remain committed to supporting small and mid-sized

enterprises across our markets. In Wholesale Banking, lending grew by

€18.3 billion following sustained demand in corporate lending and Working

Capital Solutions. In Retail, we maintained our number one NPS position in

five out of 10 retail markets, while in Wholesale Banking, we achieved an

NPS of 77 in 2025, up from 74 in 2024.

Sustainability remains a strategic, business and commercial priority for

ING. Sustainable volume mobilised increased to €166 billion for the full

year, a 28 percent increase from 2024, demonstrating strong progress

towards our long-term ambitions. We continued to support clients in their

sustainability transitions across sectors and geographies, while further

embedding sustainability into our core business activities.

Financial and capital results in 2025 were again well above the

performance hurdles. Following this performance, the SB has conducted a

thorough and balanced assessment. Based on the outcomes of this and

their overall achievements, the SB concluded that the EB members

delivered strong results in 2025.

Furthermore, the SB considered whether any discretionary adjustment

was required, and determined that both the financial and non-financial

results speak for themselves in the current environment. The SB also

considered the behaviour of the EB members and saw no reason to apply

any discretionary adjustments.

In the final step, the SB took into account the feedback from the CRO and

Risk Committee on risk and compliance matters. Here, there was no

reason to apply any individual additional risk adjustments in accordance

with ING's Remuneration Regulations Framework (IRRF)1.

Following this performance assessment process, the resulting variable

remuneration award for Steven van Rijswijk is €341,666; for Tanate

Phutrakul €242,193; and for Ljiljana Čortan €240,006. For the CEO, this

equates to a variable remuneration award at 18 percent out of the

maximum 20 percent cap. For the CFO, it represents 18 percent out of the

maximum 20 percent cap, and for the CRO, it represents 18 percent out of

the maximum 20 percent cap (see table '2025 variable remuneration

outcomes').

Certain components of variable remuneration are not recognised in the

statement of profit or loss directly, but are allocated over the vesting

period of the award. As recognised in the profit or loss statement of 2025,

the expenses for each EB member, relating to their role on the EB, amount

to €2.8 million for the CEO, €3.3 million for the CFO, and €2.1 million for the

CRO. These amounts include deferred elements from previous years, paid

out in 2025.

1ING indemnifies the members of the EB against direct financial losses in connection with claims from third parties filed, or threatened to be filed, against them by virtue of their service as a member of the EB, as far as permitted by law, on the conditions laid down in the Articles of Association and their commission

contract. ING has taken out liability insurance for the members of the EB.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	95

The following tables (i.e. total direct compensation, pension costs and benefits) show the remuneration awarded to individual Executive Board members, with respect to the performance years 2025 and 2024.1 All EB remuneration is

paid directly by ING.


2025 remuneration outcomes
		1. Fixed remuneration			2. Variable remuneration		3. Extraordinary items	4. Pension benefits	5. Total remuneration	6. Proportion of fixed and variable remuneration
Amounts in euros (rounded figures)		Base salary	Fees	Other benefits	One-year variable1	Multi-year variable	3. Extraordinary items	4. Pension benefits	5. Total remuneration	6. Proportion of fixed and variable remuneration
Steven van Rijswijk (CEO)	2025	1,921,200	—	534,500	341,700	—	—	27,700	2,825,100	87.9% / 12.1%
	2024	1,847,300	—	507,200	311,800	—	—	27,900	2,694,200	88.4% / 11.6%

Tanate Phutrakul (CFO)	2025	1,346,800	—	377,300	242,200	—	1,346,800 2	27,700	3,340,700	92.8% / 7.2%
	2024	1,270,500	—	336,100	219,700	—	—	27,900	1,854,300	88.2% / 11.8%

Ljiljana Čortan (CRO)	2025	1,346,800	—	521,900	240,000	—	—	27,700	2,136,400	88.8% / 11.2%
	2024	1,270,500	—	495,000	223,600	—	—	27,900	2,017,100	88.9% / 11.1%

1The variable remuneration percentages over 2025 for the EB members are as follows: CEO 18%, CFO 18% and CRO 18%. Thus the ratio between base salary and total direct compensation is as follows: CEO 84.9%, CFO 84.8% and CRO 84.9%.

2In accordance with the Executive Board Remuneration Policy and with due observance of applicable legal requirements, a severance payment equal to one year's base salary has been granted.

Benefits

The individual members of the EB receive benefits. The table below shows the breakdown of all benefits paid in 2025.


Breakdown of benefits paid in 2025
Amounts in euros (rounded figures)	Steven van Rijswijk (CEO)	Tanate Phutrakul (CFO)	Ljiljana Čortan (CRO)
Contribution individual savings plans	67,200	47,100	47,100
Individual savings allowance	395,800	268,300	268,300
Travel and accident insurance	16,400	16,400	16,400
Other benefits1	55,100	45,400	190,000
Total	534,500	377,300	521,900

1This includes expatriate allowances (such as housing, school/tuition fees and international health insurances, if applicable); banking and insurance benefits from ING (on the same terms as for other

employees of ING in the Netherlands); tax and financial planning services to ensure compliance with the relevant legislative requirements, and the use of a company car or driver service.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	96

Deferred shares, awarded as part of the variable remuneration, are shares conditionally granted subject to a tiered vesting over a period of five years, with the ultimate value of each deferred share based on ING’s share price on the vesting

date. This is conditional on there being no holdback. The main condition for vesting is that these shares require continued employment through vesting date. The table below details all share-based remuneration for the EB members.


Share-based remuneration for Executive Board members
	The main conditions of share award plans					Information regarding the reported financial year
						Opening balance			During the year		Closing balance
	1	2	3	4	5	6A	6B	6C	7	8	9	10	11A	11B
	Specification of plan1	Performance period	Granting/ offering date	Vesting date	End of retention period	Shares held at the beginning of the year	Shares subject to retention at the beginning of the year	Shares sold- to-cover2	Shares granted/ offered	Shares vested	Shares subject to a performance condition	Shares granted/ offered unvested at YE	Shares subject to a retention period	Vested shares sold-to-cover2
Steven van Rijswijk (CEO)	LSPP Upfront Shares	2019	11/05/2020	11/05/2020	11/05/2025	-	4,193	3,350	-	-	-	-	-	-
	LSPP Deferred Shares Idnt	2019	11/05/2020	11/05/2021	11/05/2025	-	1,241	1,022	-	-	-	-	-	-
	LSPP Deferred Shares Idnt	2019	11/05/2020	11/05/2022	11/05/2025	-	1,224	1,039	-	-	-	-	-	-
	LSPP Deferred Shares Idnt	2019	11/05/2020	11/05/2023	11/05/2025	-	1,202	1,061	-	-	-	-	-	-
	LSPP Deferred Shares Idnt	2019	11/05/2020	11/05/2024	11/05/2025	-	1,174	1,089	-	-	-	-	-	-
	LSPP Deferred Shares Idnt	2019	11/05/2020	11/05/2025	11/05/2026	2,263	-	-	-	2,263	-	-	1,174	1,089
	LSPP Upfront Shares	2021	09/05/2022	09/05/2022	09/05/2027	-	5,108	4,082	-	-	-	-	5,108	-
	LSPP Deferred Shares Idnt	2021	09/05/2022	11/05/2023	09/05/2027	-	1,512	1,245	-	-	-	-	1,512	-
	LSPP Deferred Shares Idnt	2021	09/05/2022	11/05/2024	09/05/2027	-	1,491	1,266	-	-	-	-	1,491	-
	LSPP Deferred Shares Idnt	2021	09/05/2022	11/05/2025	09/05/2027	2,757	-	-	-	2,757	-	-	1,464	1,293
	LSPP Deferred Shares Idnt	2021	09/05/2022	11/05/2026	11/05/2027	2,757	-	-	-	-	-	2,757	-	-
	LSPP Deferred Shares Idnt	2021	09/05/2022	11/05/2027	11/05/2028	2,757	-	-	-	-	-	2,757	-	-
	LSPP Upfront Shares	2022	11/05/2023	11/05/2023	11/05/2028	-	4,846	3,872	-	-	-	-	4,846	-
	LSPP Deferred Shares Idnt	2022	11/05/2023	11/05/2024	11/05/2028	-	1,434	1,181	-	-	-	-	1,434	-
	LSPP Deferred Shares Idnt	2022	11/05/2023	11/05/2025	11/05/2028	2,615	-	-	-	2,615	-	-	1,415	1,200
	LSPP Deferred Shares Idnt	2022	11/05/2023	11/05/2026	11/05/2028	2,615	-	-	-	-	-	2,615	-	-
	LSPP Deferred Shares Idnt	2022	11/05/2023	11/05/2027	11/05/2028	2,615	-	-	-	-	-	2,615	-	-
	LSPP Deferred Shares Idnt	2022	11/05/2023	11/05/2028	11/05/2029	2,618	-	-	-	-	-	2,618	-	-
	LSPP Upfront Shares	2023	10/05/2024	10/05/2024	10/05/2029	-	5,415	4,327	-	-	-	-	5,415	-
	LSPP Deferred Shares Idnt	2023	10/05/2024	11/05/2025	10/05/2029	2,922	-	-	-	2,922	-	-	1,602	1,320
	LSPP Deferred Shares Idnt	2023	10/05/2024	11/05/2026	10/05/2029	2,922	-	-	-	-	-	2,922	-	-
	LSPP Deferred Shares Idnt	2023	10/05/2024	11/05/2027	10/05/2029	2,922	-	-	-	-	-	2,922	-	-
	LSPP Deferred Shares Idnt	2023	10/05/2024	11/05/2028	11/05/2029	2,922	-	-	-	-	-	2,922	-	-
	LSPP Deferred Shares Idnt	2023	10/05/2024	11/05/2029	11/05/2030	2,925	-	-	-	-	-	2,925	-	-
	LSPP Upfront Shares	2024	09/05/2025	09/05/2025	09/05/2030	-	-	-	7,965	7,965	-	-	4,427	3,538
	LSPP Deferred Shares Idnt	2024	09/05/2025	11/05/2026	09/05/2030	-	-	-	2,389	-	-	2,389	-	-
	LSPP Deferred Shares Idnt	2024	09/05/2025	11/05/2027	09/05/2030	-	-	-	2,389	-	-	2,389	-	-
	LSPP Deferred Shares Idnt	2024	09/05/2025	11/05/2028	09/05/2030	-	-	-	2,389	-	-	2,389	-	-
	LSPP Deferred Shares Idnt	2024	09/05/2025	11/05/2029	11/05/2030	-	-	-	2,389	-	-	2,389	-	-
	LSPP Deferred Shares Idnt	2024	09/05/2025	11/05/2030	11/05/2031	-	-	-	2,391	-	-	2,391	-	-
Total						35,610	28,840	23,534	19,912	18,522	-	37,000	29,888	8,440


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	97


Share-based remuneration for Executive Board members – continued
	The main conditions of share award plans					Information regarding the reported financial year
						Opening balance			During the year		Closing balance
	1	2	3	4	5	6A	6B	6C	7	8	9	10	11A	11B
	Specification of plan1	Performance period	Granting/ offering date	Vesting date	End of retention period	Shares held at the beginning of the year	Shares subject to retention at the beginning of the year	Shares sold- to-cover2	Shares granted/ offered	Shares vested	Shares subject to a performance condition	Shares granted/ offered and unvested at year-end	Shares subject to a retention period	Vested shares sold-to-cover2
Tanate Phutrakul (CFO)	LSPP Deferred Units Idnt (Equity settled)	2017	27/03/2018	27/03/2024	NULL	-	200	201	-	-	-	-	-	-
	LSPP Deferred Shares Idnt	2018	27/03/2019	27/03/2024	27/03/2025	-	117	110	-	-	-	-	-	-
	LSPP Upfront Shares	2019	11/05/2020	11/05/2020	11/05/2025	-	3,934	3,144	-	-	-	-	-	-
	LSPP Deferred Shares Idnt	2019	11/05/2020	11/05/2021	11/05/2025	-	1,164	959	-	-	-	-	-	-
	LSPP Deferred Shares Idnt	2019	11/05/2020	11/05/2022	11/05/2025	-	1,148	975	-	-	-	-	-	-
	LSPP Deferred Shares Idnt	2019	11/05/2020	11/05/2023	11/05/2025	-	1,127	996	-	-	-	-	-	-
	LSPP Deferred Shares Idnt	2019	11/05/2020	11/05/2024	11/05/2025	-	1,102	1,021	-	-	-	-	-	-
	LSPP Deferred Shares Idnt	2019	11/05/2020	11/05/2025	11/05/2026	2,124	-	-	-	2,124	-	-	1,102	1,022
	LSPP Upfront Shares	2021	09/05/2022	09/05/2022	09/05/2027	-	3,700	2,956	-	-	-	-	3,700	-
	LSPP Deferred Shares Idnt	2021	09/05/2022	11/05/2023	09/05/2027	-	1,095	902	-	-	-	-	1,095	-
	LSPP Deferred Shares Idnt	2021	09/05/2022	11/05/2024	09/05/2027	-	1,080	917	-	-	-	-	1,080	-
	LSPP Deferred Shares Idnt	2021	09/05/2022	11/05/2025	09/05/2027	1,997	-	-	-	1,997	-	-	1,061	936
	LSPP Deferred Shares Idnt	2021	09/05/2022	11/05/2026	11/05/2027	1,997	-	-	-	-	-	1,997	-	-
	LSPP Deferred Shares Idnt	2021	09/05/2022	11/05/2027	11/05/2028	1,997	-	-	-	-	-	1,997	-	-
	LSPP Upfront Shares	2022	11/05/2023	11/05/2023	11/05/2028	-	3,351	2,678	-	-	-	-	3,351	-
	LSPP Deferred Shares Idnt	2022	11/05/2023	11/05/2024	11/05/2028	-	991	817	-	-	-	-	991	-
	LSPP Deferred Shares Idnt	2022	11/05/2023	11/05/2025	11/05/2028	1,808	-	-	-	1,808	-	-	978	830
	LSPP Deferred Shares Idnt	2022	11/05/2023	11/05/2026	11/05/2028	1,808	-	-	-	-	-	1,808	-	-
	LSPP Deferred Shares Idnt	2022	11/05/2023	11/05/2027	11/05/2028	1,808	-	-	-	-	-	1,808	-	-
	LSPP Deferred Shares Idnt	2022	11/05/2023	11/05/2028	11/05/2029	1,811	-	-	-	-	-	1,811	-	-
	LSPP Upfront Shares	2023	10/05/2024	10/05/2024	10/05/2029	-	4,051	3,237	-	-	-	-	4,051	-
	LSPP Deferred Shares Idnt	2023	10/05/2024	11/05/2025	10/05/2029	2,186	-	-	-	2,186	-	-	1,198	988
	LSPP Deferred Shares Idnt	2023	10/05/2024	11/05/2026	10/05/2029	2,186	-	-	-	-	-	2,186	-	-
	LSPP Deferred Shares Idnt	2023	10/05/2024	11/05/2027	10/05/2029	2,186	-	-	-	-	-	2,186	-	-
	LSPP Deferred Shares Idnt	2023	10/05/2024	11/05/2028	11/05/2029	2,186	-	-	-	-	-	2,186	-	-
	LSPP Deferred Shares Idnt	2023	10/05/2024	11/05/2029	11/05/2030	2,188	-	-	-	-	-	2,188	-	-
	LSPP Upfront Shares	2024	09/05/2025	09/05/2025	09/05/2030	-	-	-	5,612	5,612	-	-	3,119	2,493
	LSPP Deferred Shares Idnt	2024	09/05/2025	11/05/2026	09/05/2030	-	-	-	1,683	-	-	1,683	-	-
	LSPP Deferred Shares Idnt	2024	09/05/2025	11/05/2027	09/05/2030	-	-	-	1,683	-	-	1,683	-	-
	LSPP Deferred Shares Idnt	2024	09/05/2025	11/05/2028	09/05/2030	-	-	-	1,683	-	-	1,683	-	-
	LSPP Deferred Shares Idnt	2024	09/05/2025	11/05/2029	11/05/2030	-	-	-	1,683	-	-	1,683	-	-
	LSPP Deferred Shares Idnt	2024	09/05/2025	11/05/2030	11/05/2031	-	-	-	1,686	-	-	1,686	-	-
Total						26,282	23,060	18,913	14,030	13,727	-	26,585	21,726	6,269


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	98


Share-based remuneration for Executive Board members – continued
	The main conditions of share award plans					Information regarding the reported financial year
						Opening Balance			During the year		Closing balance
	1	2	3	4	5	6A	6B	6C	7	8	9	10	11A	11B
	Specification of plan1	Performance period	Granting/ offering date	Vesting Date	End of retention period	Shares held at the beginning of the year	Shares subject to retention at the beginning of the year	Shares sold- to-cover2	Shares granted/ offered	Shares vested	Shares subject to a performance condition	Shares granted/ offered and unvested at year-end	Shares subject to a retention period	Vested shares sold-to-cover2
Ljiljana Čortan (CRO)	LSPP Upfront Shares	2021	09/05/2022	09/05/2022	09/05/2027	-	4,478	1,936	-	-	-	-	4,478	-
	LSPP Deferred Shares Idnt	2021	09/05/2022	11/05/2023	09/05/2027	-	1,331	593	-	-	-	-	1,331	-
	LSPP Deferred Shares Idnt	2021	09/05/2022	11/05/2024	09/05/2027	-	1,319	605	-	-	-	-	1,319	-
	LSPP Deferred Shares Idnt	2021	09/05/2022	11/05/2025	09/05/2027	1,924	-	-	-	1,924	-	-	1,302	622
	LSPP Deferred Shares Idnt	2021	09/05/2022	11/05/2026	11/05/2027	1,924	-	-	-	-	-	1,924	-	-
	LSPP Deferred Shares Idnt	2021	09/05/2022	11/05/2027	11/05/2028	1,925	-	-	-	-	-	1,925	-	-
	LSPP Upfront Shares	2022	11/05/2023	11/05/2023	11/05/2028	-	4,419	1,911	-	-	-	-	4,419	-
	LSPP Deferred Shares Idnt	2022	11/05/2023	11/05/2024	11/05/2028	-	1,313	586	-	-	-	-	1,313	-
	LSPP Deferred Shares Idnt	2022	11/05/2023	11/05/2025	11/05/2028	1,899	-	-	-	1,899	-	-	1,301	598
	LSPP Deferred Shares Idnt	2022	11/05/2023	11/05/2026	11/05/2028	1,899	-	-	-	-	-	1,899	-	-
	LSPP Deferred Shares Idnt	2022	11/05/2023	11/05/2027	11/05/2028	1,899	-	-	-	-	-	1,899	-	-
	LSPP Deferred Shares Idnt	2022	11/05/2023	11/05/2028	11/05/2029	1,899	-	-	-	-	-	1,899	-	-
	LSPP Upfront Shares	2023	10/05/2024	10/05/2024	10/05/2029	-	4,724	2,042	-	-	-	-	4,724	-
	LSPP Deferred Shares Idnt	2023	10/05/2024	11/05/2025	10/05/2029	2,029	-	-	-	2,029	-	-	1,403	626
	LSPP Deferred Shares Idnt	2023	10/05/2024	11/05/2026	10/05/2029	2,029	-	-	-	-	-	2,029	-	-
	LSPP Deferred Shares Idnt	2023	10/05/2024	11/05/2027	10/05/2029	2,029	-	-	-	-	-	2,029	-	-
	LSPP Deferred Shares Idnt	2023	10/05/2024	11/05/2028	11/05/2029	2,029	-	-	-	-	-	2,029	-	-
	LSPP Deferred Shares Idnt	2023	10/05/2024	11/05/2029	11/05/2030	2,033	-	-	-	-	-	2,033	-	-
	LSPP Upfront Shares	2024	09/05/2025	09/05/2025	09/05/2030	-	-	-	5,713	5,713	-	-	3,989	1,724
	LSPP Deferred Shares Idnt	2024	09/05/2025	11/05/2026	09/05/2030	-	-	-	1,713	-	-	1,713	-	-
	LSPP Deferred Shares Idnt	2024	09/05/2025	11/05/2027	09/05/2030	-	-	-	1,713	-	-	1,713	-	-
	LSPP Deferred Shares Idnt	2024	09/05/2025	11/05/2028	09/05/2030	-	-	-	1,713	-	-	1,713	-	-
	LSPP Deferred Shares Idnt	2024	09/05/2025	11/05/2029	11/05/2030	-	-	-	1,713	-	-	1,713	-	-
	LSPP Deferred Shares Idnt	2024	09/05/2025	11/05/2030	11/05/2030	-	-	-	1,717	-	-	1,717	-	-
Total						23,518	17,584	7,673	14,282	11,565	-	26,235	25,579	3,570

1All Executive Board members participate in the ING Group Long-term Sustainable Performance Plan (LSPP) and receive their shares under its plan rules.

2These refer to the number of shares sold at the vesting date to cover the estimated tax liabilities on the vested awards.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	99

Loans and advances to Executive Board members

EB members may obtain banking and insurance services from ING Group

and its subsidiaries in the ordinary course of their business and on terms

that are customary in the sector. The EB members do not receive

privileged financial services. On 31 December 2025, there were no loans or

advances outstanding to the EB members.

ING shares held by Executive Board members

EB members are encouraged to hold ING shares as a long-term investment

to maintain alignment with ING. The table below shows an overview of the

shares held by members of the EB on 31 December 2025 and 2024.


ING shares held by Executive Board members
Numbers of shares	2025	2024
Steven van Rijswijk (CEO)	111,990	101,908
Tanate Phutrakul (CFO)	40,618	33,160
Ljiljana Čortan (CRO)	25,579	17,584

Internal ratio

In line with the Dutch Corporate Governance Code, ING calculates the

internal ratio of the remuneration for the CEO compared to the average

remuneration of all ING staff. Using the CEO's total remuneration (i.e., the

total of fixed and variable remuneration, including benefits such as

pension and allowances) compared to the average remuneration for all

ING staff, the ratio in 2025 was 1:24. The ratio is the same as disclosed last

year. It declined initially and has since remained unchanged for the past

three years, mainly because the CEO’s average remuneration has

increased in line with the average remuneration increases of ING staff.

CEO pay ratio

ING is also required to disclose the annual total remuneration ratio based

on the European Sustainability Reporting Standards (ESRS), which deviates

from the internal ratio.

Furthermore, we calculated the average ratio of total remuneration for the

CFO and CRO compared to all ING staff. On that basis, the average ratio in

2025 for the CFO and CRO was 1:18, which is comparable to that of 2024.

Remuneration versus company performance and average

employee remuneration

The table on the next page shows the development of directors’

remuneration (EB and SB members), company performance, and the

average remuneration of an ING employee. This is carried out by showing

the development of the remuneration for EB and SB members over the

past five years presented in percentages. This table comes from the draft

(non-binding) 'Guidelines on the standardised presentation of the

remuneration report' from the European Commission.

To maintain the Supervisory Board's independent role, its remuneration is

not linked to company performance metrics.

The relative performance of the company is presented on three different

metrics over the past five years. The metrics consist of:

§Mobile primary customer;

§Profit before tax for ING Group; and

§Return on equity based on IFRS-EU equity.

Finally, we present the development of the remuneration on average (per

employee). For this number, we use the same data as for the internal ratio.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	100


Development of directors’ remuneration, company performance and employee remuneration ¹
Amount in thousands of euros unless otherwise stated	FY 2025	FY 2025 vs FY 2024		FY 2024 vs FY 2023		FY 2023 vs FY 2022		FY 2022 vs FY 2021		FY 2021 vs FY 2020
Directors' remuneration (Executive Board) 2, 3, 4, 5
Steven van Rijswijk (CEO)	2,263	104	4.8%	83	4.0%	23	1.1%	-24	-1.2%	578	38.6%
Tanate Phutrakul (CFO)	1,589	99	6.6%	44	3.0%	33	2.3%	-27	-1.9%	218	17.9%
Ljiljana Čortan (CRO)	1,587	93	6.2%	64	4.5%	7	0.5%	-	-	-	-
Directors' remuneration (Supervisory Board) 6
Karl Guha (chairperson)	222	16	7.6%	-	-	-	-	-	-	-	-
Mike Rees (vice-chairperson)	170	12	7.8%	7	4.6%	12	8.8%	10	7.8%	0	0%
Juan Colombás	154	13	8.9%	18	14.7%	21	20.4%	8	8.5%	-	-
Stuart Graham	86	-	-	-	-	-	-	-	-	-	-
Margarete Haase	147	19	14.6%	11	9.3%	6	4.9%	8	7.7%	-1	-1.0%
Lodewijk Hijmans van den Bergh	117	6	5.2%	4	3.4%	11	10.8%	-	-	-	-
Petri Hofsté	46	-	-	-	-	-	-	-	-	-	-
Herman Hulst	117	6	5.2%	4	3.4%	8	7.5%	5	5.0%	-	-
Harold Naus	117	11	10.2%	8	8.7%	6	6.0%	-3	-2.9%	-	-
Alexandra Reich	132	14	11.4%	-	-	-	-	-	-	-	-
Herna Verhagen	128	17	15.1%	4	3.4%	6	5.4%	2	2.0%	-21	-17.4%
Company’s performance
Mobile primary customer (in mln) 7	15.4	-	-	-	-	-	-	-	-	-	-
Profit before tax ING Group (in mln)	9,148	-152	-2%	-1,192	-11%	4,990	91%	-1,280	-19%	2,973	78%
Return on equity based on IFRS-EU equity	13.2%	0.2%	1.5%	-1.8%	-12%	7.6%	106%	-2%	-22%	4.4%	92%
Average employee remuneration
Average fixed and annual variable remuneration	85	3.9	4.8%	3.8	4.9%	4.8	6.5%	2.4	3.5%	2.7	4.0%

1For consistency reasons, this table only makes a comparison between two full financial years, in which the respective EB or SB member served in their role as board member.

2The remuneration of the EB consists of base salary and variable remuneration (total direct compensation).

3Variable remuneration for the EB is included in the year in which the performance was delivered i.e. prior to the year in which it is paid out.

4Fixed remuneration for EB members is not linked to company performance but is predominantly based on a benchmark exercise. Total direct compensation of EB members should stay below the median of the benchmark, in line with the Dutch Banking Code. This has a mitigating effect on the correlation with

company performance.

5The relative total compensation increase from 2020 to 2021 is mainly caused by the fact that no variable remuneration was awarded for the performance year 2020.

6There is no relation between SB remuneration and company performance. SB members do not receive any variable remuneration. This remuneration is based on fixed fees related to their role and number of meetings. The high fluctuations are caused by the role changes during the year and differences in the

number of meetings.

7In 2025, ING moved from the metric primary customers to mobile primary customers.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	101

Proposed updates to Executive Board Remuneration

Policy

In 2025 we conducted an extensive review of our Executive Board

Remuneration Policy and the remuneration level of our EB. Over the past

years, ING was successful, based on our strong brand, digital DNA,

entrepreneurial culture, good employee engagement and strong results.

That makes us attractive as an employer, but it is imperative we continue

to remain so. Our review showed that the EB compensation is well below

the market level and that the gap has widened in recent years. These

factors reinforce the need to act now, applying a balanced approach to

ensure long-term competitiveness and success in retaining and

attracting talent.

Remuneration is an important and sensitive topic, and viewpoints on the

topic vary for different stakeholder groups. For this reason, in 2025 and

2026 as part of the renewal process of the Remuneration Policy, the

Supervisory Board conducted a comprehensive stakeholder engagement

process with shareholders, regulators, customers, employees (via the

Central Works Council), and wider society to take their views into

account. This resulted in valuable feedback on the proposals, which were

broadly supported.

ING’s goal is to position the total direct compensation of the EB slightly

below the market median of the peer group, using a progressive, step-by-

step approach as further explained in the proposed new Remuneration

Policy for the EB. As part of this approach, the Supervisory Board aims to

increase the CEO's base salary by 5-7 percent per year and the CFO's and

CRO's base salaries by 7-9 percent per year. If any of the Executive Board

positions reaches just below median, the increase will cease and again be

reviewed the following year. For the avoidance of doubt: any increases to

the annual base salary remain at the full discretion of the SB and are

therefore not guaranteed. In making such decisions, the SB will consider

all relevant circumstances, including performance, market developments,

internal pay ratios and salary increase for other employees within ING

(including Dutch CLA and wider workforce increases), stakeholder views,

and the other factors that are considered when determining base salaries.

The proposed new Remuneration Policy for the Executive Board also

includes a fixed shares plan for its members. To strengthen alignment with

long-term shareholder experience, at least 50 percent of any annual base

salary increase for the EB will be delivered as fixed share salary, to be used

to acquire ING Groep N.V. ordinary shares (fixed shares). These fixed shares

will be acquired quarterly in arrears and will be subject to a five-year

holding period.

For more information on the proposed new Executive Board Remuneration

Policy, please refer to the letter of the Chairperson of the SB RemCo. The

full proposed updated Executive Board Remuneration Policy is available on

ing.com/about-us/corporate-governance/remuneration.

2026 Executive Board remuneration

For 2026, the SB considers it appropriate to increase the CEO’s base salary

by 5 percent, and the CFO's and CRO's base salaries each by 7 percent. The

proposed increase for the CEO is broadly in line with the Dutch CLA and

wider workforce increases. These adjustments represent a step in reducing

the gap with the market median, while still remaining well below median

levels after the 2026 adjustments and continuing to follow our policy aim

of positioning total direct remuneration just below the median over time.

Delivering 50 percent of the increase in fixed shares, subject to a five-year

retention period, further strengthens alignment with long-term

shareholder interests.

2026 annual variable remuneration performance measures

Performance measures with appropriately stretching targets have been

selected to cover a range of financial, non-financial, and risk objectives

that support ING's key strategic priorities. The performance measures and

weightings for the 2026 annual variable remuneration are presented on

the next page.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	102

For 2026, the table below outlines the target areas and their respective percentage weightings for EB members, as well as the corresponding stakeholder groups:


2026 Target areas		CEO	CFO	CRO	Alignment stakeholder groups
		Weighting	Weighting	Weighting
Financial
Profit before tax		16.7%	16.7%	8.3%
Return on tangible equity		16.7%	16.7%	8.3%
Operational expenses		16.7%	16.7%	8.3%
		50%	50%	25%
Non-financial
Customer	§Increase number of mobile primary customers as this leads to deeper relationships, greater customer satisfaction, and ultimately customers choosing ING for more of their financial needs1 §Increase customer satisfaction of Retail and Wholesale by increasing NPS2	7.5%	5%	NA
Risk & Regulatory	§Manage financial risk within risk appetite §Manage non-financial risk within risk appetite §Delivery on regulatory programmes including risk data and reporting enhancements	15%	17.5%	45%
Strategy	§Increase digitisation and straight-through-processing (STP) rate of customer processes §Accelerating the responsible and effective use of artificial intelligence to unlock new opportunities and efficiencies	12.5%
	§Harden the internal and external reporting processes		12.5%
	§Increase efficiency of risk processes while maintaining the effectiveness of controls §Accelerate AI use in risk practices in a responsible and effective way			15%
Environment	§Increase WB financing for clients to allow them to pursue their sustainability objectives (as reflected in sustainable volume mobilised)3 §Managing and mitigating transition risk exposure relating to WB clients in the most carbon-intensive sectors4	10%
	§Further enhancement of ESG disclosures in line with applicable reporting requirements		10%
	§Continuous refinement of ESG risk assessment methodology5			10%
Social	§Strengthen organisational health with a focus on five priority areas: strategic clarity, role clarity, customer orientation, data-driven decision making, talent development §Increase ING’s attractiveness as an employer as reflected in the gender balance in ING's leadership cadre6	5%	5%	5%
		50%	50%	75%
Total		100%	100%	100%



Legend	Our people	Shareholders	Regulators	Our customers	Society at large

1The number of mobile primary customers means the number of customers who are primary customers with at least one mobile interaction through our app or mobile website per quarter (2025: 15.4 million; 2024: 14.4 million).

2NPS means net promoter score and indicates whether customers would recommend ING to others. See 'Our NPS performance' for more information.

3For more information on the detailed methodology, see ing.com (2025: €166 billion; 2024: €130 billion).

4Transition risk exposure is evaluated by reference to the Terra approach.

5ESG risk-assessment methodology refers to designing and integrating the Prudential Transition Plan in line with EBA ESG Risk Guidelines.

6Gender balance is measured as the percentage of female representation in senior management positions. The evaluation of gender balance for the purposes of determining whether this non-financial target has been satisfied should exclude any employees located in jurisdictions where gender-based targets may

be subject to any restrictions or other considerations under applicable law or regulation.

1SB members are not eligible for retirement benefits nor any other benefits in relation to their position on the SB.

2Stuart Graham was appointed to the SB by the AGM on 22 April 2025 with effect from 1 July 2025. The remuneration figures for 2025 reflect a partial year as a member of the SB.

3 Petri Hofsté was appointed to the SB by the AGM on 22 April 2025 with effect from 1 July 2025. The remuneration figures for 2025 reflect a partial year as a member of the SB.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	103

Supervisory Board remuneration

Our Supervisory Board Remuneration Policy was approved by shareholders at

the 2024 AGM and became effective retroactively from 1 January 2024 until

the 2028 AGM at the latest. The full policy, including contract information and

governance, can be found on ING.com/remuneration. The Supervisory Board

Remuneration Policy aims to enable ING to attract qualified SB members with

the ability, experience, skills, values, and behaviours to deliver on ING's

strategy, long-term interests, and sustainability.

Supervisory Board Remuneration Policy summary

The SB remuneration structure is outlined in the Supervisory Board

Remuneration Policy. The remuneration components and operation of the

Supervisory Board Remuneration Policy are set out below.


Remuneration component	Operation
Annual remuneration, committee fees and attendance fees	§SB members receive fees for their service on the SB as set out in the remuneration structure table below. The remuneration is awarded to the SB members by the General Meeting.1 §The remuneration structure reflects the roles and responsibilities of individual SB members. §All fees are paid out fully in cash. No variable remuneration is provided (and therefore none is disclosed) to ensure that the SB members can maintain independence and provide objective stewardship of ING, thereby contributing to the long- term performance of the company. §Any changes in the fee levels will be presented in ING’s Annual Report for the relevant year.1,2
Expenses	§SB members are reimbursed for their travel and business-related expenses incurred in their capacity as SB members.

Annually the total fees of SB members are reviewed against comparable

positions in the market. For this benchmarking process, the SB uses the

same peer group as is used for the EB, see 'Executive Board benchmark

approach'.

In accordance with the Articles of Association, ING indemnifies the

members of the SB as far as legally permitted, against direct financial

losses in connection with claims from third-parties filed, or threatened to

be filed against them by virtue of their services as a member of the SB.

2025 Supervisory Board remuneration

The following visual shows the remuneration, including attendance fees,

for each SB member. All fees for the SB are paid directly by ING. For total

costs for the SB, see Note 45 'Related parties'.3

Loans and advances to Supervisory Board members

SB members may obtain banking and insurance services from ING and its

subsidiaries in the ordinary course of their business and on terms that are

customary in the sector. The SB members do not receive privileged

financial services. On 31 December 2025, there were no loans or advances

outstanding to SB members.

ING shares held by Supervisory Board members

SB members are permitted to hold ING shares as a long-term investment.

The table below shows the holdings by members of the SB on 31

December 2025 and 2024.


ING shares held by Supervisory Board members
Numbers of shares	2025	2024
Stuart Graham	4,100	-
Herman Hulst	3,650	3,650
Harold Naus	1,645	1,645

1 Included are all countries within the Eurozone where ING operates the full scope of banking services.

2 For display and administrative purposes, the increased/index-linked figures are rounded down to nearest hundred.

3 The Supervisory Board may appoint ad hoc committees to provide flexibility in its supervisory tasks, allowing for efficient handling of certain matters such as complex projects and decisions or strategic planning.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	104

Proposed updates to Supervisory Board

Remuneration Policy

In 2025 we undertook an extensive review of our Supervisory Board

Remuneration Policy and the remuneration level of our Supervisory Board.

Our review showed that roles have changed, and required time

commitment and regulatory complexity have increased. At the same

time, the compensation of our Supervisory Board is well below market

levels and the gap has widened in recent years. These factors reinforce the

need to act now, taking a balanced approach to ensure long-term

competitiveness and success in retaining and attracting talent.

Remuneration is an important and sensitive topic, and viewpoints on the

topic vary for different stakeholder groups. For this reason, in 2025 and

2026 as part of the renewal process of the Remuneration Policy, the

Supervisory Board conducted a comprehensive stakeholder engagement

process with shareholders, regulators, customers, employees (via the

Central Works Council), and wider society to take their views into account.

This resulted in valuable feedback on the proposals, which were broadly

supported.

ING proposed to take a progressive, step-by-step approach by moving the

Supervisory Board fees closer to the market median over the lifetime of

the proposed new Supervisory Board Remuneration Policy. This includes

increasing the annual retainer fees of the Supervisory Board annually by 9

percent. In addition, the Supervisory Board committee fees will be

increased annually by €10,000 for the Chairpersons of the Risk and Audit

Committees, €7,500 for all other Committee Chairpersons, and €3,000 for

Committee members.

ING will continue with the annual process of performing a benchmark

review. For the duration of the policy the above-mentioned annual

increases will continue to apply, unless the annual benchmark review

demonstrates that applying this increase would result in the fees for a

specific role exceeding the threshold of 3 percent below market median of

comparable positions in the peer group. In such a case, the increase for

that specific role for the relevant year will be limited to the exact

percentage required to achieve a fee that is 3 percent below the market

median. Once a fee for a specific role has reached a position that is 3

percent below the market median, the fee will be indexed annually based

on the salary increases for the wider workforce within ING (or lower) for

that relevant year, provided that such an indexation does not result in the

fee exceeding the threshold of 3 percent below the market median.

ING furthermore proposes to introduce a travel allowance for the

Supervisory Board. In certain circumstances they are required to travel

outside country or continent of residence for additional meetings with

external parties that go beyond and cannot be combined with scheduled

board meetings. The travel allowance compensates for the time and effort

associated with these additional activities. The amounts will be the same

as the attendance fees and reflect the additional time spent.

2026 Supervisory Board remuneration

For 2026, Supervisory Board annual retainer and committee fees will be

increased in line with the proposed new Supervisory Board Remuneration

Policy. The attendance fees will be increased by 4.3 percent in line with the

annual indexation percentage increase of the wider workforce.1 These

changes are subject to adoption at the 2026 Annual General Meeting of

the updated Supervisory Board Remuneration Policy and would take effect

retroactively from 1 January 2026.

These adjustments represent the first step in a gradual process to reduce

the gap with the market median, while remaining well below median levels

after the 2026 adjustments and continuing to follow our policy aim of

positioning just below median over time.

This results in the following amounts:


Supervisory Board remuneration
Amounts in euros2	2025	2026
Annual remuneration
Chairperson SB	138,500	150,900
Vice-chairperson SB	105,300	114,700
SB Member	77,500	84,400
Committee/Ad hoc Committee fees (annual amounts) 3
Audit & Risk Committee chairperson	22,000	32,000
Other Committee chairperson	22,000	29,500
Committee Member	11,000	14,000
Attendance fees (per meeting)
Attendance fee outside country of residence	2,100	2,100
Attendance fee outside continent of residence	7,800	8,100
Travel allowance (per meeting)
Travel allowance outside country of residence	-	2,100
Travel allowance outside continent of residence	-	8,100

1 For 2025, it was applied to 49 staff members worldwide. This mandate is used on an exceptional basis by ING and in 2022, 2023 and 2024 also applied to a limited number of employees worldwide.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	105

FOR INFORMATION ONLY AT 2026 ING GROEP N.V. ANNUAL GENERAL MEETING (AGM)

Group variable remuneration outcomes

In determining the 2025 Group discretionary variable remuneration pool,

the SB considered:

§the Group's financial and non-financial performance in 2025;

§the performance of business lines within the Group and their

contributions to our strategic targets; and

§the Group's capital position and current and future risks.

The award of discretionary variable remuneration is based on a

transparent, structured, and robust mechanism for measuring

performance and applying risk adjustments (the Variable Remuneration

Accrual Model or VRAM). The VRAM construct follows a five-step process –

as shown in the graphic to the right – to determine Group and business

line risk-adjusted variable remuneration pools.

Based on this, the SB approved a Group discretionary VR pool for 2025

performance of €477.3 million (2024: €421.6 million), representing an

increase of 7.7 percent compared to the target baseline ('starting point')

and 13.2 percent compared to the final VR pool for 2024. Risk and conduct

adjustments to the 2025 VR pool are slightly higher than those applied

in 2024.

Collective variable remuneration is determined by collective labour

agreements, which are shaped by regulations, laws and/or workers council

agreements across various countries. In recent years the total amount of

collective variable remuneration has remained relatively stable and typically

accounts for around 20 percent of the total spend on variable remuneration.

Overall, the total actual amount of both discretionary and collective

variable remuneration awarded to all eligible employees globally for 2025

was €576.1 million (€98.8 million in collective variable remuneration),

compared to the total staff expenses of €7,600 million. For 2024, the total

amount was €522.7 million (€101.1 million in collective variable

remuneration) on €7,184 million staff expenses.

In 2025, 26 employees, excluding members of the Management Board

Banking, were awarded total annual remuneration (including employer

pension contributions and excluding severance payments made) of €1

million or more. For more information on our CRR disclosure (including a

breakdown by each group of employees), see the section ‘Annual reports’

on ing.com.

At the 2021 AGM, shareholders approved an increased maximum

percentage of 100 percent up to 200 percent for employees outside the

EEA, applicable for five performance years through to the end of 2026, in

line with the Dutch Wbfo1. At the 2026 AGM, we will ask for a new

mandate to apply an increased maximum percentage of up to 200

percent for employees outside the EEA for a further period of five

performance years, from 2027 until 2031.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	106

Variable Remuneration Accrual Model

Step 1

Step 2

Step 3

Step 4

Step 5

Set-up of target

Group VR pool

Conditions to qualify for a VR

award or reduce pools potentially

to zero

Meeting basic prudential &

performance risk conditions

Performance measures

Assessing performance

Set-up final Group and business line

VR pool: CEO discretion

Additional risk adjustment

Applying additional ex-ante and ex-post risk adjustment

(material risk events and individual risk modifiers)

Financial performance

Individual

targets

Return on equity

Common equity

tier 1 (SREP)

Profit before

tax

Return on

equity

Operating

expenses

Business line

quantitative

Additional performance factors

Step 5i Additional ex-ante and ex-post risk adjustments

Non-financial & risk performance

Target Group

VR pool

Customer

Risk & Regulatory

Strategy

CEO discretion

Step 5ii Employee significant incidents and ex-post risk

adjustments

Environment

Social

Final Group

VR pool

Business line

VR pool

Final Group

VR pool

Business line

VR pool

Step 1

Step 2

Step 3

Step 4

Step 5

Target VR pool is

a sum of

individual VR

targets which

are set in

reference to

market pay

levels.

ROE and CET1 hurdles, as qualifiers,

are requirements that both need to

be met before the VR pools can be

unlocked.

Performance scorecards are based on assessments against

financial, non-financial and risk measures, and the pool may

increase or decrease depending on financial and non-financial

results.

Group CEO reviews the VR pools and,

where appropriate, makes a

discretionary recommendation to

adjust upwards or downwards the

VR pools based on performance

parameters.

Final and independent risk assessment where the Group CRO can

recommend to adjust upwards or downwards the VR pools based

on any exceptional risk performance at a Group, business line,

entity or team level.

Furthermore, the Group CRO also recommends risk modifiers to

individual variable awards where risk requirements are below

expectations applicable only to IDS Risk Takers* as well as

holdback (i.e. forfeiture of up to 100 percent of the unvested

variable remuneration awards) and/or clawback sanctions (i.e.

repayment of up to 100 percent of the paid or vested variable

remuneration) for employee significant incidents.

* Identified staff reporting hierarchically to a business line and not working in a control function.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	107

C.Board practices

For information regarding board practices, see Item 6.A.

Severance payments to members of the Executive Board

The contracts entered into with the members of the EB provide for severance payments that become due upon

termination of the applicable member’s contract, including if termination occurs in connection with a public bid as

defined in section 5:70 of the Dutch Financial Supervision Act. Severance payments to the members of the

Executive Board are limited to a maximum of one year’s fixed salary.

Transactions between ING Group and significant shareholders

ING Group did not enter into any transactions with shareholders holding at least 10 percent of the share capital.

D. Employees

The average number of internal employees at a full time equivalent basis was 62,770 in 2025, of which 15,280 or

24%, were employed in the Netherlands. Substantially all of the Group’s Dutch employees are subject to a

collective labor agreement covering ING in the Netherlands.

The distribution of employees with respect to the Group’s continuing operations for the years 2025, 2024 and 2023

were as follows:


Number of employees
	Netherlands			Rest of the world			Total
	2025	2024	2023	2025	2024	2023	2025	2024	2023
Total average number of internal employees at full time equivalent basis	15,280	14,821	14,449	47,490	46,301	44,985	62,770	61,121	59,434

The Group employs a number of temporary employees. The average number of temporary employees, not

included in the table above, at a full time equivalent basis was 3,058 at the end of 2025.

E.Share ownership

For information regarding share ownership, see Item 6.B of this Form 20-F, Note 45 'Related parties' and Note 25

'Staff expenses' in the consolidated financial statements.

F.Disclosure of a registrant’s action to recover erroneously awarded

compensation

Not applicable.

Reference is made to Exhibit 97 to this Form 20-F for the policy on 'Clawback rules for erroneously awarded

variable remuneration for executive officers'.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	108

Item 7. Major Shareholders and Related Party

Transactions

A. Major shareholders

ING Group ordinary shares are listed on the stock exchanges of

Amsterdam (Euronext Amsterdam) and Brussels (Euronext Brussels). ING

Group American Depositary Shares (“ADSs”) are listed on the New York

Stock Exchange (NYSE). Options on ING Group ordinary shares or in the

form of American depository receipts (ADRs) are traded on the Euronext

Amsterdam Derivative Markets and the Chicago Board Options Exchange.

Major shareholders as filed with SEC

According to the U.S. Securities and Exchange Commission, shareholders in

a company which have registered a class of their equity securities under

the Exchange Act, are required to file beneficial owner reports if the

ownership exceeds more than 5% of the outstanding shares of that class.

The shareholder is obliged to file Schedule 13D or 13G until their holdings

drop below 5%.

To the best of our knowledge, as of 31 December 2025, no holder of

ordinary shares or ADSs, other than BlackRock Inc. held 5% or more of ING

Group’s issued share capital.

On 1 February 2023, BlackRock, Inc. disclosed by way of a Schedule 13G

filed with the SEC, beneficial ownership of 259,211,756 ordinary shares of

ING Group as of 31 December 2022, representing 7.0% of ING Group's

issued share capital. On 13 February 2023, Capital Research Global

Investors disclosed by way of a Schedule 13G filed with the SEC, beneficial

ownership of 57,557,399 ordinary shares of ING Group as of 30 December

2022, representing 1.5% of ING Group's issued share capital. On 6 February

2024, BlackRock, Inc. disclosed by way of a Schedule 13G filed with the SEC,

beneficial ownership of 255,592,935 ordinary shares of ING Group as of 31

December 2023, representing 7.3% of ING Group's issued share capital.

On 12 November 2024, Capital Research Global Investors disclosed by way

of a Schedule 13G filed with the SEC, beneficial ownership of 214,691,773

ordinary shares of ING Group as of September 30, 2024, representing 6.5%

of ING Group's issued share capital. On 13 February 2025, Capital Research

Global Investors disclosed by way of a Schedule 13G filed with the SEC,

beneficial ownership of 152,644,673 ordinary shares of ING Group as of 31

December 2024, representing 4.8% of ING Group's issued share capital.

Major shareholders as filed with AFM

Pursuant to section 5.3 of the Dutch Financial Supervision Act (“Major

Holdings Rules”), any person who, directly or indirectly, acquires or

disposes of an interest in the voting rights and/or the capital of (in short) a

public limited company incorporated under the laws of the Netherlands

with an official listing on a stock exchange within the European Economic

Area, as a result of which acquisition or disposal the percentage of his

voting rights or capital interest - whether through ownership of shares,

American depositary receipts (ADRs) or any other financial instrument,

whether stock-settled or cash-settled, such as call or put options,

warrants, swaps or any other similar contract - reaches, exceeds or falls

below the threshold levels of 3%, 5%, 10%, 15%, 20%, 25%, 30%, 40%,

50%, 60%, 75% and 95% is required to provide updated information on its

holdings and are recorded in the Dutch AFM (Authority for the Financial

Markets) register (http://www.afm.nl/nl-en/professionals/registers/

meldingenregisters/substantiele-deelnemingen). This notification

obligation also applies in respect of gross short positions that exceed the

relevant threshold levels.

In addition, any person who acquires or disposes of a net short position

relating to the issued share capital of ING Group, whether by a transaction

in shares or ADRs, or by a transaction creating or relating to any financial

instrument where the effect or one of the effects of the transaction is to

confer a financial advantage on the person entering into that transaction

in the event of a change in the price of such shares or ADRs, is required to

notify the AFM if, as a result of such acquisition or disposal, the person’s

net short position reaches, exceeds or falls below 0.1% of the issued share

capital of ING Group and each 0.1% above that. Each reported net short

position equal to 0.5% of the issued share capital of ING Group and any

subsequent increase of that position by 0.1% will be made public via the

short selling register on afm.nl/en/.

Based on the AFM register as per 31 December 2025, shareholders with

(potential) holdings of 3% or more are BlackRock Inc. (5.28% interest and

6.33% voting rights reported on 15 March 2024), Capital Research and

Management Company (4.99% voting rights reported on 26 November

2024) and Amundi Asset Management (3.02% interest and voting rights

reported on 13 August 2025). ING Groep N.V. and its subsidiaries held

90,753,376 ordinary shares or ADSs, representing 3.00% of ING Group's

issued share capital. ING Groep N.V. does not have voting rights in respect

of shares and ADSs it holds or which are held by its subsidiaries.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	109

As a result, other than based on information available from public filings

available under the applicable laws of any other jurisdiction, ING Groep

N.V. is not aware of any changes in the ownership of ordinary shares or

ADSs between the thresholds levels mentioned in the previous sentence.

On 31 December 2025, no person is known to ING Groep N.V. to be the

owner of more than 10% of the ordinary shares or ADSs.

As of 31 December 2025, members of the Supervisory Board and their

related third parties held 9,395 Ordinary Shares. Members of the

Supervisory Board do not hold ING options.

As at 31 December 2025, members of the Executive Board and their

related third parties held 100.994 ordinary shares.

As at 31 December 2025, members of the Management Board Banking

and their related third parties held 69.247 ordinary shares.

Change of control matters

As at 31 December 2025 ING Groep N.V. was not a party to any material

agreement that becomes effective, or is required to be amended or

terminated in case of a change of control of ING Groep N.V. following a

public bid as defined in the Dutch Financial Supervision Act. ING Groep

N.V.’s subsidiaries may have customary change of control arrangements

included in agreements related to various business activities, such as joint

venture agreements, letters of credit and other credit facilities, ISDA-

agreements, hybrid capital and debt instruments, reinsurance contracts

and futures and option trading agreements. Following a change of control

of ING Groep N.V. (as the result of a public bid or otherwise), such

agreements may be amended or terminated, leading, for example, to an

obligatory transfer of the interest in the joint venture, early repayment of

amounts due, loss of credit facilities or reinsurance cover and liquidation of

outstanding futures and option trading positions.

As of 31 December 2025 ING Groep N.V. was not aware of any

arrangements the operation of which may result in a change of control of

ING Groep N.V.

B. Related Party Transactions

In the normal course of business, ING Group enters into various

transactions with related parties. Parties are considered to be related if

one party has the ability to control or exercise significant influence over

the other party in making financial or operating decisions. Related parties

of ING Group include, among others, its associates, joint ventures, key

management personnel, and various defined benefit and contribution

plans. Transactions between related parties include rendering or receiving

of services, leases, transfers under finance arrangements and provisions of

guarantees or collateral. There are no significant provisions for doubtful

debts or individually significant bad debt expenses recognised on

outstanding balances with related parties.

ING Group has entered into various transactions with related parties. For

more information, reference is made to Note 45 “Related parties” in the

consolidated financial statements.

As described under “Item 6. Directors, Senior Management and

Employees”, some members of the Supervisory Board are current or

former senior executives of leading multi-national corporations based

primarily in the Netherlands. ING Group may at any time have lending,

investment banking or other financial relationships with one or more of

these corporations in the ordinary course of business on terms which we

believe are no less favorable to ING than those reached with unaffiliated

parties of comparable creditworthiness.

C. Interests of experts and counsel

This item does not apply to annual reports on Form 20-F.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	110

Item 8. Financial information

A.Consolidated statements and other

financial information

Consolidated statements

For information regarding consolidated statements and other

financial information, see Item 18 of this Form 20-F.

Legal Proceedings

For a description of ING’s legal proceedings, see Note 42 'Legal

proceedings' in the consolidated financial statements.

Dividend and distribution policy

ING’s distribution policy is a pay-out ratio of 50% of resilient net profit

and additional distributions in case of structural excess capital.

Prerequisite for a distribution is a CET1 ratio of at least prevailing

Maximum Distributable Amount (MDA) level after distribution. For

detailed information on ING’s 2025 dividend, reference is made to

‘Capital Management’ in Additional Information.

Cash distributions on ING Groups ordinary shares are generally paid in

Euros. However, the Executive Board may decide, with the approval of

the Supervisory Board, to declare dividends in the currency of a

country other than the Netherlands in which the shares are traded.

Amounts payable to holders of ADRs that are paid to the Depositary

in a currency other than dollars will be converted to dollars and

subjected to a charge by the Depositary for any expenses incurred by

it in such conversion.

If the Executive Board has been designated as a body authorised to

resolve to issue shares, it may decide, with the approval of the

Supervisory Board, that a distribution on ordinary shares shall be

made in the form of ordinary shares instead of cash or to decide that

the holders of ordinary shares shall be given the choice of receiving

the distribution in cash or in the form of ordinary shares.

The right to dividends and distributions in respect of the ordinary

shares will lapse if such dividends or distributions are not claimed

within five years following the day after the date on which they were

made available.

There are no legislative or other legal provisions currently in force in

the Netherlands or arising under ING Groups’ Articles of Association

restricting the remittance of dividends to holders of ordinary shares,

or ADRs not resident in the Netherlands. Insofar as the laws of the

Netherlands are concerned, cash dividends paid in Euro may be

transferred from the Netherlands and converted into any other

currency, except that for statistical purposes such payments and

transactions must be reported by ING Group to DNB and, further, no

payments, including dividend payments, may be made to jurisdictions

or persons, that are subject to certain sanctions, adopted by the

Government of the Netherlands, implementing resolutions of the

Security Council of the United Nations, or adopted by the European

Union.

Dividends are subject to withholding taxes in the Netherlands as

described under "Item 10. Additional Information - Taxation -

Netherlands Taxation”.

ING’s distribution policy may be changed at any time and there is no

guarantee that any dividends or other distributions will be made in

accordance with the distribution policy in effect from time to time or

at all.

B. Significant changes

For information on subsequent events reference is made to Note 48

‘Subsequent events’ of the consolidated financial statements.

Since 31 December 2025, until the filing of this report, no other

significant changes have occurred in the financial statements of the

Group included in “Item 18. Consolidated Financial Statements” of this

document.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	112

Item 10. Additional information

A.Share capital

This item does not apply to annual reports on Form 20-F.

B.Memorandum and articles of association

For a description of ING’s memorandum and articles of association, please

see Exhibit 2.1 “Description of Securities Registered under Section 12 of the

Exchange Act”, which is incorporated by reference herein.

Reference is made to Exhibit 1.1 to this Form 20-F for the articles of

association.

C.Material contracts

There have been no material contracts outside the ordinary course of

business to which ING Groep N.V. or any of its subsidiaries is a party in the

last two years.

D. Exchange controls

Cash distributions, if any, payable in Euros on Ordinary Shares and ADSs

may be officially transferred from the Netherlands and converted into any

other currency without violating Dutch law, except that for statistical

purposes such payments and transactions must be reported by ING Groep

N.V. to the Dutch Central Bank and, further, no payments, including

dividend payments, may be made to jurisdictions or persons subject to

certain sanctions, adopted by the government of the Netherlands or the

European Union.

E.Taxation

The following is a summary of certain Netherlands tax consequences, and

the United States federal income tax consequences, of the ownership of

our Ordinary Shares or American Depositary Shares (“ADSs”) by U.S.

Shareholders (as defined below) who hold Ordinary Shares or ADSs as

capital assets for tax purposes.

For the purposes of this summary, a “U.S. Shareholder” is a beneficial

owner of Ordinary Shares or ADSs that is, for United States federal income

tax purposes:

§an individual citizen or resident of the United States,

§a corporation organized under the laws of the United States or of any

state of the United States, or any entity taxable as United States

corporation,

§an estate, the income of which is subject to United States federal

income tax without regard to its source, or

§a trust if a court within the United States is able to exercise primary

supervision over the administration of the trust and one or more United

States persons have the authority to control all substantial decisions of

the trust.

Further, this summary is limited to U.S. Shareholders who are not, and are

not deemed to be, a resident of the Netherlands for Dutch tax purposes.

This summary is based on the United States Internal Revenue Code of

1986 and the laws of the Netherlands, each as amended, their legislative

history, existing and proposed regulations, published rulings and court

decisions, and the tax treaty between the United States and the

Netherlands for the Avoidance of Double Taxation and the Prevention of

Fiscal Evasion with respect to Taxes on Income (“Treaty”), all as applicable

as of the date hereof. These laws are subject to change, possibly on a

retroactive basis. The information provided below is neither intended as

tax advice nor purports to describe all of the tax considerations that may

be relevant to investors and prospective investors including foreign, state

or local tax consequences, estate and gift tax consequences, and tax

consequences arising under the Medicare contribution tax on net

investment income or the alternative minimum tax. It should not be read

as extending to matters not specifically discussed, and investors should

consult their own advisors as to the tax consequences of their ownership

and disposal of Ordinary Shares or ADSs. In particular, the summary does

not take into account the specific circumstances of particular investors

(such as tax-exempt organizations, banks, insurance companies, dealers in

securities, traders in securities that elect to use a mark-to-market method

of accounting for their securities holdings, investors whose functional

currency is not the U.S. dollar, investors that actually or constructively own

10% or more of the combined voting power of the voting stock or of the

total value of ING Groep N.V., investors that hold Ordinary Shares or ADSs

as part of a straddle or a hedging or conversion transaction or investors

that acquired or dispose of Ordinary Shares or ADSs as part of a wash sale

for tax purposes, some of which may be subject to special rules). If an

entity or arrangement that is treated as a partnership for United States

federal income tax purposes holds the Ordinary Shares or ADSs, the United

States federal income tax treatment of a partner will generally depend on

the status of the partner and the tax treatment of the partnership. A

partner in a partnership holding the Ordinary Shares or ADSs should

consult its tax advisor with regard to the United States federal income tax

treatment of an investment in the Ordinary Shares or ADSs.

Moreover, this summary does not discuss (i) the Dutch tax treatment of a

holder of Ordinary Shares or ADSs who is an individual receiving income or

capital gains derived from the Ordinary Shares and ADSs if such income or

capital gains are attributable to the past, present or future employment

activities of such holder and (ii) the potential consequences for corporate


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	113

holders of Ordinary Shares or ADSs pursuant to the Dutch Minimum Tax

Act 2024 (Wet Minimumbelasting 2024).

The summary is based in part upon the representations of the Depositary

and the assumption that each obligation in the Deposit Agreement and

any related agreement will be performed in accordance with its terms. In

general, for United States federal income tax and Netherlands tax

purposes, holders of ADSs will be treated as the owners of the Ordinary

Shares underlying the ADSs, and exchanges of Ordinary Shares for ADSs,

and exchanges of ADSs for Ordinary Shares, will not be subject to United

States federal income tax or Netherlands income tax. References to

Ordinary Shares in this section include references to ADSs.

It is assumed, for purposes of this summary, that a U.S. Shareholder is

eligible for the benefits of the Treaty and that a U.S. Shareholder’s

eligibility is not limited by the limitation on benefits provisions of the

Treaty.

Netherlands Taxation

Dutch dividend withholding tax

The Netherlands imposes a withholding tax on a distribution of a dividend

at the statutory rate of 15%. Dividends include:

1.dividends paid in cash and in kind;

2.deemed and constructive dividends;

3.the consideration for the repurchase or redemption of shares in excess

of the qualifying average paid-in capital unless such repurchase is

made for temporary investment purposes or is exempt by law;

4.any (partial) repayment of paid-in capital not qualifying as capital for

Dutch dividend withholding tax purposes;

5.liquidation proceeds in excess of the qualifying average paid-in capital

for Dutch dividend withholding tax purposes; and

6.stock dividends up to their nominal value (unless distributed out of ING

Groep N.V.’s qualifying paid-in capital).

Reduction of Dutch dividend withholding tax based on Dutch law

Under certain circumstances, a reduction of Dutch dividend withholding

tax can be obtained based on Dutch law:

1.An exemption at source is available if the Dutch participation

exemption applies and the Ordinary Shares or ADSs are attributable to

a business carried out in the Netherlands. To qualify for the Dutch

participation exemption, the U.S. Shareholder must generally hold at

least 5.0 percent of our nominal paid-in capital and meet certain other

requirements.

2.An exemption at source is available for dividend distributions to certain

qualifying corporate U.S. Shareholders owning our Ordinary Shares or

ADSs if such shareholder would have been able to apply the Dutch

participation exemption if it would have been resident of the

Netherlands, unless such shareholder holds the Ordinary Shares or

ADSs with the primary aim or one of the primary aims to avoid the levy

of Dutch dividend withholding tax at the level of another person and

the Ordinary Shares or ADSs are not held for valid commercial reasons

that reflect economic reality.

3.Certain tax exempt organizations (e.g. pension funds and excluding

collective investment vehicles) may be eligible for a refund of Dutch

dividend withholding tax upon their request or in certain cases, an

exemption at source.

4.Upon request and under certain conditions, certain qualifying individual

and corporate U.S Shareholders of Ordinary Shares or ADSs which are

not subject to personal or corporate income tax in the Netherlands

may request a refund of Dutch dividend withholding tax insofar as the

withholding tax withheld on the gross dividend is higher than the

personal or corporate income tax which would have been due on the

net dividend if they were resident or established in the Netherlands.

This refund is however not applicable when, based on the Treaty, the

Dutch dividend withholding tax can be fully credited in the United

States by the U.S. Shareholder. However, it is unclear whether (i) which

(financing) costs can be taken into account when determining the

hypothetical personal or corporate income tax due on the net income

(ii) or how the Netherlands would determine whether, based on the

double taxation convention, a full credit is available in the country of

residence of the holder for purposes of this refund. See “United States

Taxation—Taxes on dividends” for more information. The provision in

essence is intended to be a codification of certain judgments by both

the European Free Trade Association Court of Justice and the European

Court of Justice that already indicated that in certain circumstances a

refund should be available prior to the introduction of the provision in

Dutch law. It is possible that this provision is an insufficient codification

of these judgments and that based on EU law a larger refund should be

provided.

Reduction of Dutch dividend withholding tax based on the Treaty

Pursuant to the provisions of the Treaty, certain corporate U.S.

Shareholders owning directly at least 10% of our voting power are eligible

for a reduction to 5% Dutch dividend withholding tax provided that the U.S.

Shareholder is the beneficial owner of the dividends received and does not

have an enterprise or an interest in an enterprise that is, in whole or in

part, carried on through a permanent establishment or permanent

representative in the Netherlands to which the dividends are attributable.

The Treaty also provides for a dividend withholding tax exemption on

dividends, but only for a shareholder owning directly at least 80.0 percent

of our voting power and meeting all other requirements.

Provided that certain conditions are met, under the Treaty dividends paid

to qualifying exempt pension trusts and other qualifying exempt

organizations, as defined in the Treaty, are exempt from Dutch dividend

withholding tax. To obtain a refund of the tax withheld such qualifying

exempt pension trusts are required to file a request. Only if certain

conditions are fulfilled, such qualifying exempt pension trusts may be

eligible for relief at source upon payment of the dividend. Qualifying

exempt organizations (other than qualifying exempt pension trusts) can

only file for a refund of the tax withheld.

Anti-dividend stripping rules

Pursuant to the Dutch anti-dividend stripping rules, in the case of dividend-

stripping, the 15% dividend withholding tax cannot be reduced or

refunded. Dividend-stripping is deemed to be present if the recipient of a

dividend is, contrary to what has been assumed above, not the beneficial

owner thereof and is entitled to a larger credit, reduction or refund of

dividend withholding tax than the beneficial owner of the dividends. Under

these rules, a recipient of dividends will not be considered the beneficial


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	114

owner thereof if as a consequence of a combination of transactions a

person other than the recipient wholly or partly benefits from the

dividends, whereby such person retains, whether directly or indirectly, an

interest similar to the shares on which the dividends were paid.

Credit for ING Groep N.V.

ING Groep N.V. may, with respect to certain dividends received from

qualifying non-Netherlands subsidiaries, credit taxes withheld from those

dividends against the Netherlands withholding tax imposed on certain

qualifying dividends that are redistributed by ING Groep N.V., up to a

maximum of the lesser of:

§3% of the amount of qualifying dividends redistributed by ING Groep

N.V.; and

§3% of the gross amount of certain qualifying dividends received by ING

Groep N.V.

The reduction is applied to the Dutch dividend withholding tax that ING

Groep N.V. must pay to the Dutch tax authorities and not to the Dutch

dividend withholding tax that ING Groep N.V. must withhold.

Dutch conditional withholding tax

From 1 January 2024 onwards, in addition to Dutch dividend withholding

tax, Dutch conditional withholding tax may apply at a statutory rate of

25.8% on dividends and other (deemed) distributions to certain affiliated

(gelieerde) entities of ING Groep N.V. for the purpose of the Dutch

Withholding Tax Act 2021 (Wet bronbelasting 2021).

The Dutch conditional withholding tax only applies on dividends and other

(deemed) distributions to entities that are resident (gevestigd), or have a

permanent establishment to which the dividend or distribution is

attributable, in a jurisdiction that is listed in the yearly updated Dutch

Regulation on low-taxing states and non-cooperative jurisdictions for tax

purposes (Regeling laagbelastende staten en niet-coöperatieve

rechtsgebieden voor belastingdoeleinden), and in certain deemed abusive

situations.

An entity is generally affiliated within the meaning of the Dutch

Withholding Tax Act 2021 if there is a controlling relationship between

such entity and ING Groep N.V.

Taxes on income and capital gains

Income and capital gains

Income and capital gains derived from the Ordinary Shares or ADSs by an

individual or corporate U.S. Shareholder are generally not subject to

Netherlands income tax or corporation tax, unless:

1.such income and gains are attributable to a (deemed) permanent

establishment or (deemed) permanent representative in the

Netherlands of the U.S. Shareholder; or

2.the shareholder is entitled to a share in the profits of an enterprise or

(in case of a non-Dutch resident corporate shareholder only) a co-

entitlement to the net worth of an enterprise, that is effectively

managed in the Netherlands (other than by way of securities) and to

which enterprise the Ordinary Shares or ADSs are attributable; or

3.such income and capital gains are derived from a direct, indirect or

deemed substantial interest in the share capital of ING Groep N.V. (such

substantial interest not being a business asset), and in the case of a

non-Dutch resident corporate shareholder only, that substantial

interest is being held with the primary aim or one of the primary aims

to avoid the levy of income tax from another person and is put in place

without valid economic reasons that reflect economic reality;

4.in case of a non-Dutch resident corporate shareholder, such

shareholder is a resident of Aruba, Curaçao or Saint Martin with a

permanent establishment or permanent representative in Bonaire,

Eustatius or Saba to which the Ordinary Shares or ADS are attributable,

while the profits of such shareholder are taxable in the Netherlands

pursuant to Article 17(3)(c) of the Dutch Corporate Tax Act 1969; or

5.in case of a non-Dutch resident individual, such individual derives

income or capital gains from the Ordinary Shares or ADSs that are

taxable as benefits from ‘miscellaneous activities’ in the Netherlands

(‘resultaat uit overige werkzaamheden’, as defined in the Dutch Income

Tax Act 2001), which includes the performance of activities with respect

to the Ordinary Shares or ADSs that exceed regular portfolio

management.

Substantial interest

Generally speaking, for Dutch tax purposes, an interest in the share capital

of ING Groep N.V., should not be considered a substantial interest if the

holder of such interest, and, in case of an individual, his or her spouse,

registered partner, certain other relatives or certain persons sharing the

holder’s household, alone or together, does or do not hold, either directly

or indirectly, the ownership of, or certain rights over, shares or rights

resembling shares representing 5% or more of the total issued and

outstanding capital, or the issued and outstanding capital of any class of

shares, of ING Groep N.V.

Gift or inheritance tax

No Netherlands gift or inheritance tax will be imposed on the transfer or

deemed transfer of the Ordinary Shares or ADSs by way of a gift by or on

the death of a U.S. Shareholder if, at the time of the gift or the death of

that shareholder, such shareholder is not a (deemed) resident of the

Netherlands.

Netherlands inheritance or gift taxes (as the case may be) are due,

however, if the transfer of the Ordinary Shares or ADSs is construed as an

inheritance or as a gift made by or on behalf of a person who, at the time

of the gift or death, is deemed to be a resident of the Netherlands. For the

purposes of Netherlands gift or inheritance tax, an individual of Dutch

nationality is deemed to be a resident of the Netherlands if he or she has

been a resident thereof at any time during the ten years preceding the

time of the gift or death. For the purposes of Netherlands gift tax, any

person is deemed to be a resident of the Netherlands if he or she has

resided therein at any time in the twelve months preceding the gift.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	115

United States Taxation

Taxes on dividends

The tax treatment of owning Ordinary Shares or ADSs will depend in part

on whether or not ING Groep N.V. is classified as a passive foreign

investment company, or PFIC, for United States federal income tax

purposes. Except as discussed below under “-PFIC Rules”, this discussion

assumes that ING Groep N.V. is not classified as a PFIC for United States

federal income tax purposes.

Under the United States federal income tax laws, a U.S. Shareholder will be

required to include in gross income the gross amount of a cash dividend

(including any Netherlands withholding tax withheld) as ordinary income

when the dividend is actually or constructively received by the U.S.

Shareholder in the case of Ordinary shares, or by the Depositary, in the

case of ADSs. For this purpose, a “dividend” will include any distribution

paid by ING Groep N.V. with respect to the Ordinary Shares or ADSs, but

only to the extent such distribution is not in excess of ING Groep N.V.’s

current and accumulated earnings and profits as determined for United

States federal income tax purposes. Distributions in excess of current and

accumulated earnings and profits, as determined for United States federal

income tax purposes, will be treated as a non-taxable return of capital to

the extent of a U.S. Shareholder’s basis in the Ordinary Shares or ADSs and

thereafter as capital gain. Because ING Groep N.V. does not keep account

of its earnings and profits, as determined for United States federal income

tax purposes, U.S. Shareholders should generally expect to treat any

distribution as a dividend for U.S. federal income tax purposes.

For foreign tax credit limitation purposes, dividends will generally be

income from sources outside the United States and will, depending on the

circumstances of the U.S. Shareholder, generally be “passive” income for

purposes of computing the foreign tax credit allowable to the shareholder.

However, if (a) we are 50% or more owned, by vote or value, by United

States persons and (b) at least 10% of our earnings and profits are

attributable to sources within the United States, then for foreign tax credit

purposes, a portion of our dividends would be treated as derived from

sources within the United States. With respect to any dividend paid for any

taxable year, the United States source ratio of our dividends for foreign tax

credit purposes would be equal to the portion of our earnings and profits

from sources within the United States for such taxable year, divided by the

total amount of our earnings and profits for such taxable year.

A dividend will not be eligible for the dividends-received deduction

generally allowed to U.S. corporations in respect of dividends received

from other U.S. corporations. Dividends paid to a non-corporate U.S.

Shareholder that are considered qualified dividend income will be taxable

to the shareholder at preferential rates applicable to long-term capital

gains provided that the shareholder holds the Ordinary Shares or ADSs for

more than 60 days during the 121-day period beginning 60 days before

the ex-dividend date and meets other holding period requirements.

Dividends paid by ING Groep N.V. with respect to the Ordinary Shares or

ADSs generally will be qualified dividend income, provided that, in the year

that you receive the dividend, we are eligible for the benefits of the Treaty.

We believe that we are currently eligible for the benefits of the Treaty and

we therefore expect that dividends on the Ordinary Shares or ADSs will be

qualified dividend income, but there can be no assurance that we will

continue to be eligible for the benefits of the Treaty.

Subject to certain limitations, a U.S. Shareholder may generally deduct

from income, or credit against its United States federal income tax liability,

the amount of any Netherlands withholding taxes withheld under the

Treaty and paid over to the Netherlands Tax Administration. However, the

Netherlands withholding tax may not be creditable unless a U.S.

Shareholder is eligible for and elects to apply the benefits of the Treaty.

Even in such case, the Netherlands withholding tax will likely not be

creditable against the U.S. Shareholder’s United States tax liability to the

extent that ING Groep N.V. is allowed to reduce the amount of dividend

withholding tax paid over to the Netherlands Tax Administration by

crediting withholding tax imposed on certain dividends paid to ING Groep

N.V. In addition, special rules apply in determining the foreign tax credit

limitation with respect to dividends that are subject to preferential rates.

To the extent a reduction or refund of the tax withheld is available to a U.S.

Shareholder under Dutch law or under the Treaty, the amount of tax

withheld that could have been reduced or is refundable will not be eligible

for credit against the U.S. Shareholder's United States federal income tax

liability. In addition, to the extent an amount of Dutch tax withheld is

contingent on the availability of a credit against the amount of income tax

owed to another country, that amount of Dutch tax withheld will not be

eligible for a credit against the U.S. Shareholder's United States federal

income tax liability. It is unclear whether or how the Netherlands would

apply this rule in determining whether, based on the Treaty, a credit is

available in the United States for purposes of the dividend withholding tax

refund provision described in Section IV under “Netherlands Taxation—

Withholding tax on dividends—Reduction of Dutch dividend withholding

tax based on Dutch law”.

Since payments of dividends with respect to Ordinary Shares or ADSs will

be made in Euros, a U.S. Shareholder will generally be required to

determine the amount of dividend income by translating the Euro into U.S.

dollars at the “spot rate” on the date the dividend is distributed, regardless

of whether the payment is in fact converted into U.S. dollars. Generally,

any gain or loss resulting from currency exchange fluctuations during the

period from the date the dividend is distributed to the date such payment

is converted into U.S. dollars will be treated as ordinary income or loss and

will not be eligible for the special tax rate applicable to qualified dividend

income. Such gain or loss will generally be income or loss from sources

within the United States for foreign tax credit limitation purposes.

Taxes on capital gains

Gain or loss on a sale or exchange of Ordinary Shares or ADSs by a U.S.

Shareholder will generally be a capital gain or loss for United States federal

income tax purposes equal to the difference between the U.S. dollar value

of the amount that such U.S. Shareholder realizes and such U.S.

Shareholder's tax basis, determined in U.S. dollars, in the Ordinary Shares

or ADSs. If such U.S. Shareholder has held the Ordinary Shares or ADSs for

more than one year, such gain or loss will generally be long-term capital

gain or loss. Long-term capital gain of a non-corporate U.S. Shareholder is

generally taxed at preferential rates. In general, gain or loss from a sale or

exchange of Ordinary Shares or ADSs by a U.S. Shareholder will be treated

as income or loss from sources within the United States for foreign tax

credit limitation purposes.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	116

PFIC rules

ING Groep N.V. believes it is not a PFIC for United States federal income tax

purposes, and it does not expect to become a PFIC in the foreseeable

future. However, this conclusion is a factual determination that must be

made annually and thus may be subject to change. It is therefore possible

that we could become a PFIC in a future taxable year.

If ING Groep N.V. were to be treated as a PFIC, unless a U.S. Shareholder

made an effective election to be taxed annually on a mark-to-market

basis with respect to the Ordinary Shares or ADSs, any gain from the sale

or disposition of Ordinary Shares or ADSs by a U.S. Shareholder would be

allocated ratably to each year in the holder’s holding period and would be

treated as ordinary income. Tax would be imposed on the amount

allocated to each year prior to the year of disposition at the highest rate in

effect for that year, and interest would be charged at the rate applicable

to underpayments on the tax payable in respect of the amount so

allocated. The same rules would apply to “excess distributions”, defined

generally as any distributions in a single taxable year, other than the

taxable year in which the U.S. Shareholder's holding period in the shares or

ADSs begins, exceeding 125% of the average annual distribution made by

ING Groep N.V. in respect of the Ordinary Shares or ADSs over the shorter

of the three preceding taxable years or the portion of the holder’s holding

period that preceded the taxable year in which the holder receives the

distribution. Dividends received by a U.S. Shareholder will not be eligible for

the special tax rates applicable to qualified dividend income if ING Groep

N.V. were a PFIC (or were to be treated as a PFIC with respect to the

shareholder) either in the taxable year of the distribution or the preceding

taxable year, but instead will be taxable at rates applicable to ordinary

income. A U.S. Shareholder who owns Ordinary Shares or ADSs during any

year that ING Groep N.V. is a PFIC may be required to file Internal Revenue

Service Form 8621.

F.Dividends and paying agents

This item does not apply to annual reports on Form 20-F.

G.Statement by experts

This item does not apply to annual reports on Form 20-F.

H.Documents on display

ING Groep N.V. is subject to the informational requirements of the

Securities Exchange Act of 1934, as amended. In accordance with these

requirements, ING Groep N.V. files reports and other information with the

Securities and Exchange Commission (”SEC”). These materials, including

this Annual Report and its exhibits, may be inspected and copied on the

SEC’s website at www.sec.gov. You may also inspect ING Groep N.V.’s SEC

reports and other information on the website of ING Groep N.V.

(www.ing.com).

I.Subsidiary information

This item does not apply to annual reports on Form 20-F.

J.Annual Report to Security Holders

Not applicable.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	118

Item 12. Description of Securities other than

Equity Securities

A.Debt securities

This item does not apply to annual reports on Form 20-F.

B.Warrants and rights

This item does not apply to annual reports on Form 20-F.

C.Other securities

This item does not apply to annual reports on Form 20-F.

D.American depositary shares

Fees and Charges Payable by a Holder of ADSs

JPMorgan Chase Bank, N.A., as ADR depositary, may collect fees for, among other things, the delivery and

surrender of ADSs directly from investors, or from intermediaries acting for them, depositing Ordinary Shares or

surrendering ADSs for the purpose of withdrawal.

The charges of the ADR depositary payable which may be payable by investors are as follows:


Type of Service	ADR Depositary Actions	Fee Payable
Depositing or substituting the underlying Ordinary Shares	Issuance of ADSs against the deposit of Ordinary Shares, including deposits and issuances in respect of: §share distributions, rights and other distributions. §a stock dividend or stock split. §a merger, exchange of securities or other transactions or events affecting the ADSs or the underlying Ordinary Shares.	$5.00 for each 100 ADSs (or portion thereof) issued, delivered or upon which a share distributive or elective distribution is made or offered. The ADR depositary may sell sufficient securities or property received in respect of share distributions, rights and other distributions prior to such deposit to pay such charge.
Receiving or distributing cash dividends	Distribution of cash dividends or other cash distributions, or offering of elective cash/stock dividends.	$0.05 or less per ADS held.


Selling or exercising rights	§additional ADRs resulting from a dividend or free distribution consisting of Ordinary Shares, or U.S dollars resulting from sales of Ordinary Shares received in a distribution. §Instruments representing rights to acquire additional ADRs as a result of distribution on Ordinary Shares, or U.S dollars resulting from sales of such rights. §other securities available to the ADR depositary resulting from any distribution on the deposited Ordinary Shares, or U.S dollars resulting from sales of such other securities.	An amount equal to the fee for the execution and delivery of ADSs which would have been charged as a result of the deposit of such securities.

Withdrawing an underlying Ordinary Share	Acceptance of ADSs surrendered for withdrawal of deposited Ordinary Shares	$5.00 for each 100 ADSs (or portion thereof) reduced, cancelled or surrendered.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	119


Type of Service	ADR Depositary Actions	Fee Payable
Transferring, splitting or grouping of ADRs	Registration, registration of transfer, combination and split-up of ADRs in the ADR register as evidenced by the ADRs surrendered or upon delivery of proper instruments of transfer	$1.50 per ADR.
General depositary services, particularly those charged on an annual basis	Other services performed by the ADR depositary in administering the ADR program	$0.05 per ADS per calendar year (or portion thereof), which may be charged on a periodic basis during each calendar year against holders of the record date(s) set by the ADR depositary and shall be payable at the sole discretion of the ADR depositary by billing such holders or deducting such charge from one or more cash distributions.

Reimbursement of fees, charges and expenses of the ADR depositary	The ADR depositary and/or any of its agents may incur fees, charges and expenses (including expenses incurred on behalf of holders of ADRs in connection with compliance with foreign exchange control regulations or any law or regulation relating to foreign investment) in connection with the servicing of the underlying Ordinary Shares or other deposited securities, the sale of securities (including, without limitation, deposited securities), the delivery of deposited securities or otherwise in connection with the ADR depositary’s compliance with applicable law, rule or regulation.	Fees and charges shall be assessed on a proportionate basis against holders of ADRs as of the record date or dates set by the ADR depositary and shall be payable at the sole discretion of the ADR depositary by billing such holders of ADRs or by deducting such charge from one or more cash dividends or other cash distributions.


Type of Service	ADR Depositary Actions	Fee Payable
Other charges and expenses of the ADR depositary	The ADR depositary may incur charges and expenses on behalf of holders in connection with: §stock transfer or other taxes and other governmental charges. §SWIFT, cable, telex and facsimile transmission and delivery charges incurred at the request of persons §depositing, or holders of ADRs delivering underlying Ordinary Shares, ADRs or deposited securities. §transfer or registration fees for the registration or transfer of deposited securities.	Payable by holders or persons depositing Ordinary Shares. Payable by persons depositing, or holders of ADRs delivering underlying Ordinary Shares, Ads or deposited securities. Payable by persons depositing or withdrawing deposited securities.

Fees and Payments made by the ADR depositary to ING

In consideration for acting as depositary, the ADR depositary has agreed to provide ING with certain amounts on

an annual basis. In the year ended 31 December 2025, the ADR depositary paid aggregate fees and made other

direct and indirect payments to ING in an amount of USD 6,092,292.

Under certain circumstances, including removal of the ADR depositary or termination of the ADR program by ING,

ING is required to repay the ADR depositary certain amounts reimbursed and/or expenses paid to or on behalf of

ING.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	122

Item 15. Controls and Procedures

Internal control over financial reporting

Due to the listing of ING shares on the New York Stock Exchange, ING

Group is required to comply with the SEC regulations adopted pursuant to

Section 404 of the Sarbanes-Oxley Act (SOX 404). These regulations require

that the Chief Executive Officer (“CEO”) and the Chief Financial Officer

(“CFO”) of ING Group report and certify on an annual basis on the

effectiveness of ING Group’s internal control over financial reporting.

Moreover, the external auditors are required to provide an opinion on the

effectiveness of ING Group’s internal control over financial reporting.

SOX 404 activities are organised along the lines of the governance

structure and involve the participation of senior management across ING.

Following the SOX 404 process, ING is in the position to publish an

unqualified statement that the Company’s internal control over financial

reporting was effective as of 31 December 2025. The SOX 404 statement

by the Executive Board is included on this page, followed by the report of

the external auditor as issued on Form 20-F.

Disclosure Controls and Procedures

The Company’s management, under the supervision and with the

participation of the CEO and CFO, has performed an evaluation of the

effectiveness of the design and operation of the Company’s disclosure

controls and procedures. Based on that evaluation, the CEO and CFO

concluded that the Company’s disclosure controls and procedures were

effective as of December 31, 2025, the end of the period covered by the

2025 Form 20-F.

Report of the Executive Board on Internal Control Over Financial

Reporting

The Executive Board is responsible for establishing and maintaining

adequate internal control over financial reporting. ING’s internal control

over financial reporting is a process designed under the supervision of our

principal executive and principal financial officers to provide reasonable

assurance regarding the reliability of financial reporting and the

preparation of financial statements for external purposes in accordance

with generally accepted accounting principles.

Our internal control over financial reporting includes those policies and

procedures that:

§Pertain to the maintenance of records that, in reasonable detail,

accurately and fairly reflect the transactions and dispositions of assets

of ING;

§Provide reasonable assurance that transactions are recorded as

necessary to permit preparation of financial statements in accordance

with generally accepted accounting principles, and that our receipts

and expenditures are being made only in accordance with

authorisations of our management and directors; and

§Provide reasonable assurance regarding prevention or timely detection

of unauthorised acquisition, use or disposition of our assets that could

have a material effect on our financial statements.

Because of its inherent limitations, internal control over financial reporting

may not prevent or detect misstatements. Also, projections of any

evaluation of effectiveness to future periods are subject to the risk that

controls may become inadequate because of changes in conditions, or

that the degree of compliance with the policies or procedures may

deteriorate.

The Executive Board assessed the effectiveness of internal control over

financial reporting as of 31 December 2025. In making this assessment,

the Executive Board performed tests based on the criteria of the

Committee of Sponsoring Organizations of the Treadway Commission

(“COSO”) in Internal Control – Integrated Framework (2013 Framework).

Based on the Executive Board’s assessment and those criteria, the

Executive Board concluded that the Company’s internal control over

financial reporting was effective as of 31 December 2025.

Attestation Report of the Registered Public Accounting Firm

Our independent registered public accounting firm has audited and issued

their report on ING’s internal control over financial reporting, which

appears on the page below.

Changes in Internal Controls over Financial Reporting

There have been no changes in the Company’s internal controls over

financial reporting during the period covered by this Annual Report that

have materially affected or are reasonably likely to materially affect, our

internal control over financial reporting.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	123

Report of Independent Registered Public Accounting Firm

To the Shareholders and the Supervisory Board ING Groep N.V.

Opinion on Internal Control Over Financial Reporting

We have audited ING Groep N.V. and subsidiaries’ (the Company) internal

control over financial reporting as of December 31, 2025, based on criteria

established in Internal Control – Integrated Framework (2013) issued by

the Committee of Sponsoring Organizations of the Treadway Commission.

In our opinion, the Company maintained, in all material respects, effective

internal control over financial reporting as of December 31, 2025, based on

criteria established in Internal Control – Integrated Framework (2013)

issued by the Committee of Sponsoring Organizations of the Treadway

Commission.

We also have audited, in accordance with the standards of the Public

Company Accounting Oversight Board (United States) (PCAOB), the

consolidated statements of financial position of the Company as of

December 31, 2025 and 2024, the related consolidated statements of

profit or loss, comprehensive income, changes in equity, and cash flows for

each of the years in the three-year period ended December 31, 2025, and

the related notes and specific disclosures described in Note 1 as being part

of the consolidated financial statements (collectively, the consolidated

financial statements), and our report dated February 23, 2026 expressed

an unqualified opinion on those consolidated financial statements.

Basis for Opinion

The Company’s management is responsible for maintaining effective

internal control over financial reporting and for its assessment of the

effectiveness of internal control over financial reporting, included in the

accompanying Report of the Executive Board on Internal Control Over

Financial Reporting. Our responsibility is to express an opinion on the

Company’s internal control over financial reporting based on our audit. We

are a public accounting firm registered with the PCAOB and are required to

be independent with respect to the Company in accordance with the U.S.

federal securities laws and the applicable rules and regulations of the

Securities and Exchange Commission and the PCAOB.

We conducted our audit in accordance with the standards of the PCAOB.

Those standards require that we plan and perform the audit to obtain

reasonable assurance about whether effective internal control over

financial reporting was maintained in all material respects. Our audit of

internal control over financial reporting included obtaining an

understanding of internal control over financial reporting, assessing the

risk that a material weakness exists, and testing and evaluating the design

and operating effectiveness of internal control based on the assessed risk.

Our audit also included performing such other procedures as we

considered necessary in the circumstances. We believe that our audit

provides a reasonable basis for our opinion.

Definition and Limitations of Internal Control Over Financial Reporting

A company’s internal control over financial reporting is a process designed

to provide reasonable assurance regarding the reliability of financial

reporting and the preparation of financial statements for external

purposes in accordance with generally accepted accounting principles. A

company’s internal control over financial reporting includes those policies

and procedures that (1) pertain to the maintenance of records that, in

reasonable detail, accurately and fairly reflect the transactions and

dispositions of the assets of the company; (2) provide reasonable

assurance that transactions are recorded as necessary to permit

preparation of financial statements in accordance with generally accepted

accounting principles, and that receipts and expenditures of the company

are being made only in accordance with authorizations of management

and directors of the company; and (3) provide reasonable assurance

regarding prevention or timely detection of unauthorized acquisition, use,

or disposition of the company’s assets that could have a material effect on

the financial statements.

Because of its inherent limitations, internal control over financial reporting

may not prevent or detect misstatements. Also, projections of any

evaluation of effectiveness to future periods are subject to the risk that

controls may become inadequate because of changes in conditions, or

that the degree of compliance with the policies or procedures may

deteriorate.

/s/ KPMG Accountants N.V.

Utrecht, The Netherlands

February 23, 2026


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	126

Item 16C. Principal Accountant Fees and Services

At the Annual General Meeting held on 24 April 2023, KPMG (KPMG

Accountants N.V. in Amstelveen, the Netherlands – PCAOB ID: 1012) was

re-appointed as the external audit firm for ING Group for the financial

years 2024 and 2025 which is the maximum term for KPMG as the external

auditor. This appointment includes the responsibility to provide an audit

opinion on the financial statements and internal control over financial

reporting on 31 December 2025 and to report on the outcome of these

audits to the Executive Board and the Supervisory Board.

The external auditor may be questioned at the Annual General Meeting in

relation to its audit opinion on the financial statements. The external

auditor will therefore attend and be entitled to address this meeting. The

external auditor attended the meetings of the Risk Committee and of the

Audit Committee and attended and addressed the 2024 Annual General

Meeting, at which the external auditor provided an explanation on the

audit activities and the audit opinion.

The external auditor may only provide services to ING Group and its

subsidiaries with the permission of the Audit Committee, in line with the

ING Group Global Procedure on External Auditors’ Independence. All

services were approved by the Audit Committee.

More information on the ING Group Global Procedure on External Auditors’

Independence is available on the website of ING Group www.ing.com.

Audit fees

Audit fees were paid for audit and assurance services provided by the

auditors. The services provided include the audit of ING Group’s

consolidated financial statements and Form 20-F. Moreover, these services

include the audits of the statutory financial statements of its subsidiaries.

And, it includes assurance services provided by the auditor regarding other

filings for regulatory and supervisory purposes as well as the review on

interim financial statements. Furthermore, it includes the assurance

services relating to comfort letters issued in connection with prospectuses

and reviews of SEC product filings.

Audit-related fees

Audit-related fees were paid for assurance and related services that are

reasonably related to the performance of the audit or review of the

consolidated financial statements not reported under the audit fee item

above. These services consisted primarily of specific agreed-upon

procedure engagements and assurance engagements for third parties.

Tax fees

Over 2025 no tax fees were paid. Under the current ING Group Global

Procedure on External Auditors’ Independence most tax services are

prohibited. Some tax services are only allowed after specific approval

under an ‘exception procedure’.

Reference is made to Note 27 ‘Audit fees’ in the consolidated financial

statements for audit, audit-related, tax and all other fees paid to the

external auditors in 2025, 2024 and 2023.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	128

Item 16E. Purchases of Equity Securities by the Issuer

and Affiliated Purchasers

Share buyback programmes executed in 2025

On 30 October 2025, ING announced a shareholder distribution of up to

EUR 1,600 million. The distribution consists of a share buyback programme

for a maximum total amount of EUR 1,100 million and a cash payment of

EUR 500 million. The share buyback programme is expected to end no

later than 27 April 2026. The total number of ordinary shares repurchased

under the programme in 2025 is 17,537,269 at an average price of EUR

22.62 for a total consideration of EUR 397 million. The EUR 500 million in

cash has been paid on 15 January 2026.

On 2 May 2025, ING announced a share buyback programme under which

it planned to repurchase ordinary shares of ING Groep N.V., for a maximum

total amount of EUR 2,000 million. The share buyback programme was

completed on 27 October 2025. The total number of ordinary shares

repurchased under the programme is 101,193,469 at an average price of

EUR 19.77 for a total consideration of EUR 2,000 million. The purchases

exceeded 100% due to performance arrangements with our executing

broker for the programme. The broker repurchased shares until the

performance arrangements were fulfilled. The total consideration for ING

was limited to EUR 2,000 million. The excess purchases above this amount

were funded by the executing broker. Based on the total programme

period, the effective average price for ING was EUR 19.76.

On 3 March 2025, ING announced a share buyback programme for a

maximum total amount of EUR 70 million. The share buyback programme

was executed by ING and completed on 4 March 2025. The total number of

shares repurchased under the programme is 3,674,043 ordinary shares at

an average price of EUR 17.44 for a total consideration of EUR 64 million.

The purpose of the share repurchase programme was to meet obligations

under the share-based compensation plans. After fulfilling delivery

obligations under the employee share-based compensation scheme, the

buyback programme had negligible impact on our CET1 ratio.

On 31 October 2024, ING announced a shareholder distribution of up to

EUR 2,500 million. The distribution consists of a share buyback programme

for a maximum total amount of EUR 2,000 million and an additional cash

distribution of EUR 500 million. The share buyback programme was

completed on 30 April 2025. The total number of ordinary shares

repurchased under the programme in 2025 is 75,371,667 at an average

price of EUR 16.42 for a total consideration of EUR 1,238 million. The shares

have been cancelled in July 2025.

General

All share buyback programmes have been approved by the ECB and were

executed within the limitations of the existing authority of a maximum of

20% of the issued shares as granted by the general meeting of

shareholders on 22 April 2025 and 22 April 2024 in compliance with the

Market Abuse Regulation. For each buyback, ING entered into a non-

discretionary arrangement with a financial intermediary to conduct the

buybacks except for the share repurchase programmes for the employee

share-based compensation plans which were executed by ING.

ING Groep N.V. has no other publicly announced plans or programmes to

repurchase shares. In 2025, ING Groep N.V. did not determine to terminate

any publicly announced plans or programmes prior to expiration, or

determine that it intends not to make any further purchases under any

publicly announced plans or programmes.

There were no other purchases by us or any of our affiliated purchasers of

any of our equity securities registered pursuant to Section 12 of the

Securities Exchange Act of 1934 during the fiscal years ended December

31, 2025 and 2024.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	129


Purchases of Equity Securities by the Issuer and affiliated Purchasers
Month of purchase	Total number of shares purchased1	Average price paid per share in EUR	Total number of shares purchased as part of publicly announced plans or programmes 2, 3, 4, 5	Maximum Value of shares that may yet be purchased under the plans or programmes in EUR million
January 2025	18,026,522	15.62	18,026,522	963
February 2025	17,005,344	16.20	17,005,344	687
March 2025	14,701,980	18.19	14,701,980	484
April 2025	29,311,864	16.29	29,311,864
May 2025	20,055,856	18.49	20,055,856	1,629
June 2025	20,176,361	18.20	20,176,361	1,262
July 2025	11,872,104	19.63	11,872,104	1,029
August 2025	15,542,589	20.34	15,542,589	713
September 2025	17,582,981	21.35	17,582,981	337
October 2025	17,136,494	21.19	17,136,494	1,074
November 2025	8,499,025	22.04	8,499,025	887
December 2025	7,865,328	23.35	7,865,328	703
Total	197,776,448	18.70	197,776,448
Of which:
Purchased in the open market	197,776,448	18.70	197,776,448	703
Acquired through exercise of call options / settlement of forward contracts	n.a.	n.a.	n.a.	n.a.

1The table excludes purchases on behalf of clients in ING Groep N.V. shares.

2On 30 October 2025, ING announced a share buyback programme for a maximum total amount of EUR 1,600 million. The distribution consists of a share

buyback programme for a maximum total amount of EUR 1,100 million and a cash payment of EUR 500 million. The share buyback programme is

expected to end no later than 27 April 2026. The EUR 500 million in cash has been paid on 15 January 2026. The total number of shares repurchased in

2025 under the programme is 17,537,269 ordinary shares at an average price of EUR 22.62 per share for a total consideration of EUR 397 million with

EUR 703 million remaining to be purchased in 2026. The programme is executed by an intermediary to allow for purchases in the open market during

both open and closed periods. The purpose of the additional distribution is to converge our CET1 ratio towards our target of ~13%.

3On 2 May 2025, ING announced a share buyback programme for a maximum total amount of EUR 2,000 million. The programme was completed on 27

October 2025. The total number of shares repurchased under the programme is 101,193,469 ordinary shares at an average price of EUR 19.77 per share

for a total consideration of EUR 2,000 million. The programme is executed by an intermediary to allow for purchases in the open market during both

open and closed periods. The purchases exceeded 100% due to performance arrangements with our executing broker for the programme. The broker

repurchased shares until the performance arrangements were fulfilled. The total consideration for ING was limited to EUR 2,000 million. The excess

purchases above this amount were funded by the executing broker. Based on the total programme period, the effective average price for ING was EUR

19.76. The purpose of the share buyback programme is to converge our CET1 ratio towards our target of ~13%. The shares have been cancelled in

January 2026.

4On 3 March 2025, ING announced a share buyback programme for EUR 70 million. The programme was completed on 4 March 2025. The total number of

shares repurchased under the programme is 3,674,043 ordinary shares at an average price of EUR 17.44 per share for a total consideration of EUR 64

million. The programme is executed by ING during a two day period. The purpose of the share buyback programme was to meet obligations under the

employee share-based compensation plans.

5On 31 October 2024, ING announced an additional distribution for a maximum total amount of EUR 2,500 million. The distribution consists of a share

buyback programme for a maximum total amount of EUR 2,000 and a cash payment of EUR 500 million. The share buyback programme was completed

on 30 April 2025. The total number of shares repurchased under the programme in 2025 is 75,371,667 ordinary shares at an average price of EUR 16.42

per share for a total consideration of EUR 1,238 million with EUR 708 million purchased in 2024. The programme is executed by an intermediary to allow

for purchases in the open market during both open and closed periods. The shares have been cancelled in July 2025.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	131

Item 16G. Corporate Governance

Dutch Corporate Governance Code, Banking Code

and Dutch Tax Governance Code

As ING Group is established and listed in the Netherlands, it must comply

with Dutch laws and regulations and is subject to the Dutch Corporate

Governance Code (the DCGC).

The DCGC provides guidance for ING’s corporate governance structure and

practices. ING supports the DCGC and its principles to ensure sound

corporate governance within its organisation. ING’s application of the DCGC

is described in the booklet ‘Application of the Dutch Corporate Governance

Code by ING Groep N.V. (FY2025)' dated 26 February 2026, which is

available on ing.com. The DCGC can be downloaded from the website of

the Corporate Governance Monitoring Committee (mccg.nl).

The Dutch Banking Code (the Banking Code) is only applicable to ING Bank,

but ING Group voluntarily applies the principles of the Banking Code on

remuneration for its Executive Board members and senior management.

The Banking Code can be downloaded from the website of the Dutch

Banking Association (nvb.nl). ING Group also voluntarily applies the

principles of the Dutch Tax Governance Code.

Differences between Dutch and US corporate governance

practices

ING Group qualifies as a foreign private issuer under the US Securities and

Exchange Commission (SEC) rules and is permitted to follow home-country

practice in some circumstances, in lieu of certain corporate governance

standards required by the New York Stock Exchange (NYSE) applicable to

US domestic companies. Accordingly, ING Group must disclose in its

Annual Report on Form 20-F any significant differences between its

corporate governance practices and those applicable to US companies

under NYSE listing standards. ING Group believes these differences are the

following:

§ING Group has a two-tier board structure, in contrast to the one-tier

board structure used by most US companies. In the Netherlands, a

public limited liability company with a two-tier board structure has an

executive board as its management body and a supervisory board that

advises and supervises the executive board. Supervisory board

members are often former state or business leaders and sometimes

former members of the executive board. A member of the executive

board or other officer or employee of the company cannot

simultaneously be a member of the supervisory board. The supervisory

board must approve specified decisions of the executive board.

§Under the DCGC, all members of the supervisory board, with the

exception of not more than one person, should be ‘independent’ as

determined under the DCGC. However, the definition of ‘independent’

under the DCGC differs in its details from the definition of ‘independent’

under the NYSE listing standards. All members of ING’s Supervisory

Board are independent as determined under the DCGC.

§NYSE listing standards require a US company to have a compensation

committee and a nominating/corporate governance committee, each

composed entirely of independent directors (as determined under the

NYSE listing standards). ING’s Nomination and Corporate Governance

Committee and Remuneration Committee are composed entirely of

members of the Supervisory Board who are independent as

determined under the DCGC.

§NYSE listing standards require that, when a member of the audit

committee of a US company serves on four or more audit committees

of public companies, the company should disclose (on its website, in its

annual proxy statement or in its annual report filed with the SEC) that

the board of directors has determined this simultaneous service would

not impair the director’s service to the company. Dutch law does not

require the Supervisory Board to make such a determination.

§In contrast to the NYSE listing standards, the DCGC contains a ‘comply-

or-explain’ principle, offering the possibility of deviating from the DCGC.

For any deviations by ING Group, please refer to the paragraph ‘Dutch

Corporate Governance Code, Banking Code and Dutch Tax Governance

Code’.

§NYSE listing standards require external auditors to be appointed by the

audit committee. By contrast, Dutch law requires ING Group’s external

auditors to be appointed by the General Meeting and not by the Audit

Committee. The Audit Committee is responsible for preparing the

Supervisory Board’s nomination to the General Meeting for the

appointment and remuneration of ING Group’s external auditor, and

annually evaluates the independence and functioning of, and

developments in the relationship with, ING Group’s external auditor and

informs the Supervisory Board of its findings and proposed measures.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	132

§Under NYSE listing standards, shareholders of US companies must be

given the opportunity to vote (of which the result is advisory in nature)

on all equity compensation plans applicable to any employee, director

or other service provider of a company (or on material revisions

thereto), with limited exceptions set forth in the NYSE rules. Under

Dutch law and the DCGC, binding shareholder approval is only required

for equity compensation plans (or changes thereto) for members of the

executive board and supervisory board, and not for equity

compensation plans for other groups of employees.

§The NYSE listing standards require certain transactions with related

parties to be reviewed by a company’s audit committee or another

independent body of the board of directors for potential conflicts of

interest, and for the audit committee or other independent body to

prohibit such a transaction if it determines it to be inconsistent with the

interests of the company and its shareholders. However, foreign private

issuers can rely on home country practice with respect to review and

approval of related party transactions. ING has adopted internal

policies and procedures for the purposes of identifying, assessing, and

recording conflicts of interest, including with respect to whether related

party transactions are on customary or arm’s length terms. These

policies and procedures are intended, if and to the extent required

under applicable law, prudential rules and other applicable guidelines,

to enable the Executive Board and Supervisory Board to assess the

terms of these intended transactions.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	136

Item 16K. Cybersecurity

Introduction

Cybercrime remains a continuous threat to companies in general and to

financial institutions in particular. Both the frequency and the intensity of

attacks continue to increase on a global scale. The sophistication and

implications of ransomware attacks are of particular concern in the threat

landscape. Phishing or email-based social engineering attacks, usually

used to initiate ransomware/malware infection or plant an info/password

stealer for password reuse of valid accounts, or drive-by compromise

attacks. Distributed denial of service attacks, against financial sector and

digital services operators are used for reputational damage and/or

extortion. There has been noticeable increase in supply chain attacks using

compromised 3rd party vendors as a delivery of attack vectors. This

includes abusing cloud misconfigurations to gain access to cloud

infrastructure and applications.

The continuous enhancement of the control environment to protect from-

and detect and respond to- distributed denial-of-service (DDoS), targeted

attacks and more specific ransomware attacks is of the highest priority.

Based on regular scenario analysis done in ING’s first line of defence,

additional defensive controls continue to be embedded in the organisation

as part of the overall internal control framework and are continuously re-

assessed against existing and new threats.

The further digitalisation of banking services, increasing electronic

exchange of information via different consumer channels, use of and

dependency on third-party vendors for services are likely to present

ongoing cybercrime-resilience and IT-security challenges, both in the short

and medium-term. ING continuously invest in fraud awareness and fraud

prevention, detection and response capabilities.

IT and Cyber Risk Assessment and Reporting

To safeguard customer trust and to keep the bank secure the office of the

Chief Information Security Officer (CISO) is predicting, preventing,

detecting, and responding to threats and incidents. Secure architecture,

engineering, and Identity and Access Management are preventive

measures to define, implement and review components that mitigate the

risk of unauthorised access to IT systems and the data processed and

stored therein. Security detection and Response functionality is

implemented to identify and provide timely alerts of malicious behaviour.

Cyber threat assessments delivers awareness about new and existing

threats and vulnerabilities targeting ING infrastructure.

We continued to invest in cybersecurity and third‑party risk controls

aligned with DORA requirements, ensuring greater resilience, operational

continuity, and readiness for the regulatory enforcement timeline.

Different types of cyberthreats are not only relevant for the financial

industry, but are increasingly hitting its supply chains. We are monitoring

these Cybersecurity risks from our suppliers, via the Third-Party Cyber Risk

Management process. This process is part of the generic risk management

framework as defined in the Non-Financial Risk Framework Policies. These

policies are detailed out in a set of Minimum Standards, amongst which

the Security Monitoring Minimum Standard.

The policy documents (policies, minimum standards, process control

standards) identify inherent risks and contain objectives and controls to

mitigate identified inherent risks as well as a section on roles and

responsibilities regarding IT and controls.

The different processes for assessing, identifying, and managing material

risks from cybersecurity threats address the objectives as defined in the

Information and Technology Risk Policy.

The Global CISO and key security positions are held by internal staff. ING

Group IT Audit function is fully internally staffed. The key controls in the

risk management framework relevant for internal control over financial

reporting are being audited by an external auditor.

In addition, ING continues to strengthen its global cybercrime resilience

through collaboration, with financial industry peers, law enforcement

authorities, government (e.g. National Cyber Security Centre) and Internet

Service Providers (ISPs).

Cybersecurity incidents

In 2025, two DDoS incidents were reported to the supervisors: one

impacted the availability of ING banking channels for private individuals in

Belgium, Italy and the Netherlands. The other incident caused temporary

interruptions in third-party service availability in the Polish mobile

payment system. Both incidents were swiftly contained, minimising the

impact to our customers.

We are currently not aware of any threats in our own environment that

are likely to materialise and have a material adverse impact in the near

future.

Cybersecurity Governance

ING's risk and control structure is based on the three lines of defence (“3

LoD”) model. The 3 LoD model aims to provide a sound governance

framework for financial and non-financial risk management by defining

and implementing three risk management ‘layers’, with distinct roles,

execution, and oversight responsibilities. In 2025 the Paradigm Shift

program changed the way IT Risk is reported by implementing the IT Risk

Opinion Reporting process and the increasing use of IT Risk Metrics over

manual Key Control Testing. That has also resulted in defining a Global CoE

IT & Cyber Risk Management within the 1st line Global CISO department


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	137

that owns the IT Risk Opinion process and functionally steers the local 1st

line CoE’s IT & Cyber Risk Management. The Global Information and

Technology Risk department is the 2nd LoD which objectively challenges

the execution in the 1st LoD and 3rd LoD Corporate Audit Services (CAS)

provides an independent assessment of the internal controls.

The IT Risk Opinion Reporting process ensures that local entities report

their IT Risk posture on a quarterly basis using the IT Risk metric results

available on the IT Risk Metric Dashboards (ITRMD) and where needed

additional manual Key Control Testing via the IT Risk Management

Platform (ITRMP). The ITRMD and ITRMP dashboards also enables the local

1st line entities to continuous management of its own control state.

Material deviations found by the 1st LoD or by 2nd LoD (through second-

line monitoring, i.e. quality assurance, risk assessments, etc.) or by the 3rd

LoD (internal IT audits), are monitored by also 2nd LoD and 3rd LoD to

ensure adequate mitigation of issues and risks by 1st LoD. The Global IT

Risk Opinion report, which is the summary of all local IT Risk Opinion

reports, is presented to and discussed with the IT Bank NFRC every quarter.

The Risk monitoring processes, as described, report the cybersecurity risks

to the Bank non-financial risk Committee on a quarterly basis. The 3LoD

reports quarterly (CAS reports) to the Management Board Banking,

Executive Board and Audit Committee including relevant results, details of

the key reports issued during the quarter and the follow-up of reported

findings. The 3LoD Annual Report to the Management Banking Board,

Executive Board and Audit Committee provides the relevant results of the

CAS activities and a CAS’ view on the adequacy and effectiveness of ING’s

processes for controlling its activities and managing its risk in all the areas

of ING.

The Management Board Banking (MBB) and Executive Board (EB) of ING is

informed of key IT / cybersecurity risks on a quarterly basis via Non-

Financial Risk updates, and IT risks are included as well in regular

Integrated Risk updates. In addition, the MBB is immediately informed of

any material cybersecurity incident after it occurred. The Risk Committee

(RiCo) of ING’s Supervisory Board (SB) receives the aforementioned Non-

Financial Risk (NFR) update as well. Whenever a larger cyber incident

occurs, this is in principle also discussed in the RiCo and SB on an ad hoc

basis.

Those quarterly reports are pre-discussed by the Bank Non-Financial Risk

Committee, in which senior NFR/Risk management is represented, before

they are shared with the MBB/EB and RiCo.

Relevant expertise

To ensure that the entire Workforce have appropriate competences and

capabilities to fulfil their assigned tasks and responsibilities, ING developed

Global Job Profiles which are embedded in the Global Job Architecture.

These profiles describe in detail and regularly assess the maturity of the

workforce on required competences and capabilities as well as on

behavioural aspects. Development gaps, if any, are identified quickly,

regularly reviewed, and closed when possible. Relevant training and

certification are being offered by the Tech academy or the local IT

academies to help our employees develop further.

Every year ING enrols a mandatory cybersecurity e-learning to all

countries, covering both in- and external employees. The content is based

on the basic cybersecurity topics, and it is mandatory during the year for

all new onboarded employees as well. The Management Board steers on

92% completeness (due to in/outflow, maternity leaves, illness) this is

proven realistic. During the year there are many global (newsletters) and

local (presentations) initiatives to cover the trending cybersecurity threat

topics.

The annual programme of both EB/MBB and SB include recurring topics

related to IT/ digitalisation, such as IT risk management, operational

resilience, cybersecurity, ransomware, artificial intelligence, data and

analytics development. The Permanent Education Plan complements

these sessions with a curriculum of key priority topics- including IT/

digitalisation - to keep the boards up to date and further strengthen their

knowledge.

The members of the SB have a broad competency in the area of IT &

Cybersecurity, and since 2024 the SB has established a dedicated

Technology & Operations Committee. Cybersecurity updates are provided

to the Technology & Operations Committee (including in combined

sessions with the Risk Committee) by management. In the Management

Board Banking of ING Bank, which has ING Groep as its sole shareholder, a

dedicated Chief Technology Officer role is embedded. The Global Head of

CISO reports directly to the CTO. The CTO is a technology executive with

over 20 years of experience in leadership roles in the financial industry.

The CTO has a strong understanding of data, technology, the application

of it in ING’s operations and the risks related to it.

ING Global CISO is actively involving internal and external stakeholders on

actions to manage cybersecurity relevant measures and impacts. This

includes staff, board members, customers, partners, suppliers,

governments, and regulators. Examples of active involvement are a yearly

mandatory cybersecurity e-learning, covering both in- and external

employees, ING podcasts, webinars and round table sessions with clients

and suppliers, and on our websites we provide useful information to

improve resilience for retail customers.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	146

Capital management

ING’s capital management strategy is designed to

maintain a robust capital position that adequately

covers all material risks, including economic risks,

across the Group, while ensuring compliance with

applicable local and global regulatory

requirements. At the same time, the strategy

supports sustainable value creation for

shareholders and enables ING to serve its clients

and underpin commercial activities. Despite an

uncertain and volatile geopolitical environment,

ING’s capital position remained strong during the

year. At both consolidated and entity levels, ING

maintains sufficient capital buffers to withstand a

range of adverse stress scenarios.

Capital management strategy

Group Treasury (GT) is responsible for maintaining adequate capitalisation

across ING Group and its banking entities to support the management of

risks associated with ING’s business activities. This includes capital

planning, allocation, and management within the Group, as well as the

execution of capital market, term capital funding, and risk management

transactions. ING employs an integrated approach to assessing capital

adequacy, whereby GT considers regulatory and internal economic capital

metrics alongside the interests of key stakeholders, including customers,

shareholders, and rating agencies.

ING applies the following main capital definitions:

§Common Equity Tier 1 (CET1) capital consists of shareholders’ equity

after the correction for applicable regulatory adjustments. The CET1

ratio is calculated as CET1 capital divided by risk-weighted assets

(RWAs).

§Tier 1 capital is defined as CET1 capital plus Additional Tier 1 (AT1)

securities and other regulatory adjustments. The Tier 1 capital ratio is

defined as Tier 1 capital divided by RWAs.

§Total capital consists of Tier 1 capital plus Tier 2 subordinated liabilities,

after regulatory adjustments. The Total capital ratio is calculated as

Total capital divided by RWAs.

§ING’s CET1 target ratio is built on the CET1 requirements specified for

ING, potential increase in the regulatory requirements, the potential

impact of a standardised and predetermined stress scenario and

available mitigating actions, and general uncertainties in its baseline

planning.

§Leverage ratio (LR) is defined as Tier 1 capital divided by the leverage

exposure.

§Minimum Required Eligible Liabilities (MREL)/Total Loss Absorbing

Capacity (TLAC) is Total capital plus senior unsecured bonds and

amortisations. Related MREL and TLAC ratios are expressed relative to

both risk-weighted assets and leverage exposure.

Processes for managing capital

GT ensures adherence to ING’s solvency risk appetite statements by

capital planning and executing capital management transactions. The

ongoing assessment and monitoring of capital adequacy is embedded in

the capital planning process as part of the internal capital adequacy

assessment process (ICAAP) framework. As part of the dynamic business

planning process, ING prepares a capital and funding plan on a regular

basis for all its material businesses, and continuously assesses the timing,

need and feasibility for capital management actions in scope of its

execution strategy. Sufficient financial flexibility should be preserved to

meet important financial objectives. Risk appetite statements are at the

foundation of the capital plan and are cascaded to the different businesses

in line with ING’s risk management framework. Contingency capital

measures and early warning indicators are in place – in conjunction with

ING’s contingency and recovery plan – to support the strategy in times of

stress.

Adverse planning and stress testing, which reflect the outcome of the

annual risk assessment, are integral components of ING’s risk and capital

management framework. It allows us to (i) identify and assess potential

vulnerabilities in ING’s business model, business portfolios or operating

environment; (ii) understand the sensitivities of the core assumptions used

in ING’s strategic and capital plan; and (iii) improve decision-making and

business steering through balancing risk and return following a forward-

looking and prudent management approach.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	147

Capital position as of 31 December 2025


ING Group capital position according to CRR III / CRD V
in EUR million	2025	2024
Shareholders’ equity 1	49,698	50,314
- Interim profits not included in CET1 capital	-2,125	-2,152
- Other adjustments	-3,006	-2,902
Regulatory adjustments	-5,130	-5,054
Available common equity Tier 1 capital	44,567	45,260

Additional Tier 1 securities	7,459	7,965
Regulatory adjustments additional Tier 1	112	66
Available Tier 1 capital	52,138	53,291

Supplementary capital Tier 2 bonds	10,608	9,852
Regulatory adjustments Tier 2	98	50
Available Total capital	62,845	63,194

Risk weighted assets	340,739	333,708

Common equity Tier 1 ratio	13.1%	13.6%
Tier 1 ratio	15.3%	16.0%
Total capital ratio	18.4%	18.9%

1Shareholders' equity is determined in accordance with IFRS-EU.

Capital developments

In 2025, we adjusted our CET1 capital ratio target to ~13% to cater for

higher (expected) capital requirements. Operating at the right level of

capital is in the best interests of all our stakeholders, including our

customers and the economies where we do business. The CET1 target level

of ~13% is well above the prevailing maximum distributable amount (MDA)

level of 11.03% at 31 December 2025, implying a management buffer of

about 195 basis points.

The CET1, Tier 1 and Total capital ratios decreased compared to the end of

2024, primarily due to the continued distribution of CET1 capital to steer

towards the CET1 capital ratio target, as well as higher risk-weighted

assets. ING Group had a CET1 ratio of 13.1% as of 31 December 2025

(13.6% at 31 December 2024). ING Group’s Tier 1 ratio decreased from

16.0% to 15.3% and the Total capital ratio decreased from 18.9% at the

end of 2024 to 18.4% at the end of 2025.

CET1 capital decreased, primarily due to additional distributions, partly

offset by the inclusion of net profit after dividend reserving. Next to the

regular 50% distribution of resilient net profit, ING distributed an additional

€3.6 billion, mostly through share buybacks, to converge towards its

external CET1 target of ~13%. Risk-weighted assets increased by €7.0

billion in 2025, mainly as a result of business growth, partly mitigated by

the RWA relief from significant risk-transfer (SRT) transactions executed in

November. The combined impact from the implementation of CRR III and

other model updates on ING’s CET1 ratio was negligible. At both the

consolidated and entity level, ING has sufficient buffers to withstand

various stressed scenarios.

Risk transfer

ING employs securitisation initiatives as part of its capital management

strategy to achieve effective risk transfer, optimise RWAs, and support

efficient capital allocation. These transactions, which may include

securitisations but also credit insurance, credit derivatives and guarantees,

are executed in accordance with applicable EU regulatory requirements.

ING ensures that securitisation activities meet prudential standards,

maintain the continued effectiveness of risk transfer, and are supported by

a sound economic rationale. In November 2025, ING successfully executed

two significant risk transfer transactions, aligned with these objectives.

Capital velocity initiatives are embedded in ING’s capital planning

processes and are consistent with the Group’s risk appetite and capital

targets.

Dividend and distribution policy

ING’s distribution policy is a pay-out ratio of 50% of resilient net profit.

Resilient net profit is defined as net profit adjusted for significant items not

linked to the normal course of business. The 50% pay-out may be in the

form of cash, or a combination of cash and share repurchases, with the

majority in cash. Additional distributions are to be considered periodically,

taking into account alternative opportunities, macroeconomic

circumstances and the outcome of our capital planning. The prerequisite

for a distribution is a CET1 ratio of at least the prevailing MDA level after

distribution.

For 2025, the resilient net profit amounts €6,327 million, equal to the IFRS-

EU net result, of which €3,164 million was reserved for regular distribution

outside of CET1 capital, reflecting ING’s distribution policy of a 50% pay-

out ratio.

Following ING’s distribution policy of a 50% pay-out ratio on resilient net

profit:

§A final dividend over 2024 of €0.71 per share was paid was paid in May

2025.

§An interim dividend over 2025 of €0.35 per share was paid in August

2025.

§The boards have proposed to pay a final cash dividend over 2025 of

€0.736 per share. This is subject to the approval by shareholders at the

Annual General Meeting on 14 April 2026.

In addition, ING announced two additional distributions of €3.6 billion in

total in 2025:

§An additional distribution of €2.0 billion, by means of a share buyback

programme, was announced on 2 May 2025. Between 2 May 2025 and

27 October 2025, almost 101 million ordinary shares were repurchased

for a total consideration of €2.0 billion.

§An additional distribution of €1.6 billion was announced on 30 October

2025, of which €1.1 billion as a share buyback programme and €0.5

billion as an additional cash distribution. Between 30 October 2025 and

31 December 2025, approximately 17.5 million of ordinary shares were

repurchased for a total consideration of around €0.4 billion.

Regulatory requirements

Capital adequacy and regulatory capital requirements are based on the

standards issued by the Basel Committee on Banking Supervision (the

Basel Committee) and implemented in the European Union Directives

through the Capital Requirements Regulation (CRR) and Capital

Requirements Directive (CRD), as implemented by De Nederlandsche Bank

(DNB) and the European Central Bank (ECB). Under the CRR, the minimum

Pillar 1 capital requirements applicable to ING Group are a CET1 ratio of


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	148

4.5%, a Tier 1 ratio of 6.0%, and a Total capital ratio of 8.0% of

risk‑weighted assets.

The overall SREP CET1 requirement, including buffer requirements, for ING

Group at a consolidated level increased during 2025, mainly due to an

increase of the countercyclical buffer requirement (CCyB), and was 11.03%

at 31 December 2025. This requirement is the sum of a 4.5% Pillar 1

requirement, a 0.93% Pillar 2 requirement, a 2.5% capital conservation

buffer (CCB), a 0.93% CCyB, 0.16% Sectoral Systemic Risk buffer (s-SyRB),

and a 2.0% Other Systemically Important Institutions (O-SII) buffer that is

set separately for Dutch systemic banks by DNB. This requirement

excludes the Pillar 2 guidance, which is not disclosed. ING met the

externally imposed regulatory capital requirements in 2025.

ING’s fully loaded CET1 requirement stood at 11.09% at the end of 4Q2025

(4Q2024: 10.88%), which is higher than the prevailing CET1 ratio

requirement. This reflects an update of the s-SyRB in Belgium, an increase

in the CCyB requirements in Belgium, Poland and Spain, and a higher Pillar

2 requirement.

The MDA trigger level stood at 11.03% per end of 4Q2025 for CET1,

12.84% for Tier 1 Capital, and 15.25% for Total capital. These MDA levels

are in line with the application of Art.104a in CRD V, which allows ING to

partly fulfil the total Pillar 2 requirement with Additional Tier 1 and Tier 2

capital.

An MDA requirement on the leverage ratio of 3.5% applies to ING Group. In

the event that ING Group breaches an MDA level, ING may face restrictions

on dividend payments, coupons on AT1 securities and payment of variable

remuneration.

MREL and TLAC requirements

The minimum requirement for own fund and eligible liabilities (MREL) and

total loss absorbing capacity (TLAC) apply to ING Group at the consolidated

level of the resolution group. MREL and TLAC provide additional capacity to

absorb losses and facilitate recapitalisation in the case of resolution. ING

Group has a single point of entry resolution strategy.

MREL requirements, including buffer requirements, were 28.22% on RWA

and 7.24% on leverage exposure as of December 2025. TLAC requirements

were 23.60% of RWA and 6.75% of leverage exposure as of December

2025. ING meets these MREL/TLAC requirements with a MREL/TLAC ratio of

31.8% on RWA and 9.4% on leverage exposure at the end of December

2025. MREL is for ING Group more binding than TLAC.

Regulatory developments

In 2024, the European Union adopted CRR III and CRD VI, implementing the

finalised Basel III framework. These regulations became effective as from 1

January 2025, with several elements subject to phased implementation. In

particular, the output floor will be introduced gradually over a multi‑year

period, with certain transitional provisions extending through 2032.

CRR III impacts RWA measurement through:

§enhancing the robustness and/ or risk sensitivity of the standardised

approaches for credit risk, credit valuation adjustment (CVA) risk, and

operational risk;

§constraining the use of the internal model approaches by placing limits

on certain inputs used to calculate capital requirements under the

internal ratings-based (IRB) approach for credit risk, and by removing

the use of the internal model approaches for CVA risk and for

operational risk; and

§the introduction of a risk-sensitive output floor based on the

standardised approaches.

Ratings

ING’s credit ratings and outlook are shown in the table below. Each of

these ratings only reflects the view of the applicable rating agency at the

time the rating was issued. Any explanation of the significance of a rating

may only be obtained from the rating agency. Scope has been added as

fourth rating agency in 2025, with comparable credit ratings.


Main credit ratings of ING at 31 December 2025
	S&P	Moody’s	Fitch	Scope
ING Groep N.V.
Issuer rating
Long-term	A-	n/a	A+	AA-
Short-term	A-2	n/a	F1	S-1+
Outlook	Stable	Stable 1	Stable	Stable
Senior unsecured rating	A-	Baa1	A+	A+
ING Bank N.V.
Issuer rating
Long-term	A+	A1	AA-	AA-
Short-term	A-1	P-1	F1+	S-1+
Outlook1	Stable	Stable	Stable	Stable
Senior unsecured rating	A+	A1	AA-	AA-

1Outlook refers to the senior unsecured rating.

A security rating is not a recommendation to buy, sell or hold securities.

Each rating should be evaluated independently of other ratings. There is

no assurance that any credit rating will remain in effect for any given

period of time, or that it will not be lowered, suspended, or withdrawn

entirely by the rating agency if, in the rating agency’s judgement,

circumstances so warrant. ING accepts no responsibility for the accuracy

or reliability of the ratings.


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Risk management

As a global financial institution with a strong

European base, offering banking services, ING is

exposed to a variety of risks. We manage these

through a comprehensive risk management

framework that integrates risk management into

strategic planning and daily business activities.

This aims to safeguard ING’s financial strength and

reputation by promoting the identification,

measurement and management of risks at all

levels of the organisation. Taking measured risks

aligned with our risk appetite is core to ING’s

business.

This section sets out how ING manages its risks on a day-to-day basis.

It explains how the risk management function is embedded within the

organisation based on the ‘three-lines-of-defence’ (3 LoD) model. It

describes the key risks that arise from ING’s business model and how

these are managed. The section provides qualitative and quantitative risk

disclosures on solvency, credit, market, funding and liquidity, ESG

(environmental, social, and governance), operational, information

technology (IT), compliance, model, and business and strategy risks.



	Basis of disclosures () The risk management section contains information relating to the nature and extent of the risks of financial instruments as required by International Financial Reporting Standards (IFRS) 7 ‘Financial Instruments: Disclosures’. These disclosures are an integral part of the ING Group Consolidated financial statements and are indicated by the symbol (). This is applicable for the chapters, paragraphs, graphs, or tables within the risk management section that are indicated with this symbol in the respective headings or table header. This risk management section includes additional disclosures beyond those required by IFRS, such as certain legal and regulatory disclosures. Not all information in this section can be reconciled back to the primary financial statements and corresponding notes, as it has been prepared using risk data that differs from the accounting basis of measurement. Disclosures in accordance with Part Eight of the CRR3 and CRD VI, and as required by the supervisory authority, are published in our ‘Additional Pillar III Report’, which can be found on our corporate website ing.com.

Top and emerging risks

The risks listed below are defined as the top existing and emerging risks

that could cause ING’s results to differ, in some instances materially, from

those anticipated. They may have a material impact on the reputation of

the company, introducing volatility in future operating results. These risks

can also impact ING’s medium- and long-term strategy, affecting its ability

to pay dividends, maintain appropriate levels of capital, or meet liquidity

and funding targets. An emerging risk is defined as a new or future risk

that might impact ING. Therefore, these risks require proactive

identification and monitoring as their impact on the organisation is more

difficult to assess compared to other risks. The key existing and emerging

risks are identified through the annual risk identification and risk

assessment process, covering both the ING Group and local entity

perspectives. Top risks are determined through an annual risk assessment

that evaluates the likelihood and potential impact of the risks, while

emerging risks are identified using horizon scanning and expert

judgement. The annual risk assessment is executed through risk surveys

and scenario analysis, with validation by senior management committees.

ING ensures that identified key risks feed into, among others, the annual

review of the Risk Appetite Framework (RAF) and Stress Testing

Framework. A number of key risks are listed below, with their sequence not

indicative of their likelihood or potential impact on ING.

Geopolitical risk

Geopolitical risk remains a key focus area for ING, requiring continuous

monitoring. In 2025, persistent policy uncertainty, intensifying trade

frictions, geo-economic confrontation and sanctions-related and supply-

chain restrictions shape the global landscape. These developments have

made cross-border trade and logistics increasingly challenging, driving up

costs and creating operational bottlenecks for global businesses. The

resulting uncertainty spills over into financial markets, heightening

volatility as investors react to tariff announcements and fluctuating risk

premium. These pressures translate into slower global growth and uneven

disinflation, with fragmented trade flows and elevated input costs

affecting productivity and monetary policy transmission. This could impact

ING beyond headline volatility, potentially leading to deteriorating credit

quality in exposed sectors, increased refinancing risk, and potential ratings

migration among ING clients. In addition, geopolitical events could trigger

the materialization of non-financial risks, for example the unavailability of

services provided by third-parties and increase of regulatory diversion.


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Global trade and policy volatility

Global trade tensions intensified, reshaping economic relationships and

market dynamics. Trade relations between major economies deteriorated

as the US adopted protectionist measures through higher trade tariffs,

while the EU targeted Chinese industrial goods, including electric vehicles.

Transatlantic disputes over technology controls, digital taxation, and

green-trade measures escalated, prompting retaliatory actions from China

and the EU. Allegations of dumping and subsidy disputes added pressure

in the markets, contributing to episodic equity sell-offs, wider credit

spreads, and pressure on supply chain-linked commodities. For ING, this

backdrop could lead to reduced client cash flows, variability in collateral

quality, and changes in market risk and funding dynamics.

Europe

Fragmented policymaking and structural fiscal pressures, such as ageing

populations and higher defence spending, added complexity to the

European landscape. Due to the persistence of a higher-for-longer rate

environment, fiscal rules and national adjustment plans were closely

monitored. The challenges in implementing reforms were particularly

visible in France, as shown by its parliamentary deadlock and budget

disputes. These developments resulted in wider sovereign spreads and

tighter credit conditions. This backdrop affects ING through pressure on

corporate and household lending, changes in fixed-income pricing, and

higher costs for euro funding.

United States

US policy in 2025 featured efforts to advance a comprehensive omnibus

policy package ('One Big Beautiful Bill') combining tax reforms, industrial

policy, and border measures. The subsequent focus on reshoring and

strategic support reinforced tariff use as a negotiation tool. While

discussions on de-dollarisation gained momentum, the US dollar remained

dominant in global funding. Potential effects for ING include sector-specific

credit risk, variability in global funding costs, and changes in USD liquidity,

influencing both client exposures and wholesale funding markets.

Asia-Pacific

Security tensions persisted across key maritime and airspace zones due to

Chinese military activity near Taiwan and the Philippines. In South Asia,

renewed skirmishes and diplomatic strains between India and Pakistan

added to instability. These conditions may dampen regional investment

sentiment and equity markets, affecting ING through weaker trade finance

flows, increased counterparty risk, and potential stress on clients with

Asia-focused supply chains.

Ukraine

The war in Ukraine remained a central driver of European geopolitical risk.

Military activity continued without decisive shifts, while cross-border

strikes and attacks on energy infrastructure escalated concerns. Sanctions

tightened throughout the year, and debates over using frozen Russian

assets for Ukraine’s reconstruction raised legal and financial stability

questions. This environment heightens volatility in energy-sensitive

sectors, exposing ING to heightened credit risk across Eastern European

portfolios and increasing compliance costs linked to sanctions screening.

For more information on sanctions, see 'Compliance risk’.

Our credit exposure remained stable at €547 million (2024: €550 million),

mainly with Central Bank liquidity facilities and other lending. A significant

part is guaranteed by international parents or benefits from strong

collateral.

Exposure in Russia

In March 2022, we announced a decision to no longer do new business

with Russian counterparties. Nevertheless, ING’s remaining operations in

Russia and with Russian counterparties are subject to various risks,

including, but not limited to, credit risk, changes in laws and regulations –

including sanctions and counter sanctions – as well as conflicts of law,

potential litigations, and events that would trigger loss of control.

In December 2025, ING’s remaining credit exposures to Russian

counterparties, booked outside of Russia, was €0.6 billion (2024: €1.0

billion).

On 28 January 2025, ING announced the proposed sale of ING Bank

(Eurasia) JSC to Global Development JSC. Completion of the transaction is

subject to various regulatory approvals. This transaction will effectively

end ING’s activities in the Russian market. Under the terms of the

agreement, Global Development will acquire all shares of ING Bank

(Eurasia) JSC, taking over all Russian onshore activities and staff. Global

Development intends to continue to serve customers in Russia under a

new brand. As of the date of this report and as announced in September

2025, the buyer has not received all necessary approvals yet. We continue

working towards completing the transaction and our exit from the Russian

market. In the meantime, we are in discussion with regulators on the

conflicting regulatory requirements in various jurisdictions with respect to

the activities of ING Bank (Eurasia) JSC.

ING expects a negative P&L impact of around €0.8 billion post tax. This

includes an estimated book loss of around €0.5 billion, representing the

difference between the sale price and the book value of the business. It

also includes an estimated negative impact of around €0.3 billion from

recycling the currency translation adjustment through P&L, which is

capital neutral. The sale is expected to have a negligible impact on ING’s

CET1 ratio.

Starting from 2024 a trend emerged whereby Russian parties hold

Western banks liable in Russian courts. The Russian parties claim that such

banks, by complying with sanctions imposed by the EU, US and other

authorities, have caused damage to the Russian party. There have also

been instances where Russian courts ruled in favour of the Russian party.

In these cases, Russian courts did not recognise such sanctions, did not

respect the choice of law and courts pursuant to the applicable contracts,

and held Russian subsidiaries of Western banks liable for acts by other

entities in that banking group. For more information on litigation involving

ING, see Note 42 ‘Legal proceedings’.

Middle East

The Israel-Gaza conflict moved through fragile ceasefire phases,

repeatedly disrupted by renewed hostilities. International mediation

efforts have focused on providing humanitarian relief to alleviate civilian

suffering and to reduce the risk of regional escalation. In the Red Sea,

maritime security incidents increased the risks of wider escalation, while

concerns grew over a potential spillover involving Israeli strikes on Iran and

Qatar. These developments could destabilise energy and logistics markets,

leading to higher commodity price volatility and operational challenges in


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key trading routes. For ING, this also affects valuation risks in client

portfolios and sovereign and corporate exposures in the area.

Interest rate risk

Diverging monetary policy paths among major central banks reintroduced

volatility in interest rate and foreign exchange markets. The European

Central Bank (ECB) shifted from easing policy rates to holding them steady

as euro-area disinflation continued. Meanwhile, the US Federal Reserve

adopted a gradual return towards neutral policy, implementing rate cuts

and suspending Treasury runoff amid persistent inflation pressures.

Uneven disinflation and country-specific fiscal concerns kept interest rate

highly volatile. For ING, this environment affects funding costs, asset

valuations, and client behaviour, with knock-on effects on earnings

stability.

Cyber and Information Technology (IT) risk

Cybercrime remains an important risk. Threat actors are increasingly

sophisticated, leveraging emerging technologies such as generative AI to

develop advanced attack methods, including state-linked campaigns

targeting financial infrastructure. Regulatory requirements, including the

EU’s Digital Operational Resilience Act (DORA), reshaped expectations for

ICT risk management, incident reporting, and third-party oversight.

Operational resilience and business continuity have become central

themes, with regulators emphasising resilience testing, recovery

objectives, and contingency planning for critical service providers. The

growing complexity of IT ecosystems and reliance on cloud and third-party

vendors amplify these challenges, making resilience a systemic priority.

Disruptions in IT systems or third-party services can lead to service

outages, transaction delays, data breaches, and financial or reputational

losses for ING. IT resilience remains a priority for ING to ensure continuity

of services and protection of data. ING continues to strengthen its

measurement and reporting of IT and cyber risks while further developing

its ability to recover from large-scale ransomware events and maintain

recovery readiness for global, shared systems. These efforts are supported

by the Global Infrastructure organisation and the Chief Information

Security Office (CISO).

AI risk

AI adoption accelerated across 2025, moving from pilots to day-to-day use

in areas such as analytics, software development, and customer service.

This rapid rollout introduced risks related to data privacy and security,

model accuracy, bias, and accountability. The EU AI Act established clearer

obligations for high-risk systems; however, uneven global governance

continues to create compliance complexity and cybersecurity challenges.

These factors increase ING’s exposure to cyber incidents, misuse, and

compliance gaps, which can lead to operational and reputational impact.

As AI adoption grows, ING continues to strengthen its governance and risk

oversight through specialised structures such as the AI Risk Committee

and Centre of Excellence (CoE).

Environmental risk

Environmental risk remains an important concern for ING and the global

financial sector. This risk is increasingly shaped by the interplay of physical

climate impacts and accelerating transition pressures. Extreme weather

events and climate-related disruptions are now becoming systemic,

affecting infrastructure, supply chains, and asset valuations. The global

shift towards decarbonisation continues, but with uneven momentum:

regulatory mandates and technological advances are driving progress,

while political reality in regions such as the US and EU to ease climate

policies brings uncertainty. At the same time, increased polarisation and

politicisation of climate and broader ESG issues can produce conflicting or

rapidly changing policy signals, complicating transition pathways and

planning for financial institutions and clients. This divergence heightens

climate risk and amplifies political and macroeconomic volatility.

Biodiversity loss and resource scarcity further strain environmental

stability. These developments translate into heightened credit risk in

vulnerable sectors, market risk through valuation shifts, and operational

risks through supply chain disruptions and physical damage. Reputational

risk also intensifies as some stakeholders demand credible climate action

and others demand less.

For more details and mitigation actions, see ‘Environmental, social and

governance risk’ and ‘Credit risk’.

Risk governance

Effective risk management requires company-wide risk governance. ING’s

risk and control structure is based on the ‘three-lines-of-defence’ model.

This model aims to provide a sound governance framework for risk

management by defining and implementing three lines. Each line has a

specific role and defined responsibilities, with the execution of tasks being

distinct from the control of these same tasks. The three lines work closely

together to identify, assess, mitigate, and monitor risks.

This governance framework is designed in such a way that risk is managed

in line with the risk appetite approved by the Management Board Banking

(MBB), the Executive Board (EB) and the Supervisory Board (SB), and this

approach is cascaded throughout ING.

Board-level risk oversight

Both the EB (for ING Group) and the MBB (for ING Bank) play an important

role in managing and monitoring our risk management framework. For

more information on the SB, MBB, and EB duties, and powers and

responsibilities in relation to risk management, see ‘Corporate

governance’.


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Risk committees

In 2025, ING changed its risk-led MBB-key committees structure reporting

into the EB and MBB. The key risk committees described below act within

the overall risk policy and delegated authorities granted by the EB and/ or

MBB:

§The Global Financial Risk Committee (GFRC) is the highest authority,

except for the MBB, to discuss and approve global policies,

methodologies, and procedures related to financial risk, covering

solvency, credit, market, funding & liquidity, and environmental, social

& governance risk. GFRC is a risk committee responsible for setting and

monitoring risk appetite statements & limits, stress testing and

financial risk frameworks & policies. The GFRC meets monthly.

§The Model Risk Management Committee (MoRMC) is the owner of the

overall governance around models’ approval. MoRMC approves

frameworks, policies and procedures related to model risks. It sets

model risk strategies and monitors the model risk profile against the

RAS. The MoRMC meets monthly.

§The Global Credit Committee – Transaction Approval (GCC(TA))

discusses and approves transactions that entail taking credit risk

(including investment risk), country, legal, and environmental and

social risk and approves Wholesale Banking transactions. The GCC(TA)

meets twice a week.

§Group Non-Financial Risk Committee (Group NFRC) oversees the holding

company ING Group and all subsidiaries other than ING Bank N.V. It

opines on and approves non-financial risk matters. It ensures

appropriate action is taken by responsible management.

§The Bank Non-Financial Risk Committee (Bank NFRC) is accountable for

the design and maintenance of the non-financial risk management

framework, including operational risk management, compliance and

legal policies, minimum standards, procedures and guidelines,

development of tools, methods, and key parameters (including major

changes) for risk identification, assessment, measurement, mitigating,

and monitoring/reporting. Bank NFRC meetings are held at least

monthly.

In addition, several other committees are involved in various steps in the different risk management frameworks, as illustrated in the graph below:

EB/MBB

GFRC

Group Financial Risk Ct

MoRMC

Model Risk Management Ct

GCC-TA Global Credit Ct for

Transaction approvals

Group & Bank NFRC

Group & Bank Non-Financial Ct

CRC

Credit Risk Ct

CRMC

Credit Risk Model Ct

GUC

Global Underwriting Ct

IT BNFRC

CARC

Capital and ALM Risk Ct

AIRCO

AI Risk Ct

DREC

Distress Real Estate Ct

GPAC

Global Client Protection

and Approval Ct

TCRC

Trading and CP Risk Ct

ERC

ESG Risk Ct

1Although support functions are part of the first line of defence, they provide subject matter expertise to both the first and second lines of defence


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Three lines of defence

First line of defence

Second line of defence

Third line of defence

Who

Heads or their delegates of:

banking business, support functions 1,

geographies, countries

COO

CTO

Risk including Compliance

Internal audit function CAS

Responsible for

§Running business with clients and

accountable for assessing, controlling,

mitigating, and reporting all risks affecting

their businesses, to ensure risks are within

risk appetite, i.e. 1st LoD risk management

activities

§Completeness and accuracy of the financial

statements and risk reports with respect to

their areas of responsibility

Responsible for

§Setting, operating, and

maintaining effective and

efficient processes and running

operations for the bank, and

managing risks arising from

these activities

Responsible for

§Setting, operating, and

maintaining an effective and

efficient IT architecture and IT

services provision for the bank,

and managing risks arising

from these activities

Responsible for

§Develops, owns, and maintains the risk taxonomy, including clear

and consistent risk categories and definitions, forming the basis for

consistent risk identification, measurement, reporting, and

escalation.

§Defines and owns risk measurement methodologies, models, and

assessment frameworks used to quantify and assess risks,

including risk materiality assessment frameworks to determine

which risks are significant.

§Designs, maintains, and monitors the Risk Appetite Framework

(RAF), ensuring that risk appetite statements, limits, and thresholds

are aligned with strategy, capital planning, and regulatory

expectations, and that breaches and emerging risks are escalated

in a timely and transparent manner.

§Provides independent monitoring and reporting of risks to support

informed decision making and effective governance by senior

management and governing bodies.

§Oversees, advises, and challenges the First Line of Defence on risk

management and compliance activities, providing subject matter

expertise while maintaining independence.

§Exercises escalation and veto powers in relation to activities or

decisions assessed to present unacceptable risks, ensuring

escalation to the appropriate governance bodies when required.

Responsible for

§Independent assurance to the MB, the

Audit Committee, and the SB on the quality

and effectiveness of ING's internal control,

risk management, governance, and

implemented systems and processes in

both the first and second lines of defence


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Regional and business unit level

ING’s regional and/or business unit management have primary

responsibility for the management of risks (credit, market, funding and

liquidity, operational, IT, compliance and model) that arise in their daily

operations. They are accountable for the implementation and execution of

appropriate risk frameworks affecting their businesses in compliance with

procedures and processes at the corporate level. Where necessary, the

implementation is adapted to local requirements.

Organisational structure

The CRO function is organised along the lines of a matrix structure

integrating (i) the Global Risk functions, (ii) the Regional/Country Risk

functions at entity level, and (iii) the Risk Segments. Global Risk functions,

organised by risk types into risk domains (departments), are ultimately

responsible and accountable for the functional steering of the respective

risk type globally. They ensure a uniform taxonomy and methodology are

used for the setting of the relevant risk appetite levels, further cascading

risk appetite into detailed risk strategies, and for the effective monitoring

and reporting of risks, on an individual and consolidated basis.

The Group Chief Risk Officer (CRO) and the Chief Compliance Officer (CCO)

each have direct access to the SB Risk Committee and its chair. Conversely,

the chair of the SB Risk Committee holds periodic bilateral consultations

individually with both the Group CRO and the CCO.

The current organisation chart outlines the reporting lines within the risk

management function. A refreshed chart will be introduced in 2026 to

align with the enhanced Risk Strategy designed to further strengthen and

future‑proof the Group Risk organisation. The proposed updates are guided

by four key principles: (i) reinforcing the Risk organisation by emphasising

its core activities, (ii) enhancing global functional steering, (iii) enabling

business strategies through expanded skills and capabilities, and (iv)

building a more effective, agile, and streamlined Risk organisation.

The departments in the purple colour reflect hierarchical reporting lines,

whereas the dotted lines are for the functional reporting lines:

The Group Chief Risk Officer

Credit Risk

Financial Risk

Non-Financial Risk

Model Risk

Integrated Risk

Risk Culture

& Behavioural Risk

Compliance Risk

Retail/

Rest of the World

Wholesale Banking

COO Risk

CRO Belgium

CRO

Netherlands

CRO Germany

Risk management framework

Risk policies and internal control documents

ING maintains a comprehensive system of risk management frameworks,

policies, mandatory instructions, procedures, and control standards

(collectively referred to as ‘internal control documents’), which establish

binding requirements for all ING locations. ING locations shall comply with

both internal control documents and local requirements. Internal control

documents are regularly reviewed, updated, and approved in accordance

with ING internal control binding principles. Senior management is

responsible for ensuring the implementation of, and staff adherence to,

internal control documents.

Internal risk management and control system

The enterprise risk management (ERM) framework and its related internal

control documents constitute the internal control framework in ING. The

ERM framework establishes an ING-wide governance model that aligns

strategy to risk appetite for all risk types. It applies to all business lines and

ING locations on the global and local level. The internal control framework

is based on the following principles:

§Consistent Risk Governance at global and local level is defined

and adhered to using the three-lines-of-defence model and clear

decision-making.

§Risk Appetite framework sets forward-looking risk limits and process to

ensure that risk-taking activities remain within acceptable ranges.

§Risk Taxonomy sets a common risk language to identify and manage

all relevant risks.

§Internal Control Documents facilitate effective risk management and

compliance with legal requirements and approved risk appetite.

§Continuous Risk Management Cycle to identify, assess, mitigate,

monitor, and report risks supported by adequate Risk Data and Risk

Systems.

§Strong risk culture and people that enable proactive risk management

balancing risk and reward.

The ERM Framework and underlying risk management frameworks are

based on the EBA Guidelines on Internal Governance (EBA/GL/2021/05,

2 July 2021) which is one of the drivers for the ING Governance Framework

and are aligned with the public criteria of the Committee of Sponsoring

Organisations of the Treadway Commission in Internal Reporting (COSO) –

Integrated Control Framework (2013 Framework).

Risk effectiveness

ING’s Internal Risk Management & Control (IRM&C) systems are designed

to safeguard risk effectiveness through:

§Adequate and timely risk identification, assessment, measurement,

mitigation, monitoring, reporting, and follow up; and

§Sufficient reliable insight that risks stay within risk appetite and can be

steered.


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Internal monitoring of risk effectiveness safeguards and confirms

adequate functioning of our IRM&C systems and enables ING to adapt

them in response to emerging risks, regulatory changes, or lessons

learned.

The effectiveness of risk management and internal control systems is

monitored through the risk management activities themselves (e.g. risk

monitoring and reporting) and through dedicated mechanisms (e.g. risk

framework monitoring and quality assurance).

Risk culture

At ING, we attach great importance to a sound risk culture, which is

essential for keeping the bank safe and secure. We determine our risk

culture as the way in which employees identify, understand, discuss, and

act on the many financial and non-financial risks we are confronted with

every day.

Learning

In 2025, we continued to expand and strengthen our required learning

curriculum. This foundational learning ensures all staff understand key

regulations, policies, and risks, supporting compliance and protecting the

bank and its customers. The curriculum is tracked centrally to support

timely completion. We continue to refine our learning formats to enhance

engagement and ensure practical application of knowledge. The topics

covered in 2025 were Conflicts of Interest, the Global Code of Conduct,

Operational Resilience, the EU AI Act, Cybersecurity, and Record Retention.

In addition, we continue to expand our learning offering on a range of risk

topics for targeted audiences across the bank, including risk staff. Working

with risk experts, the Risk Academy created and curated role-based

learning for risk colleagues, providing a wide selection of learning to

support both immediate job performance and long-term professional

growth.

Dutch Banker’s Oath

In the Netherlands, all employees working for a bank are required to take

the Banker’s Oath. By taking the oath, employees declare that they will

work with integrity, diligence, and in accordance with the related Code of

conduct (gedragscode). ING requires employees to follow trainings before

taking the actual oath – to understand the content and stress the

importance of the oath, enable all employees in the Netherlands to discuss

any dilemmas they may face in their daily work, and how to carefully

balance the interests of all ING’s stakeholders therein. All employees who

have taken the oath are subject to the Dutch Disciplinary Law and

Regulations, executed by the ‘Stichting Tuchtrecht Banken’ (Foundation for

Disciplinary Law of the banking sector).

Remuneration

ING aims to align its remuneration policy with its risk profile and the

interests of all stakeholders. For more information on ING’s remuneration

approach and its relation to the risk taken, see the Capital Requirements

Regulation (CRR) remuneration disclosure published on ing.com.

Risk cycle process

ING identifies, measures, and manages risks through five recurrent phases

of the management cycle: risk identification, risk assessment, risk

mitigation, risk monitoring, and risk reporting. The risk cycle process is

embedded within dedicated risk domain frameworks, such as the Non-

Financial Risk Framework, Model Risk Framework, and ESG Risk Framework.

Each risk domain is responsible for ensuring its risk cycle process and

frameworks are operational and effective. Key components of the risk

cycle process are defined in the Enterprise Risk Management Framework

as follows:

Risk identification

Risk identification is performed periodically through a joint effort of the

business and the risk management functions, linked to ING’s common risk

language and ad hoc in case of material internal or external change.

Risk assessment

Risk assessment ensures that each identified risk is assessed (qualitatively

and quantitatively) in a structured and fact-based manner and classified

for importance based on impact and likelihood. This enables management

to decide which of the identified risks need mitigating (control) measures,

how strict or tolerant these measures should be, and to assign a Risk

Owner.

Risk mitigation

Risks mitigation refers to the process of dealing with (and controlling) risk

exposures through one or a combination of strategies: risk-level reduction

(e.g. controls), risk avoidance (e.g. stop activity), risk transfer (e.g.

insurance or securitisation), and/or risk acceptance.

Risk monitoring

Risk monitoring is a continuous process, performed at individual and

aggregate risk level. It involves tracking and reviewing risk exposures and

the effectiveness of risk management strategies, including the design and/

or operating effectiveness of mitigating (control) measures.

Risk reporting

Risk reporting provides senior and local management with comprehensive

and actionable risk information. It facilitates the measurement,

monitoring, and oversight of risk exposures against risk appetite and

tolerance.

The Enterprise risk Management Framework is reviewed regularly to

ensure it reflects regulatory developments, and incorporates changes

based on external and internal triggers.

Risk Appetite Framework

The Risk Appetite Framework (RAF) is one of the key elements of the ERM

framework. Its objective is to set an appropriate risk appetite at a

consolidated level across different risk categories and to allocate the risk

appetite throughout the organisation.


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Procedure

The RAF procedure explains the setup of the overarching global risk

appetite. Within the RAF, ING monitors a range of financial and non-

financial risk metrics to ensure that our risk profile is in line with our risk

appetite while executing our strategy. ING’s RAF, which is approved by the

SB, defines the desired risk profile that is to be integrated in the strategic

decision-making and financial planning process. It is designed to be able to

withstand market volatility and stress, while meeting regulatory

requirements. The framework, including underlying metrics and

assumptions, is reviewed at least annually so that it remains relevant. The

RAF combines various financial and non-financial risk appetite statements

(RAS) into a single, coordinated approach.

Process

The RAF and underlying limit allocation are reviewed on an annual basis, or

more frequently if necessary, based on their monthly review in the MBB

and quarterly review in the EB and the SB. It is therefore a top-down

process, which bases itself on the ambition of the bank in terms of its risk

profile, the regulatory environment, and the economic context. Limits that

require SB approval are called boundaries, and the underlying instruments

supporting the boundaries require EB and MBB approval.

Step 1. Identify and assess ING’s key risks

The outcome of the risk-identification and risk-assessment process is used

as the starting point for the review of the RAF. Within this step, the risks

ING faces when executing its strategy are identified in the context of the

current economic, political, social, regulatory, and technological

environment. The assessment identifies whether the potential impact is

material and if it is sufficiently controlled.

Step 2. Set risk appetite framework

Based on ING’s risk assessment and risk purpose, boundaries and

instruments for the overarching risk frameworks are set. Once the

overarching risk appetite statements have been set and approved by the

EB/MBB and subsequently by the SB, the statements are translated into

risk type-specific statements and lower-level risk metrics. These are set

and approved by senior risk committees, like the Global Financial Risk

Committee (GFRC), Model Risk Management Committee (MoRMC) and Bank

Non-Financial Risk Committee (NFRC). Cascading is done via several

detailed risk appetite statements defined for each risk type. Together,

these statements aim to ensure compliance with the overarching

solvency, (credit) concentration, and funding and liquidity RAS.

ING includes climate risk in its RAF by, among other things, introducing

climate risk as one of the dimensions to determine sector concentration as

part of the credit risk appetite statements. In the coming years, ING will

extend the inclusion of climate risk impact on other risk types, ensuring

that potential risks – such as transition and physical risks – are properly

reflected in the RAF.

Step 3. Cascade into statements per risk type and business unit

The bank-wide risk appetite is defined per risk type, which is further

cascaded into the organisation. Risk appetite statements are then

translated into dedicated underlying risk limits that are used for the day-

to-day monitoring and management of ING’s risks. The risk appetite

statements serve as input for the quarterly planning process as well as for

the establishment of key performance indicators and targets for senior

management. The next graph is an illustrative and non-exhaustive

overview of the RAF.

Step 4. Monitor and manage underlying risk limits

To verify that ING remains within the RAF, it reports the risk positions vis-à-

vis their limits on a regular basis to senior management committees. A

monthly report is submitted to the MBB reflecting the exposure of ING

against the risk appetite. An extended report is submitted quarterly to the

EB and the SB’s Risk Committee. Moreover, the financial plan is checked

every quarter for potential limit excess within a one-year horizon, where in

the Strategic Dialogue the MBB can take mitigating measures or make

adjustments to the dynamic plan.

Stress testing

Stress testing is an important risk-management tool that provides input

for strategic decisions and capital planning. The purpose of stress testing is

to assess the impact of severe but plausible stress scenarios on ING’s

capital and liquidity position. Stress tests provide complementary and

forward-looking insights into vulnerabilities the bank is exposed to, with

regards to adverse macroeconomic circumstances, stressed financial

markets, changes in the political and geopolitical climate, and idiosyncratic

events. The outcomes of these stress tests help management get insight

into risk the bank is exposed to as well as mitigating actions to offset the

potential impact.

Types of stress tests

Within ING, we perform different types of stress tests. The most

comprehensive type of stress tests are the firm-wide scenario analyses,

which involve setting scenario assumptions for all the relevant

macroeconomic and financial market variables in all countries relevant to

ING. These assumptions usually follow a qualitative narrative that provides

a background to the scenario. In addition to firm-wide scenario analyses,

ING executes scenario analyses for specific countries or portfolios.

Furthermore, sensitivity analyses are performed, which focus on stressing

one or more risk drivers – usually without an underlying scenario narrative.

Finally, ING performs reverse stress tests, which aim to determine

scenarios that could lead to a predefined severe adverse outcome.

Process

ING’s stress-testing process consists of several stages:

§Risk identification and risk assessment: it identifies and assesses the

risks ING or the relevant entity is facing when executing its strategy,

based on the current and possible future economic, political,

regulatory, and technological environment. It provides a description of

the main risks and risk drivers related to the nature of ING’s business,

activities, and vulnerabilities.

§Scenario definition and parameterisation: based on the outcome of the

previous step, a set of scenarios is determined with the relevant scope

and set of risk drivers for each scenario, as well as its severity, the key

assumptions, and input parameters. The output of this phase includes a

quantitative description of the stress scenarios to be analysed, the

relevant output metrics, and, when applicable, a narrative description.

§Impact calculation and aggregation: based on the quantitative

description of the stress scenarios, the impact is determined for the

relevant scenario, scope, and horizon. The impact calculation and

aggregation can be part of a recurring process or part of a specific

process set-up for one-off stress tests.


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§Scenario reporting: for each stress test, a report is prepared after each

calculation, which describes the results of the scenario and gives a

recap of the scenario with its main assumptions and parameters. The

stress-test report is sent to the relevant risk committees and/or senior

management. It is complemented, if needed, with advice for

management action based on the stress-testing results.

§Scenario control and management assessment: depending on the

outcomes of the stress test and the likelihood of the scenario,

mitigating actions may be proposed. Mitigating actions may include,

but are not limited to, sales or transfers of assets and reductions

of risk limits.

Methodology

Detailed and comprehensive models are used to assess the impact of the

scenarios. In these models, statistical analysis is combined with expert

opinion to make sure the results adequately reflect the scenario

assumptions. The methodologies are granular and portfolio-specific, and

use different macroeconomic and market variables as input. The stress-

testing models are subject to review by Model Risk management and

underlying assessments are in line with financial and regulatory reporting

frameworks.

Framework Policy

and Procedures

ING Group Risk Appetitie Framework (RAF)

Integrated Risk

Boundaries /

Instruments

Boundaries and instruments for overarching and risk-type specific RAS

Integrated Risk, Financial Risk, Credit Risk, Non-Financial Risk

Solvency RAS

Integrated Risk

Funding & Liquidity

RAS

Financial Risk

Concentration RAS

Credit Risk

Credit RAS

Credit risk

Market RAS

Financial Risk

Non-Financial RAS

Non-Financial Risk

Business & Strategy

RAS

Integrated Risk

Compliance RAS

Compliance Risk

Model RAS

Model Risk

Local application

of RAF

Group Treasury

Limits & Qualitative Statements

Local entity / Business Line / Unit A

Limits & Qualitative Statements

Local entity / Business Line / Unit B

Limits & Qualitative Statements

Local entity / Business Line / Unit C

Limits & Qualitative Statements


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Solvency risk

Introduction

Solvency risk is the risk of lacking sufficient capital to fulfil business

objectives, regulatory requirements, or market expectations. An insolvent

bank is unable to pay its debts and will be forced into bankruptcy.

The level and quality of capital is crucial for the resilience of individual

banks. Banks are expected to assess the risks they face and, in a forward-

looking manner, ensure they identify and manage all material risks. They

must also make sure these risks are sufficiently covered by loss-absorbing

capital to provide continuity if unexpected risks materialise in times of

stress. Given the interdependencies with other financial and non-financial

risks, this balancing act of capital adequacy needs to be done within a

sound and integrated management approach. It must coherently link and

align all the moving parts of the bank with its long-term business strategy.

ICAAP framework

ING’s internal capital adequacy assessment process (ICAAP) framework

aims to ensure that capital levels remain adequate – both forward-looking

and under adverse conditions, in terms of covering material risks-to-

capital from both a normative and an economic (internal) perspective. The

assessment of ING’s capital adequacy takes into account its business

strategy and risk profile, market environment, and operating macro

environment. This implies that views of various stakeholders, such as

regulators, shareholders, investors, rating agencies, clients, and customers

play an important role.

The continued strength of ING’s capital position, the adequacy of the

financial position, and risk management effectiveness are essential to

achieving the strategy. ING’s capital and funding strategy determines the

underlying ICAAP elements, and thereby contributes to ING’s business

continuity from different perspectives.

Managing ING’s capital entails finding the right balance between supply

and demand, while considering market and macro circumstances. The

process of balancing these strategic goals is captured in the ICAAP

framework. It is enabled by six building blocks and underlying elements

facilitating the ICAAP. The following building blocks have been defined in

the ICAAP framework, which are applied for both the ‘normative’ and

‘economic’ perspective, as defined in the ECB guide to ICAAP:

§Risk identification and assessment;

§Risk appetite;

§Solvency stress testing;

§Planning and forecasting;

§Capital management; and

§Continuity.

Risk identification and assessment

ING’s capital management and solvency risk management starts with the

risk-identification and risk-assessment process, which is performed on an

annual basis. In addition to this annual process, ING also reassesses its

risks as part of its capital adequacy statement, a quarterly process to

assess ING’s capital adequacy.

Risk appetite

ING has solvency risk appetite statements in place for the following

metrics: CET1 ratio, total capital ratio, leverage ratio, total loss-absorbing

capacity (TLAC), and minimum requirement for own funds and eligible

liabilities (MREL) based on RWA/leverage ratio and economic capital

adequacy.

Solvency stress testing

Solvency stress testing allows ING to examine the effect of plausible but

severe stress scenarios on the solvency position. It also provides insight

into which entities or portfolios are vulnerable to certain types of risks or

scenarios. Solvency stress testing is an important tool in identifying,

assessing, measuring, and controlling risks to capital, providing a

complementary and forward-looking perspective to other solvency risk

management tools. For solvency stress testing, ING follows the same steps

described in the overall section on stress testing.

The outcomes of solvency stress test analyses are taken into account in

capital planning, but also for setting risk appetite statements and the

capital management buffer.

Planning and forecasting

The capital and funding plan is an integral part of the dynamic plan, ING’s

financial and business planning process. For more information, see section

‘Capital management’.

Capital management

Formulation of the CET1 target is a key element in solvency risk

management. The target ratio, based on the management buffer concept,

enables ING’s senior management to steer, benchmark, and assess the

bank’s current and future capital levels much more efficiently. The target

level clearly supports trust-building among ING’s key stakeholders (e.g.

regulators, investors, and customers).

The capital management buffer aims to protect the interests of key

stakeholders and plays an important role in the overall capital adequacy

governance. The rationale behind the buffer is that it provides an

additional cushion on top of the (local) regulatory minimum requirements

(e.g. supervisory review and evaluation process (SREP) requirements) to

withstand a certain level of stress and facilitate awareness and

preparedness to take management actions. ING reviews its capital

management buffer on a regular basis to determine its effectiveness and

robustness, updating it as appropriate. For more information, see section

‘Capital management’.

Continuity

Risk events with high severity or significant deteriorations of economic and

market conditions beyond ING’s control could cause deviations from the

business and capital plans, which may result in a potential capital shortfall.

ING has established a continuity (safety) net of contingency and recovery

planning. This includes ongoing monitoring of relevant indicators to

maintain awareness and enable proactive action to ensure continuity. The

intervention measures, which can be activated when deemed necessary,

consist of predefined RWA reduction measures, as well as direct capital-

increasing measures. The escalation mechanisms are defined, governed,

and detailed in the contingency and recovery plans.


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Both plans aim to restore ING’s capital adequacy. Depending on the

severity of the situation, the contingency plan can be activated at this

warning phase, as well as trigger further mitigating action and the

formation of the contingency crisis teams. Further drops in capital levels

trigger the alert phase for recovery monitoring and/or the activation of the

recovery plan and corresponding crisis teams.

Assessing capital adequacy: Capital Adequacy Statement

The Capital Adequacy Statement is ING Group’s quarterly assessment of its

capital adequacy and considers different elements with respect to its

capital position. The degree to which ING’s capital position is considered

adequate depends on a variety of internal and external drivers:

§Current supervisory requirements and (expected) requirements going

forward;

§Current internal requirements and (expected) requirements going

forward (economic capital/view);

§Coherence of the available capital with the (realisation of) strategic

plans; and

§The ability to meet internal and external requirements in the case of

stressed events or should a risk materialise.

The Capital Adequacy Statement assesses the adequacy of ING’s capital

position in relation to the above-mentioned drivers and states the extent

to which the capital position consequently is considered as adequate. The

Capital Adequacy Statement document is prepared on a quarterly basis.

Additionally, each year the EB/MBB signs and provides a comprehensive

assessment of ING’s capital adequacy, supported by the ICAAP outcomes,

in the form of a capital adequacy statement.


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Credit risk

Introduction

Credit risk is the risk of loss from the default and/or credit rating

deterioration of clients. Credit risks arise in ING’s lending, financial markets,

and investment activities. The credit risk section provides information on

how ING measures, monitors, and manages credit risk, and gives an

insight into the portfolio from a credit risk perspective.

Credit & counterparty risk categories (*)

In the table below, we describe the different types of credit and

counterparty risk categories and include a reconciliation with the notes in

the financial statements:

Credit risk appetite and concentration risk framework (*)

The credit risk appetite and concentration risk framework is designed to

prevent undesired high levels of credit risk and credit concentrations within

various levels of the ING portfolio. It is derived from the concepts of

boundaries and instruments as described in the ING Risk Appetite Framework.

Credit risk appetite is the maximum level of credit risk ING is willing to

accept for growth and value creation. The credit risk appetite is linked to

the overall bank-wide framework and is expressed in quantitative and

qualitative measures.

The credit risk appetite is set at different levels and dimensions within ING.

The credit risk appetite framework specifies the scope and focus of the

credit risk ING is willing to take, as well the composition of the credit

portfolio, including the concentration and diversification objectives across

business lines, locations, sectors, and products.


Reconciliation between credit & counterparty risk categories and financial position (*)
Credit risk categories	Notes in the financial statements
Lending risk: The risk that the client (counterparty, corporate, or individual) does not pay the principal interest or fees on a loan when they are due, or on demand for letters of credit (LCs) and guarantees provided by ING.	2	Cash and balances with central banks
	3	Loans and advances to banks
	4	Financial assets at fair value through profit or loss
	5	Financial assets at fair value through other comprehensive income
	7	Loans and advances to customers
	41	Commitments
Investment risk: The credit default and risk rating migration risk that is associated with ING’s investments in bonds, commercial paper, equities, securitisations, and other similar publicly traded securities. This can be viewed as the potential loss that ING may incur from holding a position in underlying securities whose issuer's credit quality deteriorates or defaults.	4	Financial assets at fair value through profit or loss
	5	Financial assets at fair value through other comprehensive income
	6	Debt securities
Money market risk: This arises when ING places short-term deposits with a counterparty in order to manage excess liquidity. In the event of a counterparty default, ING may lose the deposit placed.	2	Cash and balances with central banks
	3	Loans and advances to banks
	7	Loans and advances to customers
Pre-settlement risk: This arises when a client defaults on a transaction before settlement and ING must replace the contract by a trade with another counterparty at the then prevailing (possibly unfavourable) market price. This credit risk category is associated with derivatives transactions (exchange-traded derivatives, over-the-counter (OTC) derivatives and securities financing transactions).	4	Financial assets at fair value through profit or loss
	14	Financial liabilities at fair value through profit or loss
	40	Offsetting financial assets and liabilities
Settlement risk: This arises when there is an exchange of value (funds or instruments) and receipt from its counterparty is not verified or expected until after ING has given irrevocable instructions to pay or has paid or delivered its side of the trade. The risk is that ING delivers but does not receive delivery from its counterparty.	4	Financial assets at fair value through profit or loss
	11	Other assets
	14	Financial liabilities at fair value through profit or loss
	16	Other liabilities

The credit concentration risk framework is composed of:

§Country risk concentration: Country risk is the risk that arises due to

events in a specific country (or group of countries). To manage the

maximum country loss ING is willing to accept, boundaries are

approved by the SB. The estimated level is correlated to the risk rating

assigned to a given country. Actual country limits are set by means of

country instruments, which are monitored monthly and updated when

needed. For countries with elevated levels of geopolitical or severe

economic cycle risk, monitoring is performed on a more frequent basis,

with strict pipeline and exposure management.

§Single name concentration (including secondary risk): ING has an

established credit concentration risk framework to identify, measure,

and monitor single name concentration, including secondary risk. The

same concept of boundaries and instruments is applicable.

§Sector and product concentration risk are managed via the credit risk

appetite framework.


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Credit risk models (*)

Within ING, internal CRR-compliant models are used to determine

probability of default (PD), exposure at default (EAD), and loss given

default (LGD) for regulatory and economic capital purposes. These models

also form the basis of ING’s IFRS 9 loan loss provisioning (see ‘IFRS 9

models’ below).

There are two main types of PD, EAD and LGD models used throughout the

bank:

§Statistical models are created where a large set of default or detailed

loss data is available. They are characterised by sufficient data points

to facilitate meaningful statistical estimation of the model parameters.

The model parameters are estimated with statistical techniques based

on the data set available.

§Hybrid models are statistical models supplemented with knowledge

and experience of experts from risk management and front-office staff,

literature from rating agencies, supervisors and academics. These

models are only used for ‘(ultra) low default portfolios’, where limited

historical defaults exist.

Credit risk rating process (*)

The majority of risk ratings are based on a risk rating (PD) model that

complies with the minimum requirements detailed in CRR/CRD, ECB

Supervisory Rules and European Banking Authority (EBA) guidelines. This

concerns all borrower types and segments.

ING’s PD rating models are based on a 1-22 internal risk rating scale (1 =

best rating; 22 = worst rating) referred to as the ‘master scale’, which

roughly corresponds to the rating grades that are assigned by external

rating agencies, such as Standard & Poor’s, Moody’s and Fitch. For

example, an ING rating of 1 corresponds to an S&P/Fitch rating of AAA and

a Moody’s rating of Aaa; an ING rating of 2 corresponds to an S&P/Fitch

rating of AA+ and a Moody’s rating of Aa1, and so on.

The 22 internal risk rating grades are composed of the following

categories:

§Investment grade (risk rating 1-10);

§Non-investment grade (risk rating 11-17);

§Performing Restructuring (risk rating 18-19); and

§Non-performing (risk rating 20-22).

The first three categories (1-19) are risk ratings for performing loans.

Ratings are calculated in IT systems with internally developed models,

based on manually or automatically fed data, or for part of the non-

performing loans set by the global or regional credit restructuring

department. Under certain conditions, the outcome of a manually fed

model can be challenged through a rating appeal process. For

securitisation portfolios, the external ratings of the tranche in which ING

has invested are leading indicators.

Risk ratings assigned to clients are reviewed at least annually, with the

performance of the underlying models monitored regularly. Some of these

models are global in nature, such as those for large corporates,

commercial banks, insurance companies, central governments, funds,

fund managers, project finance, and leveraged companies. Other models

are more regional or country-specific: there are PD models for small and

medium enterprises (SMEs) in the Netherlands, Belgium and Poland, as

well as residential mortgage and consumer loan models in the various

retail markets.

Rating models for Retail clients are predominantly statistically driven and

automated, such that ratings can be updated on a monthly basis. Rating

models for large corporates, institutions and banks include both statistical

characteristics and expert input, with the ratings being manually updated

at least annually. More frequent reviews (e.g. quarterly) are performed

where considered necessary.

Credit risk tools and data standards

The acceptance, maintenance, measurement, management, and

reporting of credit risks at all levels of ING are executed through single,

common credit risk data standards using shared credit risk tools that

support standardised and transparent credit risk practices. ING has chosen

to develop and implement credit risk tools centrally with the philosophy of

using a single source of data in an integrated way.

Credit risk portfolio (*)

Within ING, credit risk exposures are classified into four sources: 1)

Consumer Lending (to private individuals), 2) Business Lending, 3)

Investment and Money Market and 4) Pre-settlement. ING’s credit

exposure is mainly related to lending to individuals (also referred to as

consumer lending, all Retail) and businesses (referred to as business

lending, both in Retail and Wholesale), followed by investments in bonds

and securitised assets, and money market (Wholesale). Loans to

individuals are mainly mortgage loans secured by residential property.

Loans (including guarantees issued) to businesses are often collateralised,

but may be unsecured based on the internal analysis of the borrower’s

creditworthiness. Bonds in the investment portfolio are generally

unsecured, but predominantly consist of bonds issued by central

governments and EU and/or OECD-based financial institutions. Secured

bonds, such as mortgage-backed securities and asset-backed securities,

are secured by the underlying diversified pool of assets (commercial or

residential mortgages, car loans and/or other assets) held by the securities

issuer. For money market, exposure is mainly deposits to central banks.

The last major credit risk source involves pre-settlement exposures which

arise from trading activities, including derivatives, repurchase transactions

and securities lending/borrowing transactions. This is also commonly

referred to as counterparty credit risk.

Overall portfolio (*)

During 2025, ING’s portfolio size increased by €41.1 billion (4.3%) to

€1,002.9 billion outstanding. Foreign exchange rate changes had a €22.0

billion negative impact on the portfolio size, mainly driven by the

depreciation of the US dollar which had an impact of €16.6 billion mainly in

Wholesale Banking. Following this, net growth in Wholesale Banking was

€4.4 billion. Retail Banking outstandings increased by €38.4 billion mainly

due to underlying growth in residential mortgages.


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Rating distribution (*)

Overall, the rating class distribution remained stable in 2025. The share of

investment grade rating classes increased from 78.1% to 79.3%, while the

share of non-investment grade decreased from 19.9% to 18.7%.

Performing restructuring outstandings remained constant at 0.6% of the

total portfolio in 2025, whereas non-performing loans (calculated

including Investment and Pre-Settlement exposures) decreased from 1.4%

to 1.3%.

With respect to the rating distribution within the business lines, in

Wholesale Banking, investment grade increased to 84.3% from 83.7%,

while non-investment grade exposures decreased to 13.9% from 14.6%

compared to 2024. Performing restructuring assets increased from 0.6%

to 0.7% of total Wholesale Banking assets where non-performing loans for

Wholesale Banking decreased from 1.2% to 1.1%.

For Retail Banking, investment grade increased to 75.4% from 73.3%,

while non-investment grade exposures decreased to 22.5% from 24.4% as

compared to 2024. Performing restructuring decreased to 0.6% from 0.7%

whereas NPL remained constant at 1.5% in 2025.

Industry (*)

The industry breakdown is presented in accordance with the NAICS

definition. The increase of €41.1 billion in total volume during 2025 was

mainly due to the increase in Private Individuals (€28.7 billion) and Central

Governments (€13.4 billion) which was partially offset by the decrease in

Central Banks (€ 21.9 billion). The share of Private Individuals increased

from 39.5% last year to 40.7%.

Portfolio analysis per business line (*)


Outstandings per line of business (*) 1, 2, 3
in EUR million		Wholesale Banking		Retail Banking		Corporate line		Total
Rating class		2025	2024	2025	2024	2025	2024	2025	2024
Investment grade	1 (AAA)	43,030	53,363	34,022	29,151	27	1,790	77,079	84,304
	2-4 (AA)	70,691	72,462	68,484	63,187	1	4	139,175	135,653
	5-7 (A)	130,280	101,766	149,694	140,479	555	154	280,528	242,400
	8-10 (BBB)	119,661	129,429	175,823	155,375	3,240	3,662	298,724	288,466
Non-investment grade	11-13 (BB)	49,980	53,757	90,916	94,753			140,896	148,510
	14-16 (B)	8,900	7,396	33,663	31,165			42,563	38,561
	17 (CCC)	1,224	1,037	3,147	3,345	147	170	4,518	4,552
Performing Restructuring loans	18 (CC)	2,209	1,792	1,945	2,001			4,154	3,794
Performing Restructuring loans	19 (C)	637	560	1,678	1,760			2,315	2,321
Non-performing loans	20-22 (D)	4,602	5,204	8,393	8,100			12,995	13,303
Total		431,214	426,767	567,764	529,317	3,970	5,779	1,002,947	961,863

Industry
Private Individuals		1,893	2,116	406,589	377,712			408,482	379,827
Central Banks		40,270	61,091	15,713	15,044		1,785	55,983	77,919
Natural Resources		39,229	39,974	1,757	1,925			40,985	41,899
Real Estate		25,024	24,643	29,665	28,738			54,689	53,381
Commercial Banks		44,512	40,962	6,351	6,662	3,638	3,616	54,501	51,240
Non-Bank Financial Institutions		65,037	64,217	1,973	2,212	262	290	67,271	66,719
Central Governments		59,600	48,389	10,280	8,107	1	1	69,880	56,497
Transportation & Logistics		25,427	27,499	6,507	6,037			31,934	33,536
Utilities		26,378	25,517	2,431	2,196			28,809	27,713
Food, Beverages & Personal Care		13,798	13,827	11,298	10,419			25,096	24,246
Services		9,489	8,844	13,756	13,442	19	27	23,265	22,312
General Industries		13,235	10,512	9,655	8,812			22,890	19,324
Lower Public Administration		8,904	6,959	22,529	19,598			31,433	26,557
Other		58,418	52,218	29,261	28,412	50	62	87,730	80,691
Total		431,214	426,767	567,764	529,317	3,970	5,779	1,002,947	961,863


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	163


Outstandings per line of business (*) - continued 1, 2, 3
in EUR million		Wholesale Banking		Retail Banking		Corporate line		Total
Region		2025	2024	2025	2024	2025	2024	2025	2024
Europe	Netherlands	35,165	44,421	180,030	164,590	526	1,903	215,720	210,913
	Belgium	25,786	26,506	99,055	95,584			124,841	122,091
	Germany	29,699	27,443	136,951	128,598	22	30	166,672	156,071
	Poland	23,740	21,190	34,223	30,946	3		57,966	52,136
	United Kingdom	30,475	28,257	252	265	78	91	30,805	28,613
	France	26,462	24,351	3,742	3,122	3	3	30,207	27,476
	Spain	15,568	11,990	31,015	28,507	38	36	46,620	40,533
	Luxembourg	28,844	26,176	4,587	5,139			33,431	31,314
	Rest of Europe	70,498	72,860	26,384	23,203	37	14	96,919	96,076
America		83,269	86,402	2,304	2,402	201	232	85,775	89,037
Asia		47,881	44,136	257	215	3,060	3,464	51,198	47,815
Australia		11,673	10,887	48,938	46,723	1	8	60,613	57,618
Africa		2,154	2,148	27	22			2,181	2,170
Total		431,214	426,767	567,764	529,317	3,970	5,779	1,002,947	961,863

1Based on credit risk measurement contained in lending, pre-settlement, money market and investment activities.

2Based on the total amount of credit risk in the respective column using ING’s internal credit risk measurement methodologies. Economic sectors (industry) below 2% are not shown separately but grouped in Other.

3Geographical areas are based on country of residence, except for private individuals, for which the geographical areas are based on the primary country of risk.

Portfolio analysis per geographical area (*)

The portfolio analysis per geographical area re-emphasises the

international distribution of ING’s credit portfolio. The Netherlands

maintains the largest portfolio share in a single country with 21.5%

(2024: 21.9%) of the total amount, followed by Germany with 16.6%

(2024: 16.2%), and Belgium with 12.4% (2024: 12.7%).

In terms of region, the majority of the portfolio balance remained in

Europe with 80.1% (2024: 79.6%), followed by the Americas with 8.6%

(2024: 9.3%), and Australia with 6.0% (2024: 6.0%).

The top five countries within Rest of Europe based on outstandings were

Italy (€25.2 billion), Romania (€14.0 billion), Switzerland (€10.9 billion),

Türkiye (€9.7 billion) and Ireland (€5.2 billion).

The main contributors for the overall increase in outstanding are Germany

(€10.6 billion), Spain (€ 6.1 billion), Poland (€ 5.8 billion), and the

Netherlands (€4.8 billion).

Private Individuals remained the largest composition of portfolio balances

for the Netherlands at 62.0% (2024: 58.3%), Belgium at 37.7%

(2024: 37.4%), Germany at 68.5% (2024: 68.8%), and Australia at 68.1%

(2024: 66.1%).The decrease in Central Banks is mainly attributed to the

Netherlands (€13.8 billion), Belgium (€3.6 billion), and Asia (€3.1 billion).

In individual countries, the total share of investment grade/non-

investment grade remains substantial for the Netherlands at 98.5%

(2024: 98.5%), Germany at 98.7% (2024: 98.9%), and Belgium 96.8%

(2024: 96.6%).

In Europe, the increase in investment grade outstandings was mainly

observed in Germany (€11.9 billion), Spain (€ 8.4 billion), Poland (€ 5.2

billion), and France (€3.0 billion).

The net decrease in non-investment grade outstandings was mainly

observed in Spain (€ 2.4 billion), America (€1.9 billion), and Germany (€1.7

billion).


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	164


Outstandings by economic sectors and geographical area (*) 1
in EUR million	Region													Total
Industry	Netherlands	Belgium	Germany	Poland	Spain	United Kingdom	Luxembourg	France	Rest of Europe	America	Asia	Australia	Africa	2025
Private Individuals	133,644	47,047	114,235	18,871	29,412	117	2,734	2,038	18,761	183	128	41,294	20	408,482
Central Banks	8,742	6,621	13,938	1,499	577	3,791	6,088		6,912		6,426	1,388		55,983
Natural Resources	2,220	1,257	869	909	156	2,848	2,254	261	10,730	8,974	8,830	1,396	281	40,985
Real Estate	17,212	14,082	1,184	2,356	1,749	679	3,257	3,055	3,805	2,591	1,409	3,309		54,689
Commercial Banks	1,482	504	5,605	493	754	4,917	6,808	5,228	8,205	9,182	10,762	398	164	54,501
Non-Bank Financial Institutions	3,577	1,536	5,717	2,295	880	8,040	6,819	6,255	5,738	21,294	3,451	1,659	10	67,271
Central Governments	3,297	14,525	374	11,768	6,692	31	186	5,485	11,463	14,146	935	400	580	69,880
Transportation & Logistics	4,652	2,132	1,239	1,759	698	2,384	967	839	6,048	3,665	6,196	663	692	31,934
Utilities	1,678	1,868	3,890	1,127	1,932	3,184	539	593	4,291	6,144	1,376	2,067	121	28,809
Food, Beverages & Personal Care	8,415	3,675	604	2,425	340	261	1,472	801	2,998	2,358	1,269	476	1	25,096
Services	5,322	8,420	1,906	1,639	127	1,123	306	394	1,464	1,106	873	585	1	23,265
General Industries	5,118	3,232	1,304	2,957	208	262	476	550	4,399	2,575	1,461	322	25	22,890
Lower Public Administration	2,236	7,362	10,121	815	682		235	3,432	520	1,462	38	4,528		31,433
Other	18,125	12,579	5,685	9,053	2,413	3,169	1,290	1,277	11,584	12,097	8,044	2,127	287	87,730
Total	215,720	124,841	166,672	57,966	46,620	30,805	33,431	30,207	96,919	85,775	51,198	60,613	2,181	1,002,947

Rating class
Investment grade	171,615	74,908	148,033	41,249	41,114	25,930	29,551	24,917	71,116	71,271	45,214	50,441	147	795,507
Non-investment grade	40,889	45,899	16,505	14,477	4,771	4,664	3,586	5,048	22,521	12,841	5,430	9,527	1,821	187,976
Performing Restructuring	1,528	928	680	694	265	30	53	134	1,486	406	66	162	39	6,469
Non-performing loans	1,689	3,107	1,454	1,546	470	181	242	108	1,795	1,257	488	483	175	12,995
Total	215,720	124,841	166,672	57,966	46,620	30,805	33,431	30,207	96,919	85,775	51,198	60,613	2,181	1,002,947

1Geographical areas are based on country of residence, except for Private Individuals for which the geographical areas are based on the primary country of risk.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	165


Outstandings by economic sectors and geographical area (*) 1
in EUR million	Region													Total
Industry	Netherlands	Belgium	Germany	Poland	Spain	United Kingdom	Luxembourg	France	Rest of Europe	America	Asia	Australia	Africa	2024
Private Individuals	122,914	45,611	107,415	16,525	27,083	122	3,058	2,260	16,391	198	129	38,106	16	379,827
Central Banks	22,529	10,196	13,966	1,729	510	1,935	5,737		10,913		9,525	879		77,919
Natural Resources	2,197	1,531	881	778	152	3,021	2,503	405	11,212	8,475	8,989	1,593	159	41,899
Real Estate	16,749	13,387	1,218	2,085	1,595	552	3,446	2,713	3,707	3,220	1,066	3,642		53,381
Commercial Banks	1,285	314	4,129	695	376	4,733	5,268	5,074	7,779	10,700	9,394	1,336	157	51,240
Non-Bank Financial Institutions	2,872	1,766	5,147	2,874	249	8,479	6,031	5,932	5,174	23,367	3,518	1,255	55	66,719
Central Governments	1,416	11,009	51	9,435	5,308	48	82	3,202	9,203	15,377	288	488	589	56,497
Transportation & Logistics	4,290	2,076	1,426	1,623	679	2,262	828	765	7,407	3,983	6,912	504	781	33,536
Utilities	1,805	1,843	3,920	814	1,971	2,826	395	712	3,951	5,886	1,187	2,253	152	27,713
Food, Beverages & Personal Care	7,377	3,690	695	2,215	351	328	1,393	1,102	3,008	2,498	1,168	406	14	24,246
Services	4,919	8,431	1,852	1,538	122	869	540	310	1,271	1,265	516	680		22,312
General Industries	4,568	2,690	1,059	2,824	219	301	539	484	3,862	2,039	708	23	8	19,324
Lower Public Administration	782	6,824	7,435	608	557		246	3,091	476	1,554	44	4,941		26,557
Other	17,208	12,722	6,876	8,394	1,361	3,137	1,248	1,426	11,722	10,475	4,372	1,513	238	80,691
Total	210,913	122,091	156,071	52,136	40,533	28,613	31,314	27,476	96,076	89,037	47,815	57,618	2,170	961,863

Rating class
Investment grade	170,093	74,882	136,096	36,029	32,741	23,844	27,235	21,886	67,110	72,686	41,203	46,959	59	750,822
Non-investment grade	37,689	43,059	18,238	13,948	7,126	4,388	3,858	5,229	25,679	14,763	5,859	9,889	1,898	191,623
Performing Restructuring	1,579	1,078	305	701	234	59	56	54	1,369	443	30	203	4	6,114
Non-performing loans	1,552	3,071	1,432	1,458	432	322	166	307	1,918	1,145	723	568	210	13,303
Total	210,913	122,091	156,071	52,136	40,533	28,613	31,314	27,476	96,076	89,037	47,815	57,618	2,170	961,863

1Geographical areas are based on country of residence, except for Private Individuals for which the geographical areas are based on the primary country of risk.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	166

Credit risk mitigation (*)

ING uses various techniques and instruments to mitigate the credit risk

associated with an exposure and to reduce the losses incurred subsequent

to a default by a customer. The most common terminology used in ING for

credit risk protection is ‘cover’. While a cover may be an important

mitigant of credit risk and an alternative source of repayment, generally it

is ING’s practice to lend on the basis of the customer’s creditworthiness

rather than relying on the value of the cover.

Cover forms (*)

Within ING, there are two distinct forms of covers. First, where the asset

has been pledged to ING as collateral or security, ING has the right to

liquidate it should the customer be unable to fulfil its financial obligation.

As such, the proceeds can be applied towards full or partial compensation

of the customer's outstanding exposure. This may be tangible (such as

cash, securities, receivables, inventory, plant and machinery, and

mortgages on real estate properties) or intangible (such as patents,

trademarks, contract rights, and licences). Second, where there is a third-

party obligation, indemnification or undertaking (either by contract and/or

by law), ING has the right to claim from that third party an amount if the

customer fails in its obligations. The most common examples are

guarantees, such as parent guarantees, export credit insurances, or third-

party pledged mortgages. Insurance or reinsurance covers, including

comprehensive private risk insurance (CPRI) may be recognised as

guarantees and effectively function in an equivalent manner. ING accepts

credit risk insurance companies and export credit agencies (ECAs) as cover

providers.

Cover valuation methodology (*)

General guidelines for cover valuation are established with the objective of

ensuring consistent application within ING. These also require that the

value of the cover is monitored on a regular basis. Covers are revalued

periodically and whenever there is reason to believe that the market is

subject to significant changes in conditions. The frequency of monitoring

and revaluation depends on the type of cover.

The valuation method also depends on the type of covers. For asset

collateral, the valuation sources can be the customer’s balance sheet (e.g.

inventory, machinery, and equipment), nominal value (e.g. cash and

receivables), market value (e.g. securities and commodities), independent

valuations (e.g. commercial real estate) and market indices (e.g. residential

real estate). For third-party obligations, the valuation is based on the value

that is attributed to the contract between ING and that third party.

Where collateral values are used in the calculation of Stage 3 individual

loan loss provisions, haircuts may be applied to the valuation in specific

circumstances to sufficiently include all relevant factors impacting future

cash flows. ING applies haircuts to the collateral values of real estate,

shipping and aviation assets that are used in the calculation of the loss-

given-default in recovery scenarios. The haircut reflects the risks of

adverse price developments between the moment of valuation of an asset

and the actual settlement/cash receipt.

Cover values (*)

This section provides insight into the types of cover and the extent to

which exposures benefit from collateral or guarantees. The disclosure

differentiates between risk categories (lending, investment, money market

and pre-settlement). The most relevant types of cover include mortgages

(market values), financial collateral (cash and securities), guarantees, and

other covers (mainly pledges). The scope of covers in this overview has

been revised due to CRR3 implementation to align with regulatory

reporting. This explains the decrease in the values of 'other covers', which

had only a limited effect on the fully covered part of the portfolio, as ING's

portfolio remains well collateralised. Collateral covering financial market

transactions is valued on a daily basis (margining), and is as such not

included in the following tables. To mitigate the credit risk arising from

financial markets transactions, the bank enters into legal agreements

governing the exchange of financial collateral (high-quality government

bonds and cash).

The cover values are presented for the total portfolio of ING, both the

performing and non-performing portfolio.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	167


Cover values including guarantees received (*)
in EUR million		Cover type and value				Collateralisation
2025	Outstandings	Mortgages	Financial Collateral	Guarantees	Other covers	No cover	Partially covered	Fully covered
Consumer lending	407,552	905,028	5,317	37,473	842	7.8%	2.0%	90.2%
Business lending	383,536	186,276	31,834	166,953	215,177	42.1%	15.8%	42.1%
Investment and money market	151,639	—	—	1,506	—	99.6%	—%	0.4%
Total lending, investment and money market	942,727	1,091,304	37,151	205,932	216,019	36.6%	7.3%	56.1%
of which NPL	12,981	9,827	196	2,771	3,591	33.0%	18.5%	48.5%
Pre-settlement	60,220
Total Group	1,002,947


Cover values including guarantees received (*)
in EUR million		Cover type and value				Collateralisation
2024	Outstandings	Mortgages	Financial Collateral	Guarantees	Other covers	No cover	Partially covered	Fully covered
Consumer lending	378,832	865,466	6,257	25,428	55,115	6.5%	2.0%	91.5%
Business lending	368,570	163,143	24,838	119,410	484,148	34.1%	23.7%	42.2%
Investment and money market	153,493	—	—	1,115	95	99.3%	—%	0.7%
Total lending, investment and money market	900,894	1,028,609	31,095	145,953	539,357	33.6%	10.5%	55.9%
of which NPL	13,295	10,427	194	3,093	11,109	27.6%	27.7%	44.7%
Pre-settlement	60,968
Total	961,863

The above tables gives an overview of the collateralisation of ING’s total

portfolio. Excluding the pre-settlement portfolio, 56.1% (2024: 55.9%) of

ING’s outstandings were fully collateralised in 2025. Since investments

traditionally do not require covers, the ‘no covers’ percentage in this

portfolio is over 99.6%.

Consumer lending portfolio (*)

The consumer lending portfolio accounts for 40.6% (2024: 39.4%) of ING’s

total outstanding, primarily consisting of residential mortgage loans and

consequently most collateral consists of mortgages. Mortgage values are

collected in an internal central database and in most cases external data is

used to index the market value.

A significant part of ING’s residential mortgage portfolio is in the

Netherlands (2025: 35.0%, 2024: 35.0% ), Germany (2025: 27.0%,

2024: 27.3%), Belgium (including Luxembourg) (2025: 12.0%, 2024: 12.2%)

and Australia (2025: 10.9%, 2024: 10.6%).

Business lending portfolio (*)

Business lending accounts for 38.2% (2024: 38.3%) of ING’s total

outstanding. Business lending presented in this section does not include

pre-settlement, investment and money market exposures.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	168

Credit quality (*)

ING uses three distinct statuses to categorise the management of clients

with (perceived) deteriorating credit risk profiles. ING makes use of Early

Warning Indicators (EWIs) in daily credit risk management processes,

which relate to a change in (internal and/or external) circumstances or

outlook of the specific obligor, the sector or the portfolio. ING usually

classifies a client with a 'watch list' status (Business lending only) when

there are early warning indicators triggered that detect an increased risk

profile. Watch list status requires more than usual attention, increased

monitoring and quarterly reviews. Some clients with a watch list or EWI

status may develop into a performing restructuring status or a non-

performing status. When there is increasing doubt as to the performance

and collectability of the client’s contractual obligations, the loans are

managed by Global Credit Restructuring (GCR) or by restructuring units in

the various regions and business units. The statuses and links with rating

grades are illustrated in the table below.


Credit risk ratings
Internal Rating Grade	1-10	11-17	18-19	20-22
Category	Investment Grade	Non- investment Grade	Performing restructuring	Non- performing
Credit risk management	Regular incl EWI/watch list	Regular incl EWI/watch list	Credit restructuring	Credit restructuring
ECL Stage	1/21	1/21	2	3
1Stage 2 in case one of the Stage 2 triggers is hit, where Watchlist files are always Stage 2


Credit quality outstandings (*)
in EUR million	2025	2024
Performing not past due	879,378	823,478
Business lending performing past due	8,071	9,174
Consumer lending performing past due	895	802
Non-performing	12,981	13,295
Total lending and investment	901,325	846,749
Money market	41,402	54,145
Pre-settlement	60,220	60,968
Total	1,002,947	961,863

Past due obligations (*)

Retail Banking measures its portfolio in terms of payment arrears and

determines on a monthly basis if there are any significant changes in the

level of arrears. This methodology applies to Private Individuals as well as

Business lending. An obligation is considered ‘past due’ if it is more than

one day late, subject to materiality thresholds in line with Definition of

Default Regulation. ING aims to help its customers as soon as they are past

due by reminding them of their payment obligations. In its contact with

customers, ING aims to solve the (potential) financial difficulties by offering

a range of measures (e.g. payment arrangements, restructuring). If the

issues cannot be resolved because the customer is unable or unwilling to

pay, for example, the contract is sent to the recovery unit. The facility is

downgraded to risk rating 20 (non-performing) when the facility or obligor

– depending on the level at which the non-performing status is applied – is

more than 90 days past due and to risk rating 21 or 22 in case of an exit

scenario.

The table below represents the breakdown of lending and investment

credit risk outstandings that are performing by age and geographic area.

The past due but performing consumer lending outstanding increased by

€93 million, due to the increase in 1-30 days (€90 million) and 31-60 days

(€3 million).

The largest single country increase was in Belgium (€42 million), followed

by the Netherlands (€22 million), mainly in the 1-30 days bucket.

The largest decrease was seen in Australia (€21 million).


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	169


Ageing analysis (past due but performing): Consumer lending portfolio by geographic area, outstandings (*)
in EUR million		2025				2024
Region		Past due for 1–30 days	Past due for 31–60 days	Past due for 61–90 days	Total	Past due for 1–30 days	Past due for 31–60 days	Past due for 61–90 days	Total
Europe	Netherlands	84	32	6	122	62	35	4	101
	Belgium	219	60	26	305	185	49	29	263
	Germany	70	37	22	129	65	37	24	125
	Poland	58	6	3	68	61	9	4	74
	Spain	22	17	9	48	12	16	8	36
	Luxembourg	25	5	4	34	22	6	3	32
	Rest of Europe	121	23	6	150	93	15	4	112
America		0	1	0	1	0	0	0	1
Asia		0	1	0	1	0	0	0	0
Australia		29	8	1	38	38	19	2	59
Africa		0	0	0	0	0	0	0	0
Total		628	189	78	895	538	186	78	802


Ageing analysis (past due but performing): Business lending portfolio by geographic area, outstandings (*)
in EUR million		2025				2024
Region		Past due for 1–30 days	Past due for 31–60 days	Past due for 61–90 days	Total	Past due for 1–30 days	Past due for 31–60 days	Past due for 61–90 days	Total
Europe	Netherlands	586	31	9	626	929	14		943
	Belgium	476	22	10	508	1,187	17	13	1,217
	Germany	415	2	2	419	215	3	2	220
	Poland	403	31	15	449	173	17	19	209
	United Kingdom	516	531		1,046	830	8		838
	France	73			73	194			194
	Spain	9			9	26			26
	Luxembourg	212	9	1	222	367	51	5	423
	Rest of Europe	899	17	3	919	630	4	46	681
America		2,946	68		3,013	3,504	95		3,599
Asia		133			133	310			310
Australia		636	10	7	654	469	6		475
Africa						39			39
Total		7,303	720	47	8,071	8,873	215	86	9,174


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	170

Total past due but performing outstanding of business lending decreased

by €1.1 billion. The decrease was mainly witnessed in the 1–30 days past

due bucket (€1.6 billion) and was offset by the increase in 31-60 days (€0.5

billion) past due bucket, fully in the United Kingdom related to overdue

fees. The largest decreases were in Belgium (€0.7 billion) and America

(€0.6 billion), while the largest increase were in Australia (€0.2 billion),

Germany (€0.2 billion), Poland (€0.2 billion), and the United Kingdom (€0.2

billion).

Forbearance (*)

Forbearance occurs when a client is unable to meet their financial

commitments due to financial difficulties they are facing or are about to

face and ING grants them concessions. Forborne assets are assets for

which forbearance measures have been granted.

Forbearance may enable clients experiencing financial difficulties to

continue repaying their debt.

For business clients, ING mainly applies forbearance measures to support

clients with fundamentally sound business models that are experiencing

temporary difficulties. The aim is to maximise the client’s repayment

ability, thereby avoiding a default situation, and help the client to return to

a performing situation.

For ING Retail units, clear criteria have been established to determine

whether a client is eligible for the forbearance process. Specific approval

mandates are in place to approve the measures, as well as procedures to

manage, monitor, and report the forbearance activities.

ING reviews the performance of forborne exposures at least quarterly,

either on a case-by-case (Business) or portfolio (Retail) basis.

Both performing (risk ratings 1-19) and non-performing (risk ratings 20-22)

exposures are eligible for Forbearance measures. ING uses specific criteria

to move forborne exposures from non-performing to performing or to

remove the forbearance statuses that are consistent with the

corresponding European Banking Authority (EBA) standards. An exposure

is reported as forborne for a minimum of two years. An additional one-

year probation period is applied to forborne exposures that move from

non-performing back to performing.


Summary Forborne portfolio (*)
in EUR million	2025				2024
Business line	Outstandings	Of which: performing	Of which: non-performing	% of total portfolio(1)	Outstandings	Of which: performing	Of which: non-performing	% of total portfolio(1)
Business line	Outstandings	Of which: performing	Of which: non-performing	% of total portfolio(1)	Outstandings	Of which: performing	Of which: non-performing	% of total portfolio(1)
Wholesale Banking	5,910	3,194	2,716	1.7%	5,934	3,191	2,743	1.9%
Retail Banking	7,551	4,538	3,013	1.4%	6,883	3,987	2,897	1.3%
Total	13,461	7,732	5,729	1.5%	12,817	7,178	5,640	1.5%


Summary Forborne portfolio by forbearance type (*)
in EUR million	2025				2024
Forbearance type	Outstandings	Of which: performing	Of which: non-performing	% of total portfolio(1)	Outstandings	Of which: performing	Of which: non-performing	% of total portfolio(1)
Forbearance type	Outstandings	Of which: performing	Of which: non-performing	% of total portfolio(1)	Outstandings	Of which: performing	Of which: non-performing	% of total portfolio(1)
Loan modification	11,883	6,581	5,302	1.3%	11,726	6,734	4,993	1.4%
Refinancing	1,578	1,151	427	0.2%	1,091	444	647	0.1%
Total	13,461	7,732	5,729	1.5%	12,817	7,178	5,640	1.5%

% of total portfolio is based on lending and investment outstandings.

Forborne assets increased by €644 million, mainly due to the increase of

€667 million in Retail Banking, which was offset by a €24 million decrease

in Wholesale Banking. The rise in Retail Banking forborne assets was

primarily driven by residential mortgages in the Netherlands, which

contributed €608 million. This increase was largely the result of the

implementation of an updated framework, under which more clients are

classified as forborne, while outflow is only allowed after a two-year

probation period.

In terms of forbearance type, the increase is mainly witnessed in

refinancing type (€487 million) driven by a few larger files in Wholesale

Banking.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	172

Wholesale Banking (*)

Wholesale Banking forborne assets amounted to €5.9 billion (2024:

€5.9 billion), which represented 1.7% (2024: 1.9%) of the total Wholesale

Banking portfolio.

The net decrease in Wholesale Banking forborne assets was driven by a

€27 million reduction in non-performing forborne exposure and partially

offset by a €3 million rise in performing forborne exposures.

Wholesale Bankings' forborne assets show an increase in Telecom due to

refinancing, which was offset by a decrease in other sectors, such as real

estate, food, beverages & personal care, chemicals, health &

pharmaceuticals and natural resources. These five sectors accounted for

69.6% of the total Wholesale Banking forborne outstandings.


Wholesale Banking: Forborne portfolio by geographical area (*)
in EUR million		2025			2024
Region		Outstandings	Of which: performing	Of which: non- performing	Outstandings	Of which: performing	Of which: non- performing
Region		Outstandings	Of which: performing	Of which: non- performing	Outstandings	Of which: performing	Of which: non- performing
Europe	Netherlands	316	191	124	217	69	148
	Belgium	3	3	0	172	165	7
	Germany	336	29	307	372	62	310
	Poland	662	305	357	630	284	346
	United Kingdom	676	516	160	444	266	178
	Italy	547	519	28	389	353	36
	Rest of Europe	1,081	558	523	1,339	940	399
America		1,313	545	768	1,586	867	719
Asia		711	313	398	652	111	541
Australia		212	177	35	79	34	44
Africa		53	37	15	54	40	15
Total		5,910	3,194	2,716	5,934	3,191	2,743


Wholesale Banking: Forborne portfolio by economic sector (*)
in EUR million	2025			2024
Industry	Outstandings	Of which: performing	Of which: non- performing	Outstandings	Of which: performing	Of which: non- performing
Industry	Outstandings	Of which: performing	Of which: non- performing	Outstandings	Of which: performing	Of which: non- performing
Natural Resources	605	308	297	781	424	356
Real Estate	945	375	570	1,115	703	412
Transportation & Logistics	145	48	97	214	83	131
Food, Beverages & Personal Care	629	289	340	810	415	395
Services	172	149	24	211	176	34
Automotive	263	139	124	332	183	149
Utilities	497	218	279	677	301	376
General Industries	197	42	155	127	70	58
Retail	111	41	70	149	21	128
Chemicals, Health & Pharmaceuticals	619	74	545	668	136	532
Builders & Contractors	179	174	4	122	118	5
Telecom1	1,314	1,166	148	486	383	103
Other	234	172	62	243	178	65
Total	5,910	3,194	2,716	5,934	3,191	2,743

1The presentation has been revised to separately disclose Telecom. Comparative figures have been adjusted accordingly.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	174

Non-performing loans (*)

ING has aligned the regulatory concept of non-performing with that of the

definition of default. Hence, borrowers are classified as non-performing

when a default trigger occurs (non-exhaustive list):

§ING believes the borrower is unlikely to pay. The borrower has

evidenced significant financial difficulty, to the extent that it will have a

negative impact on the future cash flows of the financial asset. The

following events could be seen as indicators of financial difficulty:

–The borrower (or third party) has started insolvency proceedings;

–A group company/co-borrower has NPL status;

–Indication of fraud (affecting the company’s ability to service its

debt);

–There is doubt as to the borrower’s ability to generate stable and

sufficient cash flows to service its debt;

–Restructuring of debt; and

–ING has granted concessions relating to the borrower’s financial

difficulty, the effect of which is a reduction in expected future cash

flows of the financial asset below current carrying amount.

§The obligor has failed in the payment of principal, interest, or fees; the

total past due amount is above the materiality threshold, and this

remains the case for more than 90 consecutive days.

Furthermore, Wholesale Banking has an individual name approach, using

early warning indicators to signal possible future issues in debt service.

Also in Retail Banking early warning indicator frameworks have been

implemented.

The table below represents the breakdown of credit risk outstandings that

have been classified as non-performing by sector and business line.


Non-performing Loans: Outstandings by economic sector and business lines (*) 1
in EUR million	Wholesale Banking		Retail Banking		Total
Industry	2025	2024	2025	2024	2025	2024
Private Individuals	3	4	4,899	4,766	4,902	4,769
Natural Resources	945	965	115	99	1,061	1,064
Food, Beverages & Personal Care	372	452	325	357	697	809
Transportation & Logistics	251	347	227	157	478	504
Services	94	102	375	394	469	495
Real Estate	586	831	656	603	1,241	1,434
General Industries	243	236	471	451	713	687
Builders & Contractors	31	51	541	445	571	496
Retail	184	157	189	224	373	381
Utilities	336	582	26	19	362	600
Chemicals, Health & Pharmaceuticals	602	654	150	185	752	839
Telecom2	170	151	36	12	206	163
Other	771	666	383	387	1,154	1,052
Total	4,589	5,196	8,392	8,099	12,981	13,295

1Based on lending and investment outstandings.

2The presentation has been revised to separately disclose Telecom. Comparative figures have been adjusted accordingly.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	175


Non-performing loans: Outstandings by economic sectors and geographical area (*)
in EUR million	Region													Total
Industry	Netherlands	Belgium	Germany	Poland	Spain	United Kingdom	France	Luxembourg	Rest of Europe	America	Asia	Australia	Africa	2025
Private Individuals	697	1,481	1,113	220	357	10	8	39	574	2	2	399	1	4,902
Natural Resources	137	84		28				14	584	23	191			1,061
Food, Beverages & Personal Care	167	94	1	94		19	6		126	59	131			697
Transportation & Logistics	87	40		136	47			22	72	22	10	1	41	478
Services	68	262		75	1		3	4	16	26	13			469
Real Estate	24	419	59	115	45		47	101	8	377		48		1,241
General Industries	137	138	38	196	20			13	130	10	31			713
Builders & Contractors	89	219	7	182				8	66					571
Retail	80	79	33	56			1	4	15	105				373
Utilities	14	10	19	8		151		1	12	80	33	35		362
Chemicals, Health & Pharmaceuticals	47	65	112	346			43	25	64	49				752
Telecom	37	4		3					15	146	2			206
Other	102	209	72	88		2	1	10	105	358	75		132	1,154
Total	1,686	3,105	1,454	1,546	470	181	108	242	1,786	1,257	488	483	175	12,981


Non-performing loans: Outstandings by economic sectors and geographical area (*)
in EUR million	Region													Total
Industry	Netherlands	Belgium	Germany	Poland	Spain	United Kingdom	France	Luxembourg	Rest of Europe	America	Asia	Australia	Africa	2024
Private Individuals	646	1,461	1,066	210	304	10	8	44	545	2	2	469		4,769
Natural Resources	13	54		33					569	31	343	21		1,064
Food, Beverages & Personal Care	196	154	1	93		23	5		158	51	127			809
Transportation & Logistics	93	40	3	124	47			1	136			1	59	504
Services	57	293	5	87	2	1	3	5	10	34				495
Real Estate	12	374	63	114	59		59	90	6	606		52		1,434
General Industries	153	123	24	147	20		2	1	170	17	30			687
Builders & Contractors	68	175	5	162				7	78					496
Retail	53	97	39	62			3		14	97	15	1		381
Utilities	13	8	25	21		285			12	128	109			600
Chemicals, Health & Pharmaceuticals	37	94	84	340		1	110		113	36		24		839
Telecom	7	1		3			44		14	90	4			163
Other	202	198	117	60		2	72	17	90	54	92		150	1,052
Total	1,549	3,071	1,432	1,457	432	322	307	166	1,916	1,145	723	567	210	13,295


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	176

In 2025, the NPL portfolio decreased to €13.0 billion (2024: €13.3 billion),

mainly driven by the decrease of €0.6 billion in Wholesale Banking. The

decrease was offset by the increase in Retail Banking (€0.3 billion) in line

with strong portfolio growth, mainly in residential mortgages.

Total net decrease was mainly seen in sectors Utilities, Real Estate and

Food, Beverage & Personal Care while the largest increase was in Private

Individuals.

Loan loss provisioning (*)

ING recognises loss allowances based on the expected credit loss (ECL)

model of IFRS 9, which is designed to be forward-looking. The IFRS 9

impairment requirements are applicable to on-balance-sheet financial

assets measured at amortised cost or fair value through other

comprehensive income (FVOCI), such as loans, debt securities, and lease

receivables, as well as off-balance-sheet items such as undrawn loan

commitments and financial- and non-financial guarantees issued.

ING distinguishes between two types of calculation methods for credit loss

allowances:

§Collective 12-month ECL (Stage 1) and collective lifetime ECL (Stage 2)

for portfolios of financial instruments, as well as collective lifetime ECL

for credit-impaired exposures (Stage 3) below €1 million; and

§Individual lifetime ECL for credit-impaired (Stage 3) financial

instruments with exposures above €1 million.

IFRS 9 models (*)

ING’s IFRS 9 models leverage on the internal rating-based (IRB) models (PD,

LGD, EAD), which include certain required conservatism. To include IFRS 9

requirements, such regulatory conservatism is removed from the ECL

parameters (PD, LGD and EAD). The IFRS 9 models apply two other types of

adjustments to the IRB ECL parameters: (i) to the economic outlook and (ii)

for Stage 2 and Stage 3 assets only, to the lifetime horizon. The IFRS 9

model parameters are estimated based on statistical techniques and

supported by expert judgement.

ING has aligned the definition of default for regulatory purposes with the

definition of ‘credit-impaired’ financial assets under IFRS 9 (Stage 3). ING

has also aligned its definition of default between IFRS 9 and the regulatory

technical standards (RTS) and EBA guidelines.

Climate and environmental risks in IFRS 9 models (*)

Climate risk drivers (physical and transition risks) can reduce the ability of

businesses and households to fulfil their obligations due, under existing

lending contracts. These climate risks are partly reflected in IFRS9 ECL

through regular credit risk transmission channels such as the

macroeconomic forecast and relevant risk parameters.

On the other hand, future physical or transition risks from climate change

are not yet fully captured within the current ECL models. In our

assessment of physical risks, it is generally expected that these risks will

only become financially significant on the long-term horizon.

Consequently, for short- and medium-term loans, such risks are not

expected to lead to significant credit deterioration over the exposure’s

lifetime. For the long term, the probability and timing of physical risk

events remain highly uncertain. ING is however actively enhancing the

integration of physical and transition risks into collateral valuations,

ensuring that effects on property values are appropriately captured.

In case of risk events that have already occurred (e.g. floods, stranded

assets), the impact of such events is assessed in the calculation of Stage 3

individual provisions, collective SICR or management adjustments to ECL

models. For example, we consider whether affected assets have suffered

from a significant increase in credit risk (or are credit impaired) and

whether the ECL is appropriate.

Additionally, a management adjustment to ECL models for business

clients was introduced to specifically cover for medium- to long-term

transition risk on high greenhouse gas-emitting sectors. The management

adjustment reflects the risk of financial loss foreseen on the longer horizon

for lenders with higher transition risk in these high greenhouse gas-

emitting sectors as consequence of future carbon taxation. ‘See

Management adjustments applied this reporting period’.

ING is continuously improving on climate risk data, which will enable us to

further embed climate risks into the IFRS 9 ECL models. For more

information on ESG risk management, see ‘ESG risk’.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	177


Reconciliation gross carrying amount (IFRS 9 eligible) and statement of financial position
in EUR million	2025							2024
	Gross carrying amount	Loan loss provisions	Cash and on-demand bank positions	Reverse repurchase transactions	Cash collateral	Other	Statement of financial position	Gross carrying amount	Loan loss provisions	Cash and on-demand bank positions	Reverse repurchase transactions	Cash collateral	Other	Statement of financial position
Amounts held at central banks	53,671	-17	-1,297			532	52,889	71,280	-14	-1,550			637	70,353
Loans and advances to banks	8,445	-18	3,053	6,836	2,649	239	21,204	4,685	-22	3,195	10,777	2,362	773	21,770
Financial instruments FVOCI loans	3,244	-6					3,238	1,671	-7				-56	1,608
Financial instruments FVOCI debt securities	50,868	-15				-36	50,817	42,185	-12				46	42,219
Securities at amortised cost	54,366	-11				-487	53,867	50,701	-15				-413	50,273
Loans and advances to customers	721,423	-5,894		3,866	4,595	3,743	727,733	679,422	-5,833		3,471	4,956	1,595	683,611
Total on-balance (IFRS 9 eligible)	892,017	-5,961	1,756	10,702	7,244	3,990	909,748	849,944	-5,902	1,645	14,248	7,318	2,581	869,834
Guarantees and irrevocable facilities (IFRS 9 eligible)	243,392	-141						198,420	-146
Total gross carrying amount (IFRS 9 eligible)	1,135,409	-6,101						1,048,364	-6,049

This table presents the reconciliation between the statement of financial

position and the gross carrying amounts used for calculating the expected

credit losses. No expected credit loss is calculated for cash, on-demand

bank positions, reverse repurchase transactions, cash collateral received in

respect of derivatives, and other. Therefore, these amounts are not

included in the total gross carrying amount (IFRS 9 eligible). Other includes

hedge valuation adjustments, deferred acquisition costs on residential

mortgages, and a receivable which is offset against a liquidity facility.

Portfolio quality (*)

The table below describes the portfolio composition over the different

IFRS 9 stages and rating classes. The Stage 1 portfolio represents 92.0%

(2024: 91.1%) of the total gross carrying amounts, mainly composed of

investment grade, while Stage 2 makes up 6.8% (2024: 7.6%) and Stage 3

makes up 1.2% (2024: 1.3%) of the total gross carrying amounts,

respectively.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	178


Gross carrying amount per IFRS 9 stage and rating class (*) 1,2
in EUR million		12-month ECL (Stage 1)				Lifetime ECL not credit impaired (Stage 2)				Lifetime ECL credit impaired (Stage 3)				Total
Rating class		Gross carrying amount		Provisions		Gross carrying amount		Provisions		Gross carrying amount		Provisions		Gross carrying amount		Provisions
		2025	2024	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024
Investment grade	1 (AAA)	79,938	79,076	2	1	126	281							80,064	79,357	2	1
	2-4 (AA)	146,878	140,671	11	10	1,437	1,579	1	1					148,315	142,250	13	11
	5-7 (A)	299,699	244,241	39	21	5,394	6,908	6	8					305,093	251,149	45	29
	8-10 (BBB)	334,845	310,324	77	55	19,168	24,683	43	55					354,012	335,008	119	110
Non-investment grade	11-13 (BB)	156,373	154,348	165	190	17,217	18,479	89	91					173,589	172,827	254	281
	14-16 (B)	26,187	25,377	147	124	22,668	17,433	357	366					48,855	42,811	504	490
	17 (CCC)	412	905	5	8	4,682	3,992	224	173					5,094	4,897	228	181
Performing Restructuring	18 (CC)					4,349	4,059	262	233					4,349	4,060	262	233
Performing Restructuring	19 (C)					2,447	2,474	198	203					2,447	2,474	198	203
Non-performing loans	20-22 (D)									13,590	13,742	4,476	4,509	13,590	13,742	4,476	4,509
Total		1,044,332	954,943	446	409	77,487	79,888	1,179	1,130	13,590	13,742	4,476	4,509	1,135,409	1,048,574	6,101	6,049

1Compared to the credit risk portfolio, the differences are due to undrawn committed amounts (€200 billion; 2024: €156 billion) and other positions (2025: nil; 2024:€6 billion) not included in credit outstandings and non-IFRS 9 eligible assets (€ 68 billion; 2024: €75 billion) included in credit outstandings but not in the

gross carrying amounts.

2Stage 3 lifetime credit impaired provision includes €29 million (2024: €21 million) on purchased or

originated credit impaired.

Changes in gross carrying amounts and loan loss provisions (*)

The table below provides a reconciliation by stage of the gross carrying

amount and allowances for loans and advances to banks and customers,

including loan commitments and financial guarantees. The transfers of

financial instruments represent the impact of stage transfers upon the

gross carrying/nominal amount and associated allowance for ECL. This

includes the net-remeasurement of ECL arising from stage transfers, for

example, moving from a 12-month (Stage 1) to a lifetime (Stage 2) ECL

measurement basis.

The net-remeasurement line represents the changes in provisions for

facilities that remain in the same stage.

Please note the following comments with respect to the movements

observed in the table below:

§Stage 3 gross carrying amount decreased by €0.2 billion from €13.7

billion as at 31 December 2024 to €13.6 billion as at 31 December 2025,

mainly as a result of €3.5 billion net inflow into NPL (credit impaired) in

2025, which is offset by €2.3 billion derecognitions and repayments

and €1.5 billion write-offs and disposals. Following the decrease in

carrying amount, Stage 3 provisions slightly decreased by €33 million.

§Stage 2 gross carrying amounts decreased by €2.4 billion from €79.9

billion as at 31 December 2024 to €77.5 billion as at 31 December 2025,

largely driven by €15.7 billion net transfers from Stage 1 into Stage 2,

including the impact of changes in risk drivers (including updated

macro-economic forecasts), model redevelopments mainly for

Wholesale Banking models, and new Stage 2 overlays. This was offset

by a decrease of exposure by €18.1 billion due to derecognised

financial assets (including sales and repayments) and €1.2 billion

exposure moving to Stage 3. Stage 2 provisions increased by € 49.3

million to €1.2 billion as of 31 December 2025.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	179


Changes in gross carrying amounts and loan loss provisions (*) 1, 2
in EUR million	12-month ECL (Stage 1)		Lifetime ECL not credit impaired (Stage 2)		Lifetime ECL credit impaired (Stage 3)		Total		12-month ECL (Stage 1)		Lifetime ECL not credit impaired (Stage 2)		Lifetime ECL credit impaired (Stage 3)		Total
	Gross carrying amount	Provisions	Gross carrying amount	Provisions	Gross carrying amount	Provisions	Gross carrying amount	Provisions	Gross carrying amount	Provisions	Gross carrying amount	Provisions	Gross carrying amount	Provisions	Gross carrying amount	Provisions
	2025								2024
Opening balance	954,943	409	79,888	1,130	13,742	4,509	1,048,574	6,049	937,633	517	75,454	1,435	11,956	3,887	1,025,043	5,839
Transfer into 12-month ECL (Stage 1)	21,773	21	-21,555	-199	-218	-35		-212	20,486	22	-20,236	-195	-249	-34		-207
Transfer into lifetime ECL not credit impaired (Stage 2)	-37,208	-50	38,174	533	-966	-115		368	-43,155	-49	43,900	429	-745	-96		285
Transfer into lifetime ECL credit impaired (Stage 3)	-2,534	-14	-2,172	-138	4,705	1,259		1,108	-2,980	-18	-2,856	-235	5,836	1,802		1,548
Net remeasurement of loan loss provisions		7		-53		349		302		-181		-137		185		-133
New financial assets originated or purchased	263,371	189			22	2	263,393	191	212,516	192					212,516	192
Financial assets that have been derecognised	-119,098	-78	-12,295	-147	-1,422	-240	-132,814	-465	-126,858	-76	-11,840	-153	-1,450	-257	-140,148	-485
Net drawdowns and repayments	-57,493		-5,739		-853		-64,085		-41,763		-4,393		-309		-46,465
Changes in models/risk parameters		-33		71		-35		3		8		-6		-22		-20
Increase in loan loss provisions		43		68		1,185		1,296		-102		-297		1,578		1,179
Write-offs					-937	-937	-937	-937					-1,017	-1,017	-1,017	-1,017
Disposals	-666	-3	-84	-3	-564	-286	-1,314	-291	-935	-1	-141	-8	-279	-215	-1,355	-225
Recoveries of amounts previously written off						58		58						69		69
Other movements	21,242	-4	1,269	-16	80	-53	22,591	-73		-5				208		203
Closing balance	1,044,332	446	77,487	1,179	13,590	4,476	1,135,409	6,101	954,943	409	79,888	1,130	13,742	4,509	1,048,574	6,049

1Stage 3 lifetime credit impaired provision includes €29 million (2024: €21 million) on purchased or originated credit impaired.

2The addition to the loan provision (in the consolidated statement of profit or loss) amounts to €1,304 million (2024: €1,194 million) of which €1,301 million (2024: €1,170 million) related to IFRS 9 eligible financial assets, €-5 million (2024: €9 million) to IFRS eligible commitments and €8 million (2024: €15 million) to

modification gains and losses on restructured financial assets.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	180


Exposure per stage, coverage ratio and stage ratios 2
in EUR million	2025			2024
Balance sheet	Gross carrying amount	Loan loss provisions	Stage ratio	Gross carrying amount	Loan loss provisions	Stage ratio
Loans and advances to banks (including central banks)	62,116	35		75,964	35
Stage 1	60,430	5	97%	74,632	4	98%
Stage 2	1,609	18	3%	1,258	15	2%
Stage 3	77	12	0%	75	16	0%

Loans and advances to customers	721,423	5,894		679,422	5,833
Of which: Residential mortgages	374,780	822		348,433	814
Stage 1	341,281	49	91%	315,775	49	91%
Stage 2	30,181	288	8%	29,341	307	8%
Stage 3	3,318	485	1%	3,317	458	1%
Of which: Consumer lending (excl. Residential mortgages)	31,306	946		26,936	957
Stage 1	27,302	137	87%	22,556	112	84%
Stage 2	2,575	159	8%	3,090	191	11%
Stage 3	1,429	649	5%	1,290	654	5%
Of which: Loans to public authorities	29,089	21		23,930	17
Stage 1	28,568	8	98%	23,214	6	97%
Stage 2	298	3	1%	464	3	2%
Stage 3	222	11	1%	252	8	1%
Of which: Corporate lending	286,249	4,105		280,123	4,045
Stage 1	251,280	197	88%	238,606	196	85%
Stage 2	27,265	661	10%	33,427	575	12%
Stage 3	7,704	3,247	3%	8,090	3,274	3%

Other IFRS 9 eligible financial Instruments 1	351,870	173		293,187	180
Stage 1	335,471	51	95%	280,161	43	96%
Stage 2	15,559	49	4%	12,308	39	4%
Stage 3	840	72	0%	718	98	0.2%

Total gross carrying amount (IFRS 9 eligible)	1,135,409	6,101		1,048,573	6,049

1Includes off-balance sheet IFRS 9 eligible guarantees and irrevocable facilities. See Note 1 'Basis of preparation and material accounting policy information'.

2The exposure classification to residential mortgages, consumer lending, and corporate lending is

aligned to the regulatory definition.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	181

Macroeconomic scenarios and sensitivity analysis of key sources

of estimation uncertainty (*)

Methodology (*)

This section outlines our methodology for adopting and generating

macroeconomic scenarios. We apply this methodology when producing

our probability-weighted ECL, incorporating alternative scenarios and

management adjustments where necessary. These adjustments are made

when management believes the consensus forecast does not fully capture

the extent of recent credit or economic events. The macroeconomic

scenarios are applicable to the whole ING portfolio in the scope of IFRS 9

ECLs.

The IFRS 9 standard, with its inherent complexities and potential impact on

the carrying amounts of our assets and liabilities, represents a key source

of estimation uncertainty. In particular, ING’s reportable ECL numbers are

sensitive to the forward-looking macroeconomic forecasts used as model

inputs, the probability weights applied to each of the three scenarios, and

the criteria for identifying a significant increase in credit risk. As such,

these crucial components require consultation and management

judgement, and are subject to extensive governance.

Baseline scenario (*)

As a baseline for IFRS 9, ING has adopted a market-neutral view combining

consensus forecasts for economic variables (GDP, unemployment) with

market forwards (for interest rates, exchange rates, and oil prices). Input

from a leading third-party service provider is used to complement the

consensus with consistent projections for variables for which there are no

consensus estimates available (most notably house prices and – for some

countries – unemployment), to generate alternative scenarios, to convert

annual consensus information to a quarterly frequency, and to ensure

general consistency of the scenarios. As the baseline scenario is consistent

with the consensus view, it can be considered as free from any bias.

The relevance and selection of macroeconomic variables is defined by the

ECL models under credit risk model governance. The scenarios are

reviewed and challenged by a panels of ING experts.

Alternative scenarios and probability weights (*)

Two alternative scenarios are taken into account: an upside and a

downside scenario. The alternative scenarios have statistical

characteristics as they are based on the forecast deviations of the leading

third-party service provider.

To understand the baseline level of uncertainty around any forecast, the

leading third-party service provider keeps track of all its deviations (so-

called forecast errors) of the past 30 years. The distribution of forecast

errors for GDP, unemployment, house prices, and share prices is applied to

the baseline forecast creating a broad range of alternative outcomes. In

addition, to understand the balance of risks facing the economy in an

unbiased way, the leading third-party service provider runs a survey with

respondents from around the world and across a broad range of

industries. In this survey, respondents put forward their views of key risks.

Following the survey results, the distribution of forecast errors (that is

being used for determining the scenarios) may be skewed.

For the downside scenario, ING has chosen the 90th percentile of that

distribution because this corresponds with the way risk management

earnings-at-risk is defined within the Group. The upside scenario is

represented by the 10th percentile of the distribution. The applicable

percentiles of the distribution imply a 20 percent probability for each

alternative scenario. Consequently, the baseline scenario has a 60 percent

probability weighting. Please note that, given their technical nature, the

downside and upside scenarios are not based on an explicit specific

narrative and have not changed compared to previous year.

Macroeconomic scenarios applied (*)

The macroeconomic scenarios applied in the calculation of loan loss

provisions are based on the consensus forecasts.

Baseline assumptions (*)

The general picture that the consensus conveys is that global economic

growth is slowing compared to recent years. US growth is expected to

continue to outpace European markets, but the gap is narrowing down.

China is expected to continue a declining growth trend, but still at higher

rates than seen in advanced markets. Inflation is expected to remain near

target for most advanced economies, but a bit above for the United States.

With interest rates moderating, monetary conditions are turning more

favourable for growth. For the housing market, continued price growth is

expected for almost all main markets.

The December 2025 consensus expects global output (as measured by the

weighted average GDP growth rate of ING’s 25 main markets) to remain at

a constant 2.4% from 2025-2027.

The eurozone economy has shown more resilience than expected despite

global headwinds, with sluggish but positive growth through 2025. The

coming years are expected to see modest growth rates as well. The trade

environment continues to be plagued by higher US tariffs and a stronger

euro. Expectations of a pickup in growth over the course of 2026 come

from stronger consumer spending and investment. German infrastructure

spending is expected to add to this momentum. Southern European

economies continue to benefit from European Recovery Fund investments.

Consensus expects the eurozone to have grown by 1.4% in 2025, before

slowing to 1.1% in 2026 and then recovering to 1.3% in 2027.

Elsewhere in Europe, the growth outlook is stronger. Poland’s growth

momentum remains solid, growing faster than its European peers. The key

growth drivers over the near-term forecast are consumption and public

investments, such as those carried out under the National Recovery Plan

(KPO). The economy is expected to grow by 3.6% in 2025, picking up to

3.7% in 2026 and settling at 3.2% in 2027. The consensus expectation for

Türkiye is to see stable growth of 3.5% and 3.4% in 2025 and 2026, as


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	182

domestic demand remains resilient and fixed investments and inventories

see an uptick. For 2027, a recovery to 3.7% is expected.

The American economy has held its ground despite the tariff war and

slowing employment growth. Its characterisation by a K-shaped economy

where most of the growth comes from high-income consumers and tech

investments is likely to continue in 2026. Tariffs are not feeding into

inflation as much as expected earlier in the year, and inflation

expectations remain benign, although still above the 2% target. This has

prompted the Federal Reserve to resume its rate cutting cycle. Inflation is

expected to remain around 2.8% and 2.9% in 2025 and 2026 before

steadying down at 2.4% in 2027.The US economy is expected to

experience steady growth of 2.0% in 2025-2027.

For China, economic underperformance continues as it still struggles with

the impact of the real estate correction and weak domestic demand.

However, the economy has come out resilient to the tariff war with a trade

surplus reaching record levels, making external demand the key driver of

2025. This enables the economy to reach its short-term growth target, but

medium-term consensus continues to be downbeat for the moment

because of its weak domestic economy. For 2025, consensus expects

4.9% growth, down to 4.5% in 2026 and 4.3% in 2027.

Economic momentum in Australia is expected to be soft, as much of the

growth in 2025 came from government consumption. The economy is

lacking a clear growth engine, with the private sector struggling against

restrictive policy settings and consumers facing a tough outlook with

weaker employment growth and real wage gains moderating. Growth is

expected to come in at 1.8% in 2025, with a pick-up expected for 2026 to

2.2% and 2.3% for 2027.

When compared to the June 2025 consensus forecast, the December 2025

forecast has improved slightly because of better than expected growth in

major economies. Global GDP is expected to increase by 2.4% in both

2025 and 2026 (compared to 2.0% and 2.1% assumed before). The global

economy showed quite some resilience in 2025 despite trade and

geopolitical tensions, as GDP growth has continued despite political

disruptions. Markets, too, have adjusted to the new world of volatility.

Alternative scenarios and risks (*)

The baseline scenario assumes steady economic growth. However, further

escalation of geopolitical tensions and global trade uncertainty are seen as

key downside risks to the global economy. The balance of risks to the

baseline outlook is negative, and the alternative scenarios have a

downward skew.

The downside scenario sees a recession in 2026 and 2027 for most

countries. Unemployment increases strongly in this scenario and house

prices in most countries show outright falls. The downside scenario

captures the possible impact of geopolitical tensions, global trade policy

and heightened tariff uncertainty.

The upside scenario reflects the possibility of a better economic out-turn

resulting from the avoidance of further trade escalation, an AI-driven

productivity rebound and stronger European growth supported by defence

spending.

Management adjustments applied this reporting period (*)

In times of volatility and uncertainty where portfolio quality and the

economic environment are changing rapidly, models alone may not be

able to accurately predict losses. In these cases, management

adjustments can be applied to appropriately reflect ECL. Management

adjustments may also be applied when the impact of the updated

macroeconomic scenarios is over- or under-estimated by the IFRS 9

models, or to account for model redevelopment, recalibration, and periodic

assessment procedures that have not yet been incorporated into the IFRS9

models.

ING has an internal governance framework and controls in place to assess

the appropriateness of all management adjustments.


Management adjustments to ECL models (*)
in EUR million	2025	2024
Commercial Real Estate/ Inflation and interest rate increases		50
Economic sector / portfolio based adjustments	9	38
Mortgage portfolio adjustments	121	112
Climate transition risk	47	29
Other Post Model Adjustments	7	-27
Total management adjustments	183	203

The management adjustment of €50 million for the Commercial Real

Estate portfolio, reported at 31 December 2024 due to prevailing risks in

this sector, is released in 2025 due to improved risk profile and partially

replaced with a management adjustment for a recent model update,

which corrects for the effects of the aforementioned risks on the model

outcome. As the model update has not been implemented in production

yet, a management adjustment of €10 million is reported under the Other

Post Model Adjustments category at 31 December 2025.

As at 31 December 2025, an economic sector / portfolio-based adjustment

is reported in the Mortgages portfolio in Australia (€9 million) to address

emerging risk from inflation, interest rate increases and overall cost of

living. The management adjustment reported at 31 December 2024 for the

increased credit risk in the Mortgages and Consumer Lending portfolios in

Spain – due to the effects of floods – has been released, as the remaining

affected performing customers are reported in Stage 2. Also the

adjustment taken in the Business Banking portfolio in Germany at 31

December 2024 to cover for the increased uncertainty in the German

economy has been released due to the agreed sale of the affected

portfolio.

As of 31 December 2025, the overall mortgage portfolio adjustment

amounts to €121 million (31 December 2024: €112 million) and fully

related to the management adjustment in Stage 2 for the risk

segmentation model that captures affordability, repayment, and

refinancing risk on performing mortgage customers with a bullet loan in

the Netherlands.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	183

As of 31 December 2025, an adjustment of €47 million is in place to

address the impact of climate transition risk in Wholesale Banking (€31

million) and in Business Banking (€16 million). Climate transition risk is

expected to lead to a structural change in credit risk, which means specific

business activities will become structurally riskier due to environmental

policies, technological progress or changes in market sentiment and

preferences. The current IFRS 9 models do not capture this (novel) risk. The

management adjustment to ECL models for business clients was made to

specifically cover for the medium- to long-term transition risk on high

greenhouse gas-emitting sectors and is reported in Stage 2. The sectors

included in the overlay represent approximately 20% of the exposure

within Wholesale and Business Banking.

Other post-model adjustments mainly relate to the impact of model

redevelopment or recalibration and periodic model assessment

procedures that have not been incorporated in the ECL models yet. The

impact on total ECL can be positive or negative. These adjustments will be

removed once updates to the specific models have been implemented.

The change in balance compared to previous reporting date is due to i)

released negative overlays because of model updates that have been

implemented and ii) new overlays recognised for new recalibrations and

periodic model assessment procedures that have not been incorporated

yet.

Analysis on sensitivity (*)

The table below presents the analysis on the sensitivity of key forward-

looking macroeconomic inputs used in the ECL collective-assessment

modelling process and the probability weights applied to each of the three

scenarios. The countries included in the analysis are the most significant

geographic regions in ING. For Wholesale Banking, the US is the most

significant in terms of both gross contribution to reportable ECL and

sensitivity of ECL to forward-looking macroeconomics. Accordingly, ING

considers these portfolios to present the most significant risk of resulting in

a material adjustment to the carrying amount of financial assets within

the next financial year.

The purpose of the sensitivity analysis is to enable the reader to

understand the extent of the impact from the upside and downside

scenario on model-based reportable ECL.

In the table below, the real GDP is presented in percentage year-on-year

change, the unemployment in percentage of total labour force, and the

house price index (HPI) in percentage year-on-year change.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	186

When compared to the sensitivity analysis of 2024, the baseline

macroeconomic inputs have become slightly more positive overall,

underpinned by the resilience of the global economy in the face of trade

and geopolitical tensions. House price growth expectations are lower for

the Netherlands, given a rise in supply from the sale of rental properties

and slowdown of wage growth. In the US, a weak labour and housing

market both signal underlying economic challenges due to policy and

trade uncertainty, and persistent affordability issues. The upside and the

downside scenarios are not directly comparable with those of 2024 due to

an update in the basis of their derivation.

On a total ING level, the unweighted ECL for all collective provisioned

clients in the upside scenario was €2,938 million, in the baseline scenario

€3,232 million and in the downside scenario €3,993 million compared to

€3,326 million reportable model ECL as at 31 December 2025 (excluding all

management adjustments). To perform the sensitivity analysis, a point in

time reportable ECL is used as input, which slightly deviates from the total

reportable collective provisions as presented below:


Reconciliation of reportable collective ECL to total ECL (*)
in EUR million	2025	2024
Total reportable collective provisions	3,168	2,975
ECL from individually assessed impairments	2,750	2,871
ECL from management adjustments	183	203
Total ECL	6,101	6,049

Criteria for identifying a significant increase in credit risk (SICR) (*)

All assets and off-balance-sheet items that are in scope of IFRS 9

impairment and which are subject to collective ECL assessment are

allocated a 12-month ECL if deemed to belong in Stage 1, or a lifetime ECL

if deemed to belong in Stages 2 or 3. An asset belongs in Stage 2 if it is

considered to have experienced a significant increase in credit risk (SICR)

since initial origination or purchase.

The main determinant of SICR is a quantitative test, whereby the lifetime

PD of an asset at each reporting date is compared against its lifetime PD

determined at the date of initial recognition. If either a threshold for

absolute change in lifetime PD or a threshold for relative change in lifetime

PD is reached, the item is considered to have experienced an SICR (for more

details on absolute and relative thresholds, see the following sections).

Furthermore, any facility which shows an increase of 200 percent between

the PD at the date of initial recognition and the lifetime PD at the reporting

date (i.e. threefold increase in PD) must be classified as Stage 2. This is

considered a backstop within the quantitative assessment of SICR.

In Wholesale Banking, a significant increase in lifetime PD is not considered

plausible for assets of obligors with a credit rating at the reporting date in

the top range of investment grade. The assets of these Wholesale Banking

obligors are excluded from the assessment of significant increase in credit

risk triggers. For these obligors the qualitative significant increases in credit

risk triggers remain applicable (see the section below on Qualitative SICR

triggers). These are, for example, the watch list and/or forbearance

triggers. Finally, the 30 days past due backstop also remains applicable for

the top range of investment grade exposures to ensure a significant

increase in credit risk recognition.

Absolute lifetime PD threshold

The absolute threshold is a fixed value calibrated per portfolio/segment

and provides a fixed threshold that, if exceeded by the difference between

lifetime PD at reporting date and lifetime PD at origination, triggers Stage 2

classification. The absolute threshold is calibrated during model

development.

Relative lifetime PD threshold

The relative threshold defines a relative increase of the lifetime PD, beyond

which a given facility is classified in Stage 2 because of a significant

increase in credit risk. The relative threshold is dependent on the individual

PD assigned to each facility at the moment of origination, and a scaling

factor calibrated in the model development phase.

Ultimately, the relative threshold provides a criterion to assess whether

the ratio (i.e. increase) between lifetime PD at reporting date and lifetime

PD at origination date is deemed a significant increase in credit risk. If the

threshold is breached, SICR is identified and Stage 2 is assigned to the

given facility.

The threshold for the relative change in lifetime PD is inversely correlated

with the PD at origination; the higher the PD at origination, the lower the

threshold. The logic behind this is to allow facilities originated in very

favourable ratings to downgrade for longer without the need of a Stage 2

classification. In fact, it is likely that such facilities will still be in favourable

ratings even after a downgrade of a few notches. On the contrary, facilities

originated in already unfavourable ratings grades are riskier and even a

single-notch downgrade might represent a significant increase in credit

risk and thus a tighter threshold will be in place. Still, the relative threshold

is relatively sensitive for investment-grade assets while the absolute

threshold primarily affects non-investment grade assets.

Average threshold ratio

The table below shows the average increase in PD at origination needed to

be classified in Stage 2 is reported, taking into account the PD at

origination of the facilities included in each combination of asset class and

rating quality. In terms of rating quality, assets are divided into

'investment grade' and 'non-investment grade' facilities. Rating 18 and 19

are not included in the table, since facilities are not originated in these

ratings and they constitute a staging trigger of their own (i.e. if a facility is

ever to reach rating 18 or 19 at reporting date, it is classified in Stage 2). In

the table, values are weighted by IFRS 9 exposure and shown for both

year-end 2024 and year-end 2025.

To represent the thresholds as a ratio (i.e. how much should the PD at

origination increase in relative terms to trigger Stage 2 classification) the

absolute threshold is recalculated as a relative threshold for disclosure

purposes. Since breaching only relative or absolute threshold triggers

Stage 2 classification, the minimum between the relative and recalculated

absolute threshold is taken as value of reference for each facility.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	187


Quantitative SICR thresholds (*)
	2025		2024
Average threshold ratio	Investment grade (rating grade 1-10)	Non-investment grade (rating grade 11-17)	Investment grade (rating grade 1-10)	Non-investment grade (rating grade 11-17)
Asset class category
Mortgages	2.9	2.4	2.9	2.4
Consumer lending	2.9	2.3	2.8	2.1
Business lending	2.7	2.0	2.7	2.1
Governments and financial institutions	2.9	1.8	2.9	1.9
Other Wholesale Banking	2.7	1.9	2.7	1.9

As it is apparent from the disclosures above, as per ING’s methodology, the

threshold is tighter the higher the riskiness at origination of the assets,

illustrated by the difference between the average threshold applied to

investment grade facilities and non-investment grade facilities.

Sensitivity of ECL to PD lifetime PD thresholds

The setting of PD threshold bands requires management judgement and is

a key source of estimation uncertainty. On Group level, the total model

ECL on performing assets, which is the ECL collective assessment without

taking management adjustments into account, was €1,501 million as at

31 December 2025 (31 December 2024: €1,328 million). To demonstrate

the sensitivity of the ECL to these PD threshold bands, hypothetically

solely applying the upside scenario would result in total model ECL on

performing assets of €1,159 million and a decrease in the Stage 2 ratio by

0.3%-point, while solely applying the downside scenario would result in

total model ECL on performing assets of €2,193 million and an increase in

the Stage 2 ratio by 1.6%-point.

Qualitative SICR thresholds

It should be noted that the lifetime PD thresholds are not the only drivers

of stage allocation as ING Group also relies on a number of qualitative

indicators to identify and assess SICR. An asset can also change stages as

a result of other triggers, such as having over 30 days arrears (used as a

backstop), the occurrence of an early warning indicator, collective SICR

assessment, being on a watch list, being under intensive care

management, having a substandard internal rating, or being forborne.


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Market risk

Introduction (*)

Market risk is the risk that movements in market variables, such as interest

rates, equity prices, foreign exchange rates, credit spreads, and real-estate

prices negatively impact the bank’s earnings, capital, market value, or

liquidity position. Market risk either arises through positions in banking

books or trading books.

The banking book positions are intended to be held for the long term (or

until maturity) or for the purpose of hedging other banking book positions.

The trading book positions are typically held with the intention of short-

term trading or to hedge other positions in the trading book. Policies and

processes are in place to monitor the inclusion of positions in either the

trading or banking book as well as to monitor the transfer of risk between

the trading and banking books.

The following sections elaborate on the various elements of the risk

management framework for:

§Market risk in banking books;

§Market risk in trading books; and

§Market risk capital.

Market risk in banking books (*)

ING distinguishes between the trading and banking (non-trading) books.

Positions in banking books originate from the market risks inherent in

commercial products that are sold to clients, Group Treasury exposures, and

from the investment of our own funds (core capital). Both the commercial

products and the products used to hedge related market-risk exposures are

intended to be held until maturity, or at least for the long term.

Risk transfer (*)

Market risks in the banking book are managed via the risk transfer process.

In this process the interest rate, FX, funding, and liquidity risks are

transferred from the commercial books through matched funding or

replication to Group Treasury, where they are centrally managed. The

scheme below presents the transfer and management process of market

risks in the banking books.

Risk measurement (*)

The main concepts and metrics used for measuring market risk in the

banking book are described below per risk type.

Interest rate risk in banking book (*)

Interest rate risk in the banking book is defined as the exposure of a bank’s

earnings, capital, and market value to adverse movements in interest

rates originated from positions in the banking book.

ING centralises interest rate risk management from commercial books

(that capture the products sold to clients) to globally managed interest

rate risk books. This enables a clear demarcation between commercial

business results and results based on unhedged interest rate positions.

ING distinguishes between three types of activities that generate interest

rate risk in the banking book:

§Investment of own funds;

§Commercial business; and

§Group Treasury exposures, including strategic interest rate positions.

Group Treasury is responsible for managing the investment of own funds

(core capital). Capital is invested for longer periods to contribute to stable

earnings within the risk appetite boundaries set by ALCO Bank.

Commercial activities can result in linear interest rate risk due to different

re-pricing properties of assets and liabilities. Also, interest rate risk can

arise from customer behaviour and/or convexity risk, depending on the

nature of the underlying product characteristics.

To determine interest rate risk in specific products (such as savings or

mortgages) certain assumptions may need to be applied. Customer

behaviour risk is defined as the potential future loss (value) arising from

deviations between actual client behaviour and the modelled behaviour

regarding embedded options within commercial products. General sources

of customer behaviour risk include, among other things, the state of the

economy, competition, changes in regulation, legislation and tax regime,

developments in the housing market, and interest rate developments.

From an interest rate risk perspective, commercial activities can typically

be divided into the following main product types: savings and current

accounts (funds entrusted), demand deposits, mortgages, and loans.

Savings and demand deposits are generally invested in such a way that

both the value is hedged and the sensitivity of the margin to market

interest rates is minimised. This is achieved by creating the investment

profile distributed from short term to long term, which dampens the

immediate impact from changes in the market rates and stabilises margin

in the longer horizon. Interest rate risk is modelled based on the stability of

deposits and the pass-through rate. This takes account of different

elements, such as pricing strategies, volume developments, and the level

and shape of the yield curve.

In determining the interest rate profile of mortgages, prepayment or other

embedded optionality can be an important risk driver. In modelling this

risk, both interest-rate-dependent prepayments and constant

prepayments are considered. Next to a dependence on interest rates,

modelled prepayments may include other effects such as loan-to-value,


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	189

seasonality, and the reset date of the loan. In addition, the interest

sensitivity of embedded offered rate options is typically considered.

Wholesale Banking loans typically do not experience interest-rate-

dependent prepayment behaviour, as these are mostly floating rate

products. These portfolios are match-funded, taking the constant

prepayment model into account, and typically do not contain significant

convexity risk. Wholesale Banking loans can have an all-in rate floor or a

floor on a reference rate.

Customer behaviour in relation to mortgages, loans, savings, and demand

deposits is modelled based on extensive analysis of historical data.

However, the substantial fluctuations in the interest rate environment in

recent years make the analysis more challenging than before and may

increase model risk. Models are backtested and updated when deemed

necessary, at least annually. Model parameters and the resulting risk

measures are approved by (local) ALCO, and are closely monitored on a

monthly basis.

Linear risk transfers take place from commercial business books to the

treasury book (Group Treasury), if necessary, by using estimations of

customer behaviour. The originating commercial business is ultimately

responsible for estimating this customer behaviour, leaving convexity risk

and (unexpected) customer behaviour risk with the commercial business.

Risk measurement and the risk transfer process take place at least

monthly. If deemed necessary, additional risk transfers can take place.

The commercial business manages the convexity risk that is the result of

products that contain embedded options, like mortgages. Here the

convexity risk is defined as the optionality effects in the value due to

interest rate changes, excluding the first-order effects. In some cases,

convexity risk is hedged by treasury using cap/floor contracts and

swaptions.

NII at Risk (*)

The NII-at-Risk measures the impact of changing interest rates on the

forecasted net interest income (before tax) of the banking book, excluding

the impacts of credit spread sensitivity, fees, and fair value impact. Future

projected balance sheet developments (dynamic plan) are included in this

risk metric. NII-at-Risk provides insight into the sensitivity of ING’s NII under

shocked interest rate scenarios against what is projected in a base case

scenario.

In its risk management, ING monitors the NII-at-Risk under a three-year

time frame. Interest rates are shocked during the first year of analysis

through the gradual application of shock. The rate changes considered

encompass both upward and downward scenarios, as well as both parallel

(equal movements across the yield curve) and non-parallel scenarios.

The impact of changing interest rates on ING’s NII is predominantly caused

by the following factors:

§Change in returns of (re)investments of client deposits;

§Change in client deposit rates (mainly savings), (partially) tracking

changes in market interest rates;

§Change in the amortisation profile of mortgages, due to an increase or

decrease in expected prepayments;

§Higher/lower returns of (re-)investments of core capital investment;

§Open interest rate positions, leading to changes in return because of

different market rates; and

§Assumed volume development of the balance sheet in line with ING’s

dynamic plan.

For projecting the change in client deposit rates, ING uses a client rate

model that describes the relation between market interest rates and client

deposit rates. The model is calibrated under a range of interest rate

scenarios. Per scenario, the actual change in client deposit rates may

deviate from this calibrated model. The actual NII development of

customer deposits may, indeed, differ from the provided scenarios,

depending on, among other things, actual interest rate and savings client

rate evolution, as well as changes to ING’s balance sheet composition,

such as net deposit growth and relative share of savings deposits and non-

remunerated current accounts.

The NII-at-Risk figures in the table below represent a parallel, linear

interest rate shift over one year (‘ramped’) based on the assumption that

balance sheet developments follow ING’s dynamic plan within a one-year

horizon.

The NII-at-Risk is mainly influenced by the difference in the sensitivity

between client liabilities and client assets and investments to rate

changes. The primary factor of NII-at-Risk are the investments of current

accounts, while the investments of own funds have a marginal effect, as

only a relatively small portion needs to be (re)invested within a one-year

period.


NII-at-Risk banking book per currency - year one (*)
in EUR million	2025		2024
	Ramped, floored		Ramped, floored
	parallel ▼	parallel ▲	parallel ▼	parallel ▲
By currency
Euro	-182	205	-146	160
US dollar	1	-1	-4	5
Other	-74	94	-2	21
Total	-254	298	-153	186
EUR ramped (floored at -100bps) is at +/- 120bps in 1 year
USD ramped (floored at -100bps) is at +/- 120bps in 1 year

The change in NII under declining and upward interest rate scenarios may

not be equal. This is due to different expected reactions in prepayment

behaviour of mortgages and different pricing developments of commercial

loans and deposits products (mainly savings). This is caused by embedded

options, explicit or implicit pricing floors, and other (assumed) pricing

factors.

The metrics mentioned above are internal metrics, which therefore deviate

from the regulatory NII SOT metric. Both internal and regulatory measures

are part of the bank's risk appetite framework and are actively managed.

Year-on-year variance analysis (*)

In 2025, ING maintained its dynamic hedging strategy, transferring

interest rate risk from business units to Group Treasury, where it was

subsequently hedged in financial markets, resulting in overall limited


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	190

sensitivity of NII at Risk (NIIaR) compared to ING’s total net interest income.

Year-on-year NIIaR increase by €100 million under a parallel down (worst

case) scenario, is primarily driven by revised repricing assumptions and

positions taken by treasury.

Net present value (NPV) at Risk (*)

NPV-at-Risk measures the impact of changing interest rates on the value

of the positions in the banking book and it is defined as the outcome of an

instantaneous increase or decrease in interest rates from applying

currency-specific scenarios. The metric primarily reflects the impact of

interest rate fluctuations on the bank’s strategic interest rate positions

(e.g. investments of own funds), as well as on the savings and mortgage

portfolios. While strategic positions typically adjust proportionally with

changing rates, the savings and mortgage products exhibit more complex

behavior due to embedded optionalities. Customers can prepay or

reallocate their balances, resulting in non-linear value changes. As a result,

these portfolios may incur value losses both when interest rates increase

and decrease, contributing to the asymmetric NPV-at-Risk pattern

highlighted in the annual report.

The full value impact cannot be directly linked to the financial position or

profit or loss account, as fair value movements in banking books are not

necessarily reported through the profit or loss account or through other

comprehensive income (OCI). The changes in value are expected to

materialise over time in the profit and loss account if interest rates develop

according to forward rates throughout the remaining maturity of the

portfolio. The majority of the risk comes from the investments of own

funds and from positions exhibiting negative convexity due to embedded

optionality (most notably variable rate savings and fixed rate mortgages).

The metrics mentioned above are internal metrics, which therefore deviate

from the regulatory EVE SOT metric. Both internal and regulatory

measures are part of the bank’s risk appetite framework and are actively

managed.


NPV-at-Risk banking books per currency (*)
in EUR million	2025		2024
	floored		floored
	parallel ▼	parallel ▲	parallel ▼	parallel ▲
By currency
Euro	1,319	-2,593	154	-1,613
US dollar	273	-265	274	-266
Other	269	-267	321	-329
Total	1,862	-3,125	749	-2,208
EUR (floored at -100bps) is at +/- 120bps
USD (floored at -100bps) is at +/- 120bps

Year-on-year variance analysis (*)

The overall NPV sensitivity increased considerably compared to the

previous year. The parallel up scenario continues to represent the worst-

case outcome, and the calculation shock for the primary currencies (EUR

and USD) was maintained at 120 basis points, consistent with the level

used in 2024. Year-over-year variations are explained by the evolving

balance sheet composition, movements in interest rates, and shifting

market expectations.

The impact of the benchmark rate reform (*)

In line with the recommendations of the Financial Stability Board, a

fundamental review of important interest rates benchmarks has been

undertaken. Some interest rate benchmarks have been reformed, while

others have or will be replaced by risk-free rates and discontinued.

In 2025, the benchmark rate reform of only one reference rate, to which

ING has significant exposures as at 31 December 2025, was continuing (i.e.

WIBOR in Poland).

On 24 January 2025, the Steering Committee of the National Working

Group (NWG SC) in Poland selected POLSTR (Polish Short Term Rate) as the

ultimate interest rate benchmark to replace WIBOR. POLSTR is calculated

based on unsecured deposits of Credit and Financial Institutions and is

expected to replace WIBOR by 31 December 2027.

In April 2025, the NWG SC published the updated transition roadmap of the

replacing process of WIBOR and announced in June 2025 that the official

determination of the POLSTR has started.

During the second half of 2025, the NWG SC approved several

recommendations for products based on POLSTR, and informed that

POLSTR has been applied for the first time in the domestic financial market

on 1 September 2025. Therefore, POLSTR gained a status of a benchmark

in accordance with the requirements of the EU Benchmark Regulation.

On 30 September 2025, the benchmark administrator GPW Benchmark

S.A, published the decision to cease providing the WIBOR reference rate for

various tenors in phases, between the end of 2025 and the end of 2026.

On 21 November 2025, the Ministry of Finance (of Poland) conducted the

first pilot issuance of treasury bonds linked to the POLSTR benchmark

during a sale auction.

Other important milestones of the process are planned in subsequent

years, including the construction of a market for financial products based

on the new benchmark and achieving regulatory and operational

readiness of all market participants to offer and operate these financial

products.

Due to the discontinuation of WIBOR, ING, its customers, and in general

those market participants with exposure to this benchmark rate will be

faced with a number of risks. These risks include legal, financial,

operational, reputational, and conduct risk. The WIBOR rates are used in

several of our lending and derivative products, and hence a project team

has been established to manage the transition. The WIBOR transition is

especially important for our Polish subsidiary (ING Bank Śląski S.A.) with a

significant amount of Polish zloty-denominated assets and liabilities

including derivatives that are continuously rebalanced to hedge the risk

exposures.

The tables below summarise the approximate gross exposure of ING that

has yet to transition related to WIBOR, excluding exposures expiring before

the transition date of 31 December 2027.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	191


Non-derivative financial instruments to transition from WIBOR to POLSTR (*)
	Financial assets non-derivative	Financial liabilities non- derivative	Off-balance sheet commitments
in EUR million	Carrying value	Carrying value	Nominal value
31 December 2025	25,333	360	2,301
31 December 2024	19,202	134	1,544


Derivative financial instruments to transition from WIBOR to POLSTR (*)
	31 December 2025	31 December 2024
in EUR million	Nominal value	Nominal value
WIBOR	196,133	110,189

See sections 1.5.4 of Note 1 ‘Basis of preparation and material accounting

policy information’ for information on the Phase 1 amendments to IFRS.

As at 31 December 2025, Phase 1 reliefs are applicable to WIBOR indexed

fair value and cash flow hedge accounting relationships as there is

uncertainty arising from the WIBOR reform with respect to the timing and

the amount of the underlying cash flows that the Group is exposed to.

Therefore, for WIBOR financial instruments designated in hedge

accounting the applicable Phase 1 reliefs will continue to apply until the

relevant contract is modified. At that point in time, the reliefs of Phase 2

amendments to IFRS will become applicable.

Following the Phase 1 reliefs that allow ING to continue applying hedge

accounting, ING has to assume that the WIBOR-based cash flows from the

hedging instrument and hedged item will remain unaffected for the

affected fair value and cash flow hedge relationships. In addition, for the

forecast transactions that are subject to cash flow hedge accounting,

under the Phase 1 reliefs ING has to assume that the WIBOR benchmark on

which the hedged cash flows are based is not altered as a result of the

reform and, therefore, the forecast transactions still meet the highly

probable requirement.

The total gross notional amounts of hedging instruments that are used in

ING’s hedge accounting relationships for which the Phase 1 amendments

to IAS 39 were applied are:


Notional amounts of hedging instruments from WIBOR to POLSTR (*)
	31 December 2025	31 December 2024
in EUR million	Nominal value	Nominal value
WIBOR	97,492	99,663

As at 31 December 2025, 50% (31 December 2024: 32%) of the notional

amounts have a maturity date beyond 31 December 2027. The notional

amounts of the derivative hedging instruments provide a close

approximation of the extent of the risk exposure ING manages through

these hedging relationships.

Credit spread risk in banking books (CSRBB) (*)

Credit spread risk is defined as risk driven by the changes of the market

price for credit risk, for liquidity and potentially other characteristics of

credit-risky instruments, which is not captured by another existing

prudential framework such as Interest Rate Risk in Banking Book or by

expected credit/(jump-to-) default risk. The CSRBB framework is

implemented based on EBA Guidelines. Metrics used are NPV-at-Risk, NII-

at-Risk and Market Value Changes-at Risk and view the positions across

different accounting treatments.

Credit spread risk is not part of the internal risk transfer towards Group

Treasury and therefore remains in the business unit it originated in. Group

Treasury itself is also an important driver of credit spread risk via its high-

quality liquid assets (HQLA) investment portfolio and issuance activities.

Risk appetite limits are set on a combination of metrics and accounting

scopes and are cascaded to local ALCOs depending on the type of limit

and materiality. Metrics and limits are monitored and reported monthly to

global and local risk committees, and various stakeholders.

Foreign exchange (FX) risk in banking books (*)

FX exposures in banking books result from core banking business activities

(business units doing business in currencies other than their base

currency), foreign currency investments in subsidiaries (including realised

net profit and loss), and strategic equity stakes in foreign currencies. The

policy regarding these exposures is briefly explained below.

Core banking business (*)

Every business unit hedges the FX risk resulting from core banking

business activities into its base currency to prevent volatility in profit and

loss. Consequently, assets and liabilities are matched in terms of currency,

within certain friction limits.

FX translation (*)

ING’s strategy is to protect the CET1 ratio against adverse impact from FX

rate fluctuations, while limiting the volatility in the profit and loss account

due to this CET1 hedging and limiting the RWA impact under the

regulatory framework. Currency exposure of Return on Equity is also

considered. Hedge accounting is applied to the largest extent possible.

Taking this into account, the CET1 ratio hedge can be achieved by

deliberately taking foreign currency positions equal to certain target

positions, such that the CET1 capital and risk-weighted assets are equally

sensitive in relative terms to changing FX rates.

Risk profile – FX translation (*)

The following table presents the currency exposures in the banking books

for the most important currencies for the FX translation result. Positive

figures indicate long positions in the respective currency. As a result of the

strategy to hedge the CET1 ratio, an open structural FX exposure exists.

To measure the volatility of the CET1 ratio from FX rate fluctuations,

different metrics are used, including the CET1 Ratio-at-Risk. The impact is

controlled via the Solvency and Financial Risk RAS.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	192


Foreign currency exposures banking books (*)
in EUR million	Foreign Investments		Hedges		Net exposures
	2025	2024	2025	2024	2025	2024
US Dollar	9,698	11,251	-4,500	-4,823	5,198	6,429
Pound Sterling	1,584	1,674	-515	-484	1,069	1,190
Polish Zloty	4,652	4,292	-2,009	-1,616	2,643	2,677
Australian Dollar	3,307	3,373	-1,933	-2,161	1,374	1,212
Turkish Lira	469	557	0	0	469	557
Chinese Yuan	2,015	2,439	1	-830	2,016	1,609
Russian Rouble	597	396	0	0	597	396
Romanian Leu	913	913	-228	-176	685	736
Thai Baht	1,307	1,266	-829	-838	478	428
Other currency	3,032	3,346	-1,995	-2,748	1,036	599
Total	27,573	29,509	-12,008	-13,675	15,565	15,834

1.The FX sensitivity is expressed as the FX spot equivalent position.

EBA Structural FX guidelines

In line with the EBA guidelines on Structural FX, upon permission from the

competent authorities, certain currency positions are being excluded from

the calculation of net open currency positions under CRR article 352(2).

The resulting impact is presented in the Pillar 3 disclosure.

Equity price risk in banking books (*)

ING maintains a portfolio with substantial equity exposure in its banking

books.

Risk profile (*)

Equity price risk arises from the possibility that an equity security’s price

will fluctuate, affecting the values of the equity security itself as well as

other instruments whose values react similarly to the particular security, a

defined basket of securities, or a securities index. ING’s equity exposure

mainly consists of the investments in associates and joint ventures of

€1,607 million (2024: €1,679 million) and equity securities held at fair value

through other comprehensive income (FVOCI) of €2,607 million (2024:

€2,562 million). The value of equity securities held at FVOCI is directly

linked to equity security prices with increases/decreases being recognised

in the revaluation reserve.

Investments in associates and joint ventures are measured in accordance

with the equity method of accounting, and the balance sheet value is

therefore not directly linked to equity security prices. The equity sensitivity

is expressed as the equity position.

Year-on-year variance analysis (*)

In 2025, the revaluation reserve equity securities decreased by €372

million from €1,816 million to €1,444 million due to revaluation of the

shares in Bank of Beijing with €-403 million. In 2025, the equity securities

at fair value through OCI increased by €45 million mainly due to increased

stake in Van Lanschot Kempen.


Revaluation reserve equity securities at fair value through other comprehensive income (*)
in EUR million	2025	2024
Positive remeasurement	1,456	1,820
Negative remeasurement	-12	-4
Total	1,444	1,816

Market risk in trading books (*)

Within the trading portfolios, the positions are maintained in the financial

markets. These positions are often a result of transactions with clients and

may benefit from short-term price movements. In 2025, ING continued its

strategy of undertaking trading activities to develop its client-driven

franchise and deliver a differentiating experience by offering multiple

market and trading products.

With respect to the trading portfolios, Trading Risk Management (TRM)

focuses on the management of market risks of Wholesale Banking (mainly

Financial Markets) as this is the only business line within ING where trading

activities take place. Trading activities include facilitation of client business

and market making. TRM is responsible for the development and

implementation of trading risk policies and risk measurement

methodologies, and for reporting and monitoring risk exposures against

approved trading limits. TRM also reviews trading mandates and global

limits, and performs the gatekeeper role in the product review process

(PARP).


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	193

Risk measurement (*)

ING uses a comprehensive set of methodologies and techniques to

measure market risk in trading books: Value at Risk (VaR) and Stressed

Value at Risk (SVaR), Incremental Risk Charge (IRC), and stress testing.

Systematic validation processes are in place to validate the accuracy and

internal consistency of data and parameters used for the internal models

and modelling processes.

Value at Risk (*)

TRM uses the historical simulation VaR methodology (HVaR) as its primary

risk measure. The HVaR for market risk quantifies, with a one-sided

confidence level of 99 percent, the maximum overnight loss that could

occur in the trading portfolio of ING due to changes in risk factors (e.g.

interest rates, equity prices, foreign exchange rates, credit spreads, implied

volatilities), considering the positions remain unchanged for a time period

of one day.

Next to general market movements in these risk factors, HVaR also takes

into account market data movements for specific moves in, for example,

the underlying issuer or securities. A single model which diversifies general

and specific risk is used. In general, a full revaluation approach is applied,

while for a limited number of linear trading positions and risk factors in

commodity and equity risk classes, a sensitivity-based approach is applied.

The potential impact of historical market movements on today’s portfolio

is estimated, based on equally weighted observed market movements of

the previous year (260 business days). When simulating potential

movements in risk factors, depending on the risk factor type, either an

absolute or a relative shift is used.

The data used in the computations is updated daily. ING uses HVaR with a

one-day horizon for internal risk measurement, management control, and

backtesting, and HVaR with a 10-day horizon for determining regulatory

capital. To compute HVaR with a 10-day horizon, the one-day risk factor

shifts are scaled by the square root of 10 and then used as an input for the

revaluation. The same model is used for all legal entities within ING with

market risk exposure in the trading portfolio.

Limitations (*)

HVaR has some limitations: it uses historical data to forecast future price

behaviour, but future price behaviour could differ substantially from past

behaviour. Moreover, the use of a one-day holding period (or 10 days for

regulatory capital calculations) assumes that all positions in the portfolio

can be liquidated or hedged in one day. In periods of illiquidity or market

events, this assumption may not hold. Also, the use of a 99 percent

confidence level means that HVaR does not take into account any losses

that occur beyond this confidence level.

Backtesting (*)

Backtesting is a technique for the ongoing monitoring of the plausibility of

the HVaR model in use. Although HVaR models estimate potential future

trading results, estimates are based on historical market data. In a backtest,

the actual daily trading result (excluding fees and commissions) is

compared with the one-day HVaR.

In addition to using actual results for backtesting, ING also uses hypothetical

results, which exclude the effects of intraday trading, fees, and

commissions. When an actual or a hypothetical loss exceeds the HVaR, an

‘outlier’ occurs. Based on ING’s one-sided confidence level of 99 percent, an

outlier is expected once in every 100 business days.

On an overall level in 2025, there was one outlier for hypothetical P&L and

zero outliers for actual P&L. The hypothetical outlier occurred in the first

quarter of 2025, mainly driven by higher EUR rates due to anticipated

changes in German fiscal policy.

Stressed HVaR (*)

The stressed HVaR (SVaR) is intended to replicate the HVaR calculation that

would be generated on the bank’s current portfolio with inputs calibrated to

the historical data from a continuous 12-month period of significant

financial stress relevant to the bank’s portfolio.

To calculate SVaR, ING uses the same model that is used for 1DHVaR, with a

10-day horizon. The data for the historical stress period used currently

includes the height of the credit crisis around the fall of Lehman Brothers

(2008-2009), and this stressed period selection is reviewed annually. The

historical data period is chosen so that it gives the worst-scenario loss

estimates for the current portfolio. The same SVaR model is used for

management purposes and for regulatory purposes. The same SVaR model

is used for all legal entities within ING with market risk exposure in the

trading portfolio.

Incremental risk charge (*)

The incremental risk charge (IRC) for ING is an estimate of the default and

migration risks for credit products (excluding securitisations) in the trading

book, over a one-year capital horizon, with a 99.9 percent confidence level.

Trading positions (excluding securitisations) of ING, which are subject to

specific interest rate risk included in the internal model approach for market

risk regulatory capital, are in scope of the IRC model. By model choice,

equity is excluded from the model. For the calculation of IRC, ING performs a

Monte Carlo simulation based on a multi-factor t-copula. In the multi-factor

IRC model the supervisory asset correlations are no longer applicable and

the calibration of the correlations is based on historical market data. The

rating change is simulated for all issuers over the different liquidity horizons

(i.e. time required to liquidate the position or hedge all significant risks)

within one year. Movements across different rating categories and

probabilities of default are governed by a credit-rating transition matrix. An

internal transition matrix along with internal LGDs is used, to comply with

the consistency requirement. The financial impact is then determined for

the simulated migration to default, or for the simulated migration to a

different rating category, based on LGD or credit spread changes,

respectively.

The liquidity horizon has been set to the regulatory minimum of three

months for all positions in scope. ING reviews the liquidity horizons on a

yearly basis, based on a structured assessment of the time it takes to

liquidate the positions in the trading portfolio.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	194

Stress testing and event risk (*)

Stress testing is a valuable risk management tool. In addition to the bank-

wide stress-test framework as described in the stress-testing section,

Trading Risk Management performs stress tests specific to the trading book

with various frequencies. The trading book stress tests evaluate the impact

on the bank’s trading book under severe but plausible stress scenarios, using

a full revaluation approach. The framework is based on historical as well as

hypothetical scenarios. The stress result is an estimate of the profit and loss

caused by a potential event and its worldwide impact for ING. The results of

the stress tests are used for decision-making, aimed at maintaining a

financially healthy going-concern institution after a severe event occurs.

In stress scenarios, shocks are applied to prices (credit spreads, interest

rates, equity, commodities, and FX rates) and volatilities. Depending on the

type of the stress test, additional scenario assumptions can be made, for

example on correlations, dividends, or recovery rates. The structural

scenarios are defined to cover market moves in various directions and

capture different asset class correlations. Scenarios are calculated using a

full revaluation approach. The worst scenarios are determined for each

product line, business line, and super business line, and compared against

limits.

Other trading limits

HVaR and event risk limits are the most important limits to control the

trading portfolios. Additionally, limits have been set on SVaR and IRC, and

ING uses a variety of other controls to supplement these limits. Position

and sensitivity limits are used to prevent large concentrations in specific

issuers, sectors, or countries. Moreover, other risk limits are set with

respect to the activities in complex derivatives trading. The market risk of

these products is controlled by product-specific limits and constraints.

Risk profile

The following chart shows the development of the overnight HVaR under a

99 percent confidence level and a one-day horizon versus actual and

hypothetical daily trading profits and losses. In calculation of the

hypothetical daily profit and loss, the trading position is kept constant and

only the market movement is taken into account. The overnight HVaR is

presented for the ING trading portfolio for 2025.

EU MR4. Consolidated trading VaR ING Bank

in EUR million

The risk figures shown in the backtesting graph above and in the following table relate to all trading books that use the internal model approach.


1d VaR for internal model approach trading portfolios
in EUR million	Minimum		Maximum		Average		Year end
	2025	2024	2025	2024	2025	2024	2025	2024
Interest rate 1	6	6	23	17	10	12	6	11
Equity and commodity	4	2	9	7	7	4	6	6
Foreign exchange	2	1	6	14	3	3	4	2
Credit spread	2	2	6	12	3	4	2	3
Diversification 2					-9	-7	-8	-6
Total VaR 2	10	7	19	21	14	15	11	16

1For calculation of HVaR per risk class the full valuation is performed according to HVaR methodology using a set of scenario changes for the risk factors for the particular risk class, while risk factors for all other

risk classes are kept unchanged.

2The total HVaR for the columns Minimum and Maximum cannot be calculated by taking the sum of the individual components since the minimum/maximum observations for both the individual markets as

well as for total HVaR may occur on different dates. Therefore, diversification is not calculated for the minimum and maximum categories.

Average 1D/10D HVaR, SVaR, and IRC over 2025 has decreased compared to 2024, resulting in a decrease in overall capital for 2025. The overall average

has decreased in 2025 for all trading portfolios, mainly due to an increase in diversification, despite high volatility due to the ongoing geopolitical tensions

and increased trade frictions.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	195

ING does not calculate comprehensive risk capital charge and therefore it

appears as n/a in the table below.


EU MR3: internal model approach values for trading portfolios
in EUR million	2025	2024
VaR (10 day 99%)
1 Maximum value	59	73
2 Average value	41	48
3 Minimum value	29	29
4 Period end	33	47
Stressed VaR (10 day 99%)
5 Maximum value	149	175
6 Average value	90	109
7 Minimum value	47	56
8 Period end	51	98
Incremental risk charge (99.9%)
9 Maximum value	288	232
10 Average value	144	125
11 Minimum value	46	64
12 Period end	144	100
Comprehensive risk capital charge (99.9%)
13 Maximum value	n/a	n/a
14 Average value	n/a	n/a
15 Minimum value	n/a	n/a
16 Period end	n/a	n/a

Sensitivities (*)

As part of the risk monitoring framework, TRM actively monitors the

sensitivities of the trading portfolios. Sensitivities measure the impact of

movements in individual market risk factors (foreign exchange rates,

interest rates, credit spreads, equity and commodity prices) on profit and

loss results of the trading positions and portfolios.

The following tables show the five largest trading positions in terms of

sensitivities to foreign exchange, interest rate, and credit spread risk factor

movements. These largest exposures also reflect concentrations of risk in

FX risk per currency, interest rate risk per currency, and credit spread risk

per country, rating, and sector. Due to the nature of the trading portfolios,

positions in the portfolios can change significantly from day to day, and

sensitivities of the portfolios can change daily accordingly.


Most important foreign exchange year-end trading positions (*)
in EUR million	2025		2024
Foreign exchange		Foreign exchange
US Dollar	-260	US Dollar	-93
Turkish Lira	229	Turkish Lira	84
Chinese Yuan	88	Korean Won	62
Japanese Yen	-49	Japanese Yen	61
Romanian Leu	42	Chinese Yuan	-37


Most important interest rate and credit spread sensitivities at year-end (*)
in EUR thousand	2025		2024
Interest rate (BPV) 1		Interest rate (BPV) 1
Euro	-312	Euro	-799
US Dollar	-161	US Dollar	-198
British Pound	-133	British Pound	-189
Japanese Yen	133	Korean Won	-54
Philippine Peso	-98	Philippine Peso	-54

Credit spread (CSO1) 2		Credit spread (CSO1) 2
France	178	United States	193
United Kingdom	111	Netherlands	-165
Netherlands	75	France	-113
Indonesia	-63	Poland	69
South Korea	63	Germany	49

1.Basis point value (BPV) measures the impact on value of a one basis point increase in interest

rates.

2.Credit spread sensitivity (CS01) measures the impact on value of a one basis point increase in

credit spreads. Exposures to supranational institutions are not assigned to a specific country.


Credit spread sensitivities per risk class and sector at year-end (*)
	2025		2024
in EUR thousand	Corporate	Financial institutions	Corporate	Financial institutions
Credit spread (CSO1) 1
Risk classes
1 (AAA)	-2	-19	-2	-118
2–4 (AA)	26	-13	-44	-27
5–7 (A)	64	-37	49	-246
8–10 (BBB)	191	-54	93	-76
11–13 (BB)	38	-14	38	-13
14–16 (B)	56	8	23	-12
17–22 (CCC and NPL)	6	4	4	2
Total	378	-124	162	-489
1Credit Spread Sensitivity (CS01) measures the impact on value of a 1 basis point increase in credit spreads.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	197

Standardised approach


EU MR1: market risk under standardised approach
in EUR million	2025	2024
	RWA	RWA
Outright products
1 Interest rate risk (general and specific)	92	31
2 Equity risk (general and specific)
3 Foreign exchange risk	4,968	4,374
4 Commodity risk
Options
5 Simplified approach
6 Delta-plus method
7 Scenario approach
8 Securitisation (specific risk)
9 Total	5,060	4,405

The MRWA under standardised approach have increased compared to

2024.

Market risk capital

Economic capital

Market risk economic capital (MREC) measures the capital ING must hold to

protect itself against losses due to market risks. MREC covers the entire

balance sheet of ING Group, and includes market risk sub-types such as:

interest rate and basis risk, credit spread risk, customer behaviour risk, FX

risk, equity risk, and commodity risk.

MREC is calculated as the 99.9 percent worst value loss that can be

incurred from one-year shocks to the underlying risk drivers. While

aggregating the different economic capital market risk figures for the

different portfolios, diversification benefits are taken into account as it is

not expected that all extreme market movements will appear at the same

moment.

Regulatory capital

Market risk regulatory capital is the amount of capital that ING has to hold

to protect itself against losses due to market risks, as required by the

financial regulator. From a regulatory capital perspective, market risk

stems from all the positions included in a bank’s trading book, as well as

from commodity and foreign exchange risk positions in the whole balance

sheet of ING Group. According to the Capital Requirements Regulation

(CRR/CRD IV), regulatory capital (own funds requirements) for market risk

can be calculated using the standardised approach or an internal model

approach.

FX risk in banking book

Regulatory Capital requirements for FX risk in banking book is set out in

Part 3, Title IV, Chapter 3 of the Capital Requirements Regulation (CRR). This

is further supplemented by EBA guidelines on Structural FX for the

calculation of the net open currency positions (CRR Art 352(2)). ING uses

the standardised approach where the capital requirement is 8 percent of

this total net currency and gold position.

Equity risk in banking book

Equity regulatory capital is included as part of Credit RWA as prescribed by

regulations. As of January 2025, ING applies the Standardised Approach

(SA) for the calculation of Regulatory Capital as described in Capital

Requirements Regulation (CRR3) Art 133. Under CRR3 SA, the RWA amount

is calculated by multiplying the risk weight with the exposure value (not

tailored to a specific internal model). The capital requirement is 8 percent

of the RWA value.

Trading book

ING has regulatory approval to use an internal model to determine the

regulatory capital for the market risk in all trading books of ING. Market risk

capital of trading books is calculated according to the CRR, using internal

HVaR, SVaR, and IRC models, where diversification is taken into account.

Collective investment undertakings (CIUs), cryptocurrency assets (Bitcoin

NDF) and asset-backed securities (ABS) exposures in trading books are

calculated using the standardised approach with fixed risk weights. ING

does not have a correlation trading portfolio in the trading book.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	198

Funding and liquidity risk

Introduction (*)

Funding and liquidity (F&L) risk is the risk that ING or one of its subsidiaries

cannot meet their financial obligations upon their maturity date at a

reasonable cost and in a timely manner. ING incorporates funding and

liquidity risk management in its business strategy and has established a

funding and liquidity risk framework to manage these risks within pre-

defined boundaries.

The following sections elaborate on the various elements of funding and

liquidity risk:

§Funding and liquidity risk framework;

§Funding and liquidity risk management strategy and objectives;

§Funding and liquidity adequacy and risk appetite;

§Funding and liquidity risk indicators;

§Liquidity stress testing; and

§Contingency funding planning.

Funding and liquidity risk framework (*)

Macroeconomic and market environments are important considerations in

ING’s F&L framework. The macroeconomic environment is comprised of

various exogenous factors over which ING has no control, but which may

have a material impact on ING’s F&L position. Exogenous factors analysed

on a regular basis include:

§performance of global and local macroeconomic indicators, e.g. shifts

in gross domestic product, inflation rates, unemployment rates, and

public deficit/surplus;

§developments and risks arising from geopolitical tensions and trends;

§monetary policy with a focus on the alternative monetary measures

employed by central banks in recent years as a result of the global

energy crisis and periods of high inflation; and

§regulatory requirements, e.g. understanding the changing regulatory

landscape as well as the impact of ING’s actions on existing regulatory

boundaries.

The strategic ambitions of ING, together with the design and execution of

the funding plan, are assessed under both current and projected market

conditions. An emphasis is placed on understanding overall market trends

and developments, credit rating changes, and peer comparisons.

The EB, MBB, and staff departments from the CRO and CFO domains, as

well as Group Treasury, have oversight of, and are responsible for,

managing funding and liquidity risks.

Funding and liquidity management strategy and objectives (*)

The main objective of ING’s funding and liquidity risk management is to

maintain sufficient liquidity to fund the commercial activities of ING both

under normal and stressed market circumstances across various locations,

currencies and tenors.

ING’s funding consists mainly of retail and corporate deposits contributing

to 53 percent and 22 percent of total funding, respectively. These funding

sources provide a stable funding base. The remainder of the required

funding is attracted primarily through a combination of long-term and

short-term professional funding. Group Treasury manages the professional

funding in line with the F&L risk appetite with the aim of ensuring a

sufficiently diversified and stable funding base.


Funding mix 1
	2025	2024
Funding type
Customer deposits (private individuals)	53%	53%
Customer deposits (other)	22%	22%
Lending/repurchase agreements	5%	5%
Interbank	2%	2%
CD/CP	5%	5%
Long-term senior debt	11%	11%
Subordinated debt	2%	2%
Total	100%	100%
1Liabilities excluding trading securities and IFRS equity.

ING’s long-term professional funding is diversified across maturities and

currencies. The main portion of long-term professional funding is euro and

US dollar denominated, which is in line with the currency composition of

customer lending.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	199


ING Group long-term debt maturity profile by currency at year-end 2025 1
in EUR billion (nominal amounts)	2026	2027	2028	2029	2030	2031	Beyond 2031	Total
Currency
EUR	7.7	7.0	10.7	10.3	11.7	7.2	29.3	84.0
USD	1.1	4.2	2.6	2.4	1.6	1.0	7.9	20.7
Other	2.2	1.7	2.4	2.7	1.5	0.4	3.6	14.3
Total	10.9	12.9	15.7	15.3	14.8	8.6	40.8	119.0

1Amounts adjusted to exclude Tier 1 instruments.


ING Group long-term debt maturity profile by currency at year-end 2024 1
in EUR billion (nominal amounts)	2025	2026	2027	2028	2029	2030	Beyond 2030	Total
Currency
EUR	4.7	9.2	7.1	9.7	10.3	10.6	27.0	78.6
USD	0.3	3.9	4.8	3.3	1.4	1.5	7.5	22.8
Other	1.2	2.7	1.7	1.8	2.6	0.2	3.1	13.3
Total	6.2	15.8	13.6	14.8	14.3	12.4	37.6	114.7

1Amounts adjusted to exclude Tier 1 instruments.

Funding and liquidity adequacy and risk appetite (*)

ING identifies key drivers of short-term and future liquidity and funding

needs on an ongoing basis through the periodic risk-identification process.

Taking into consideration the identified risk drivers, ING regularly assesses

its current and future liquidity adequacy and, if deemed necessary, takes

action to further improve ING’s liquidity position and maintain sufficient

counterbalancing capacity. A Liquidity Adequacy Statement is formulated

on a regular basis to substantiate and reflect the management view on

the current funding and liquidity position as well as the potential future

challenges. The Liquidity Adequacy Statement is an important part of

ING’s Internal Liquidity Adequacy Assessment Process (ILAAP).

Additionally, ING completes ad-hoc funding and liquidity assessments if

deemed necessary.

ING assesses its F&L adequacy through three lenses – stress, economic,

and normative:

§Through the stress lens, ING evaluates its ability to withstand periods of

prolonged F&L stress for both normative and economic requirements.

Limits under idiosyncratic, market-related, combined idiosyncratic and

market-related, and climate risk scenarios, which lead to customer

deposit outflows, deterioration of access to funding markets, and lower

liquidity value of counterbalancing capacity are evaluated.

§Through the economic lens, ING assesses the extent to which its

customers, professional counterparties, and investors are comfortable

to provide deposits and funding in the tenors, currencies, and

instruments necessary to sustainably fund the business (intraday,

short-term, and long-term) in a going-concern situation.

§Through the normative lens, ING ascertains that the bank is in the

position to meet current and future domestic and host regulatory

requirements.

For each lens, ING has established a related set of risk appetite statements,

which define ING’s risk appetite, commensurate with the principles of

liquidity adequacy.

The F&L risk appetite statements are translated into metrics with

appropriate boundaries and instruments which are used to regularly

measure and manage ING’s funding and liquidity risk. The risk appetite

with respect to the stress lens aims to have sufficient counterbalancing

capacity under various internally defined stress scenarios. Regarding the

economic perspective, an internally defined stable funding to loans (SFtL)

ratio and stable funding surplus (SFS) metric (supplemented by other

metrics) is used to stimulate a diversified funding base and to prevent

overreliance on professional funding. Finally, the liquidity coverage ratio

(LCR) and the net stable funding ratio (NSFR) regulatory metrics are

monitored in terms of both ING’s risk appetite and normative

requirements.


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Funding and liquidity risk indicators


ING Group liquidity risk indicators
	2025	2024
Liquidity buffer (in € billion) 1	328.4	338.6
LCR 2	140%	143%
NSFR 3	128%	133%
Asset encumbrance (AE) 4	18%	19%
Survival period (severe stress) 5	>12 months	>12 months

1Consolidated Liquidity Buffer is reflected as a fixed point in time.

2Consolidated LCR is based on a 12-month rolling average.

3Consolidated NSFR is reflected as a fixed point in time.

4Consolidated AE is reflected as a median of the end-of period values for each of the four quarters

of the reporting year.

5Consolidated Survival period after management actions.

The liquidity buffer (counterbalancing capacity) is expressed as the market

value of the underlying positions and consists largely of deposits at central

banks and highly liquid assets qualifying as HQLA for the LCR. In addition

to the HQLA, other securities, mainly retained covered bonds and ABS,

further strengthen the available liquidity buffer. Depending on the

underlying assets, haircuts are applied on the market value to determine

the liquidity value of the buffer.

Liquidity stress testing (*)

Funding and liquidity stress testing forms part of the overall F&L

framework. It allows ING to examine the effects of exceptional but

plausible future events on ING’s funding and liquidity position and provides

insight into which entities, business lines, or portfolios are vulnerable to

which types of risk drivers or scenarios.

The stress-testing framework encompasses the funding and liquidity risks

of the consolidated balance sheet of ING Group, including all entities,

business lines as well as on- and off-balance sheet positions. The net

liquidity position (NLP) is the main stress-testing measure and is measured

at different time buckets.

The stress-testing framework considers idiosyncratic, market-wide,

combined (idiosyncratic and market-wide) and climate-stress scenarios.

The design of the framework is based on empirical evidence supplemented

by expert judgment. The framework can be extended to additional ad-hoc

scenarios. For example, it can be used as input for firm-wide stress testing

and reverse stress testing.

Outcomes of the stress tests are considered in the key aspects of ING’s F&L

risk framework and F&L risk management, including:

§Risk Appetite Framework (through risk appetite statements);

§Risk identification and assessment;

§Monitoring of the liquidity and funding position;

§Business actions (if needed);

§Contingency funding plan; and

§Early-warning indicators.

The funding and liquidity stress-testing framework is also subject to

regular internal validation by model validation.

In line with supervisory expectations, ING’s liquidity position is stress tested

on (at minimum) a monthly basis using scenarios that form part of the

F&L risk appetite statement. The results of all internal stress scenarios are

monitored and assessed on a monthly basis. In addition, ad-hoc scenarios

based on current economic and market developments are run to

determine their potential impacts on the funding and liquidity position of

ING. In 2025, this included stress-test scenarios assessing the impact of a

shutdown of US short- and long-term funding markets and FX markets.

The internal stress scenarios and their corresponding results serve as input

in the decision on holding additional contingency measures.

Contingency funding planning (*)

ING’s contingent F&L risks are addressed in its Contingency Capital and

Funding Plan (CCFP). The objectives of the CCFP include:

§Establishment of a monitoring framework to detect approaching

contingent events as well as their impact on ING’s F&L position;

§Provision of a plan for responding to various and increasing levels of a

bank’s liquidity and capital shortfall under adverse and stressed

conditions;

§Designation of management responsibilities, crisis communication

methods and channels, and reporting requirements;

§Identification of contingent capital and liquidity sources under

escalating adverse and stressed conditions; and

§Description of the steps needed to ensure the bank’s capital and

liquidity sources are sufficient to fund scheduled operating

requirements and meet the institution’s commitments, with minimal

costs and disruption.

The contingency funding measures are developed in conjunction with the

ING Recovery Plan and are reviewed and tested on a regular basis.

1 In line with the European Central Bank (ECB) guide on climate-related and environmental risks.

2 As per the ING Group Risk Identification and Risk Assessment Procedure for ICLAAP purposes.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	201

Environmental, social and governance (ESG) risk

Introduction

ESG risk is defined as any negative financial and/or non-financial impact

on ING due to the present or future impact to/dependencies from factors

on and stemming from ING’s full value chain.

ESG risk is not an independent risk category/risk type but rather a set of

drivers1 affecting the likelihood and severity of existing risk categories/risk

types. ESG risk is an overarching set of risk drivers affecting:

§Financial risks: credit risk, market risk, funding and liquidity risk;

§Non-financial risks and compliance risk; and

§Other overarching risks: model risk and business and strategy risk.

The risk drivers2 are defined as risk events that lead to an impact on ING’s

financial solvency or funding and liquidity position via the above-

mentioned risk types. Our comprehensive approach ensures we integrate

ESG considerations into our risk management practices, aligning with our

commitment to sustainable growth and resilience.

Definitions

ESG factors

ESG factors are defined as environmental, social or governance matters that may have a positive or negative impact on the non-financial/financial performance

or solvency of an entity, sovereign, or individual. ING's ESG taxonomy of ESG factors are defined through the consideration of the CSRD and EUT.

Environment

§Climate-change adaptation

§Climate-change mitigation

§Pollution

§Water & marine resources

§Circular economy

§Biodiversity and ecosystems

Social

§Own workforce and workers in the value chain

§Customers

§Communities

Governance

§Business conduct

Value chain

Value chain is a concept derived from CSRD Annex II as 'the full range of activities, resources and relationships related to the business model(s) of the undertaking

and the external environment in which it operates'. For ING, the concept of the value chain defines the scope of the ESG risk management lifecycle.

Supply chain

Own operations

Wholesale

Banking

Business Banking

Private Individuals

& Private Banking

Treasury & other

investments

Double materiality

ING must identify both actual and potential:

§impacts on people and the environment (impact materiality, inside-out); as well as

§sustainability matters that impact ING's financial positions (financial materiality, outside-in).

Impact materiality and financial materiality assessments are interrelated, as financial materiality may stem from negative impact, dependency on resources and

context analysis. ING defines material ESG factor per value chain for both impact and financial materiality.

1Important ESG factors are determined on a case by case basis and consider international standards such as the OECD Guidelines for Multinational Enterprises on responsible business conduct and the UNGPs on Business and Human Rights.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	202

The ESG risk framework

The ESG risk framework provides a definition of ESG risk, the governance

structure supporting the management of ESG risk, and an overview of the

various roles and responsibilities related to ESG risk. The framework assists

in managing ESG risk effectively through the application of the risk

management process at various levels of the organisation. The framework

integrates governance components, including the three lines of defence,

defined organisational responsibilities, and ESG oversight bodies, and is

underpinned by a continuous ESG Risk Management Cycle (aligned with

the Risk Management Cycle) encompassing identification, assessment,

mitigation, reporting, and monitoring, as described in detail below.

Governance

ING has a governance structure with well-defined, transparent, and

consistent lines of responsibility in managing ESG risk in line with the three

lines of defence. For more information, see ‘Three lines of defence’.

ESG risk bodies

The ESG committees and bodies at ING are responsible for overseeing and

integrating ESG matters into ING’s strategy and daily operations in line

with our sustainability governance. The following committees, bodies, and

their associated charters are relevant with regard to the framework:

§Supervisory Board ESG Committee (SB-ESG): The ESG Committee assists

the SB by generally monitoring and advising on relevant ESG

developments.

§Executive Board (EB) and Management Board Banking (MBB): ING’s EB/

MBB has overall responsibility for the ESG risk framework and is

accountable for having it implemented and embedded.

§The key risk committees: Acting within delegated authorities granted

by the MBB, support on implementation and execution of the controls

mitigating material ESG risks.

§ESG Risk Committee (ERC): A standing committee that receives its

mandate from the MBB, and is responsible for the approval of ESG risk

procedures and mandatory instructions as well as its rollout in the

different impacted functions. In addition, it advises MBB and MBB-

delegated committees on the implementation and execution of the

controls mitigating material ESG risk.

Organisational bodies

Management of ESG risk is embedded within all material risk types across

the three lines of defence. Within the CRO domain, ESG risk governance is

embedded into the existing global risk governance framework. It aligns

with the structures that steer risk categories and types globally.

The global ESG Risk department’s role is to ensure that all risk functions

incorporate ESG considerations into their processes, while the local (ESG)

risk functions are responsible for the local adoption of the global policies,

methodologies and instructions issued by the global ESG Risk department.

Managing ESG risk

The primary concern relates to the long-term impact on credit quality and

income, rather than immediate solvency. Climate and environmental-

related risks may increase the risk of borrower default and reduce income

from vulnerable sectors. The focus is on managing underlying risks by

increasing risk management intensity. The ESG risk framework assists in

managing ESG risk effectively through the application of the risk

management process at varying levels of the organisation. The risk cycle

describes the processes by which ING can identify, assess, mitigate,

monitor, and report ESG risk integrated within the existing risk types.

Risk identification

It is our policy to formalise and maintain an up-to-date ESG impact and

risk inventory. This inventory includes descriptions of the drivers of ESG

negative impacts and ESG risks. Regarding the risk drivers, the inventory

further details their transmission channels and maps them to the risk

categories where ESG risk drivers can materialise. Additionally, the

inventory briefly outlines the drivers of positive impact and opportunities.

Risk assessment

ESG metrics are defined and assessed against predetermined thresholds to

determine materiality. The outcome of the double materiality assessment

(DMA) defines the way ESG risk is adopted in the business strategy and the

risk management of each risk category/risk type to be mitigated. In

addition to the results of the DMA, ING considers some ESG factors to be

important1 for the risk assessment and due-diligence processes that

follow.

1Material with reputational risk


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	Transmission channels	Material: Financial & non-financial risks1
E1: Climate change; E4: Biodiversity and ecosystems
	Business §Property damage & Business disruption §Stranded assets & New capital expenditure Households §Loss of income §Property damage Macro economy §Shifts in prices §Productivity changes §Labour market frictions	Risk category	Short term	Medium-long term
		Credit risk	E1, E4	E1, E4

		Compliance risk	S1, S4, G1	E1, E4, S1, S4, G1

		Market risk	In scope of the assessment, no material risks identified

		Liquidity risk

		Non financial risk	S1	S1

		Business risk	E1 (climate change mitigation)	E1 (climate change mitigation)

S1: Own workforce; S4: Consumers and end-users	Social and governance §Negative customer and investor preference §Legal liability for damages caused and loss of customer preference §Negative impact on workforce

G1: Business conduct

The above visualisation and the following paragraphs illustrate the

mapping of ESG risk drivers to financial and non-financial risks across

different time horizons.

§Credit risk

–Climate transition risk: ING has credit exposure to clients whose

business models may be more vulnerable to climate transition risks,

potentially resulting in business disruption and reduced earnings,

which could impair their ability to repay loans or meet other

financial obligations. In addition, adverse climate conditions may

lead to depreciation in the value of collateral.

•Entities may be affected by increased operating costs and

reduced revenue due to fines, taxes and adaptation costs which,

in turn, might decrease clients' affordability and ability to repay,

thus increasing PDs.

•The transition to environmentally sustainable economies might

make carbon intensive assets in ING’s lending portfolio more

vulnerable to disinvestment and demand – leading to potential

write-offs, stranded assets, early retirement of assets (based on

carbon profiling/intensity) and a decrease in the collateral value

for brown assets. This in turn might result in higher loan to

values (LTVs) and LGDs.

–Climate physical risk: Climate-related physical impacts can lead to

significant losses, unexpected expenses, and reduced income and

profits for borrowers. This may impair their ability to repay loans,

thereby increasing credit risk for ING. Additionally, the frequency

and intensity of extreme events can affect the value of real estate

or other collateral, altering the relationship between the loan and

the asset’s value.

•Acute and chronic risks can negatively impact cash flows of

affected entities: 1) as damaged physical capital might generate

less income, 2) operational disruptions might lead to decreased

productivity and increased operational costs and 3) increased

insurance premiums. This might decrease clients’ affordability

and ability to repay debt and therefore increase PDs. For

sovereign and municipal exposures, the income effects from

physical risk events may primarily arise through lower tax


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	204

revenues and higher spending channels to compensate for

negative impacts and adaptation costs.

•Write-offs, asset devaluation and early retirement of existing

assets due to acute events decrease the value of collateral and

have a negative impact on LTVs, and therefore LGDs.

–Biodiversity and ecosystems (impact on species): The negative

impact on biodiversity, which can result in a demise in natural

resources, can disrupt clients’ operations, leading to financial losses.

Financial losses can also occur due to reputational damage. This

may leave them unable to repay loans or meet their obligations on

other financial transactions at the same time as reducing the value

of the business.

§Compliance risk

–Climate transition risk: Assuming that regulation in Europe will

continue to increase in the coming years and decades, the inherent

risk may rise accordingly. These risks are expected to become more

pronounced in the medium and long term, driven by increased

regulatory expectations and stronger embedding in the prudential

framework.

Business Conduct: Financial loss, regulatory fines, and reputational

damage resulting from infringements of our corporate culture, potential

instances of bribery and corruption, and failure to protect whistleblowers.

–Consumers and end-users: materialisation of negative impact

due to not providing access to quality information on transition and

physical risks. Also includes privacy risk when failing to protect our

customers’ data.

–Own workforce: privacy risk linked to data protection of our own

employees.

Non-financial risk

§Own workforce: due to People Risk and/or Employment & Practice Risk

(EPR), regarding the employment and inclusion of persons with

disabilities and from diverse background. Moreover, EPR due to

significant concerns raised on violence & harassment in the workplace.

§Business and strategy risk

–Climate transition risk: High transition risk may materialise if ING’s

clients are unable to adapt their business models in line with

climate regulation. In such cases, increasing carbon costs,

regulatory restrictions, or declining market demand can weaken

clients’ profitability and balance‑sheet strength. This may translate

into reduced lending opportunities, ultimately affecting future

income generation.

Failing to meet the commitments made can result into a loss of trust

among ING’s customers and stakeholders, which can result in customers

choosing to take their business elsewhere. ING may therefore face

increased costs related to customer acquisition and retention efforts,

ultimately affecting profitability.

Measurement methodologies and impact

ING measures its exposure to ESG risks by assessing risks through risk

quantification methodologies and tools. The methodologies take into

account qualitative and quantitative criteria, different time horizons, and

scenario analysis and stress testing,supporting an assessment of the

organisation’s resiliency under various climate and ESG‑related conditions..

Quantification leverages on top-down and bottom-up approaches, when

applicable.

§Physical risk tool: ING has developed a tool to measure and assign a

level of physical risk for four chronic and nine acute physical risks

across the short, medium, and long term for portfolios and geographies

in which ING operates. This range of hazards is recognised under EU

Taxonomy. The thorough selection of hazards means this tool caters

for broad, continent-spanning risks as well as local and nuanced ones.

The tool has been developed using physical risk maps obtained and

recognised by academically reputable sources.

§Transition risk scorecard is used by ING to quantify transition risk

with a scorecard approach at client level. Methodology helps to identify

the pool of high-risk clients within specific sectors, in order to

subsequently manage these high-risk subsegments, taking into

account ING’s public commitments and sector-specific climate

strategies (Terra approach). This pool of high-risk clients is

subsequently managed via the climate risk-appetite setting.

§ESG risk-assessment tool: For WB, ING has developed an ESG risk-

assessment approach which considers the (climate and)

environmental, social and governance risk factors, negative impacts

and dependencies of our WB customers, and fully integrates the

previous ESR framework, which is now embedded under the umbrella

of the new ESG Risk Framework. Tooling was developed to support the

implementation of the assessment approach in the credit granting

process. Depending on the ESG risk-assessment outcome and the

impact on financial risks, addition mitigation might be required and

factored in as one factor for the broader credit risk assessment.

§Climate Stress Test and Resilience Analyses: ING continues

enhancing its climate stress-testing methodology to assess the impact

of climate risks on corporate and mortgage exposures from a credit risk

perspective under different climate scenarios.The methodology for

short/medium-term stress test (referred to as Climate Stress Test or

CST) builds on existing stress test methodology (e.g., ICAAP, EBA), while

a dedicated long-term methodology has been developed (referred to

as Climate Resilience Analysis or CRA) to assess the impact on

provisions under various scenarios and portfolio assumptions.

For both CST and CRA, dedicated climate scenarios are used, developed

using NGFS short-term and long-term (Phase V) scenario publications as

foundational inputs. These scenarios cover different narratives and explore

the impact of 1) a baseline/continuation of current policies scenario, 2) a

Net-Zero smooth transition scenario, 3) a delayed and abrupt transition

scenario, 4) a low transition risk but high physical risk scenario. These

scenarios influence macro-economic variables projections (e.g. GDP,

unemployment rate, house prices, etc.) which, in turn, determine the

forecast of the main credit risk parameters (e.g. risk migrations, PDs, LGDs

etc.). This is referred to as the "macro" transmission channel.

In addition, dedicated climate overlays are incorporated to account for the

impact of transition, physical and nature risk on a more granular level. This

is referred to as the "micro" transmission channel.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	205

For mortgages transition risk is modelled by estimating the relationship

between household income and probability of default (PD), factoring in

rising carbon prices, energy costs, and renovation expenses required for

low energy label properties. A PD multiplier is then derived per portfolio,

per energy performance certificates (EPC) levels. Physical risk is assessed

using ING’s in-house Physical Risk Tool, which combines hazard maps and

property-level exposure data to estimate expected losses. LGD is adjusted

based on modelled damage functions and loss estimates of material

Physical Risk.

For corporates, the dedicated overlays are implemented in the form of PD

multipliers across 16 NACE sectors. These multipliers are derived using

ING’s EEST (Environmental Elasticity Scenario Tool) which assesses the

impact of transition, physical and nature risk shocks on the market price

and volume per sector, and subsequently the impact of these shocks on

the counterparty’s financial position. The resulting financial stress is then

reflected in PDs.

The long‑term analysis informs the resilience of the bank’s business model.

ING’s proactive portfolio steering, sector‑specific transition engagement,

and transaction‑level risk‑management measures collectively enhance the

bank’s capacity to navigate increasing climate pressures and preserve its

business resilience over time.

Risk mitigation

The mitigation of the identified risks in line with the risk appetite can be

performed through several risk mitigating strategies, such as reducing the

risk level, avoiding risk, accepting risk, or transferring the risk. The

measures are embedded as part of the updates of the existing policies and

procedures in the different risk categories/risk types in order to mitigate

ESG risks with a material financial impact. Mitigation activities can be

performed at a process, product, portfolio, client, or transaction level and

include, but are not limited to:

§engaging with high ESG risk counterparties to understand and support

their mitigation plans;

§setting RAS to limit the level of acceptable risks;

§incorporating ESG risks in the collateral valuation process; and

§ensuring appropriate business continuity plans and insurance are in

place to reduce the impact of more frequent and severe ESG events for

ING’s value chain.

Risk monitoring, reporting and disclosures

ING aims to provide regular and transparent ESG reports and regulatory

disclosures to ensure the management body and all relevant units in ING

receive ESG risk information in a timely, accurate, concise, clear and

meaningful manner. These reports cover the identification, assessment,

measurement, monitoring, and management of ESG risks.

The ESG risk dashboard consists of comprehensive and integrated ESG risk-

related, financial and non-financial information on business activities and

own operations, summarising the following:

§Results of the double materiality assessment, detailing negative

impacts, financial and non-financial materiality for each value chain

segment;

§ING key climate risk indicators for material ESG risks across value chain

segments. The depth of reporting is informed by the materiality

assessments performed; and

§The outcome of the latest climate stress-testing assessment.


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Non-Financial risk

Introduction

Non-financial risk (NFR) is defined as the risk of financial loss, legal or

regulatory sanctions, or reputational damage due to inadequate or failing

internal processes, people and systems, a failure to comply with laws,

regulations and standards, or external events.

Non-financial risk management

Risk categories

ING categorises non-financial risks in the following 10 areas:

§Compliance risk is the risk of personal harm, financial loss, regulatory

fines, litigation, business disruption and/or reputational damage due to

impairment of ING Group’s integrity caused by a failure (or perceived

failure) to comply with applicable external laws, regulations and market

standards, societal expectations and internal ING rules.

§Information (technology) risk is the risk of financial loss, regulatory

fines, litigation, business disruption and/or reputational damage,

breach of confidentiality, failure of integrity of systems and

information, inappropriateness or unavailability of systems and

information or inability to change information technology (IT) within a

reasonable timeframe and with reasonable costs when the

environment or business requirements change (i.e. agility). This

includes security risks resulting from inadequate or failed internal

processes or external events including cyberattacks or inadequate

physical security.

§Operational resilience/business continuity risk is the risk of financial

loss, regulatory fines, litigation, business disruption, and/or reputational

damage due to the organisation’s inability to deliver its Critical Business

Services within their impact tolerance levels, and to respond and

recover from severe disruption or crisis within predefined time frames,

service levels, and capacity.

§Control risk is the risk of financial loss, regulatory fines, litigation,

business disruption, and/or reputational damage due to not complying

with controls set through governance procedures and/or project

management methods, caused by improper or insufficient monitoring

(testing) of entities or activities. The key components of Control Risk

include Third and Intragroup Party Risk (TIPM) and Model Risk.

§Processing risk is the risk of financial loss, regulatory fines, litigation,

business disruption and/or reputational damage due to unintentional

(human) error during (transaction) processing, or due to data issues

(including inadequate data governance, poor data quality, data not

available for use, or data architectures not supporting business needs

for data aggregation/consumption or reporting).

§Unauthorised activity risk is the risk of financial loss, regulatory fines,

litigation, business disruptions and/or reputational damage due to

unauthorised employee activities, approvals, or overstepping of

authority that breach delegated mandates without constituting fraud.

§Personal and physical security risk is the risk of financial loss,

regulatory fines, litigation, business disruption, and/or reputational

damage due to criminal and environmental threats that might

endanger the security or safety of ING personnel at work, people in ING

locations, ING assets or assets entrusted to ING, people at ING event

locations, or might impact the organisation’s confidentiality, integrity,

or availability.

§Employment practice risk is the risk of financial loss, regulatory fines,

litigation, business disruptions and/or reputational damage due to

breaches of employment, health, and/or safety laws, regulations or

agreements from payment of personal injury claims, from diversity/

discrimination events, unsafe physical and psychosocial working

conditions, or from the unavailability of staff.

Fraud Risk consists of two risk areas:

§Internal fraud risk is the risk of financial loss, regulatory fines, litigation,

business disruption, and/or reputational damage due to acts of fraud

performed by or in collusion with an ING employee.

§External fraud risk is the risk of financial loss, regulatory fines, litigation,

business disruption, and/or reputational damage due to acts of fraud or

scams by individuals, and/or parties excluding ING staff (and ING

contractors).

In line with ING’s sustainability strategy and regulatory requirements

relating to ESG Risk Management, the NFR Framework has been updated

to ensure ESG Risk is properly embedded in our risk management cycle

and material risk types in line with the overarching ESG Risk Management

Framework.

Risk appetite and tolerances

ING sets a Group-wide risk appetite for non-financial risks, supported by

quantitative and qualitative tolerances. Tolerances are cascaded to

business lines and are calibrated to reflect our strategy, stakeholder

expectations, and regulatory requirements. Performance against appetite

is monitored through a suite of Key Risk Indicators and assessed quarterly

by management committees, with breaches triggering predefined

escalation and remediation. The Supervisory Board is informed of material

movements relative to appetite through regular risk reporting.

Issue management and remediation

Issues arising from risk assessments, control testing, events, audits, and

supervisory reviews are recorded in a central issue management system.

Each issue has a clearly defined owner, risk classification, target

remediation date, and acceptance criteria. Progress is tracked through

regular governance routines, and overdue items are periodically reported

to senior management for follow-up. Closure is subject to evidence-based

validation.

Measurement approach

As of 1 January 2025, following CRR3 regulation, ING is using the

Standardised Measurement Approach (SMA), a non-model-based formula

to calculate regulatory operational risk capital. An internal Operational Risk

Economic Capital (OREC) model is used for economic capital and stress

testing purposes (Pillar II). The OREC model estimates the economic capital

required to cover potential losses arising from various non-financial risks

within ING. The OREC model involves the use of historical internal and

external losses together with forward-looking and expert-driven loss

estimates to arrive at bank-level loss distribution. The outcomes of the

OREC model are reported quarterly.

Main developments in 2025

The external environment continues to present significant uncertainty and

complexity. Geopolitical tensions and regulatory divergence across


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	207

jurisdictions create challenges for global operations. These dynamics may

increase exposure to non-financial risks, requiring ongoing enhancement

of risk mitigation measures and capabilities. At the same time, evolving

consumer expectations and strengthened consumer protection

regulations are likely to raise the standards for secure and resilient

banking operations. ING is continuously working to further mature its risk

management practices, ensuring continued readiness and resilience in this

changing landscape.

Continuity Risk

Providing safe, secure, and seamless services for our customers is central

to ING’s strategy as we focus on providing superior value to our customers.

Operational and IT Resilience measures are key in preventing disruptions

and ensuring a quick recovery when disruptions do occur. During 2025, ING

has further strengthened the implementation of the Operational Resilience

framework in the organisation. The framework aims at safeguarding the

resilience of our most critical business services and the related processes

and systems, facilities, people, data, and third- and intragroup services. As

an example, more real-life simulations of outages are performed to test

the resilience of our critical business services under severe stress scenarios,

including the effectiveness of anticipated contingency measures. The bank

continues to strengthen the framework, including measures related to

concentration risk and the oversight of material subcontractors in

outsourcing. Strengthening our Operational Resilience is a multi‑year

journey and a lot of progress has already been made. Over the coming

period, we will further enhance areas such as supplier concentration risk

management, oversight of material sub‑contractors, and the scope and

realism of our outage simulations.

Information (Technology) Risk

The mission of Information (Technology) Risk, together with the IT

organisation, is to help ING stay safe and secure by preventing and

mitigating unauthorised access to systems and safeguarding the

confidentiality, integrity, and availability of the data within them. To

deliver on this mission, we are continuously strengthening and maturing

our joint framework, ensuring it is equipped to adapt to emerging risks.

These risks arise from new or changing regulations (such as the EU

Artificial Intelligence Act (AI Act) and Payment Services Directive 3 (PSD3)),

rapidly shifting threat landscapes (e.g., AI-enabled attacks, QR-code

phishing, quantum-related risks), ongoing digitalisation of value chains,

adoption of new technologies and digital products, and geopolitical

developments. To keep ahead, ING implemented further enhancements in

measuring and reporting on IT risks in 2025, which will continue in 2026.

The overall cybersecurity maturity increased, due to in particular to

significant progress in the area of Identity & Access Management (IAM). IT

Resilience remains a key focus to prevent and mitigate disruption of

services and data. This is done by further developing capabilities to recover

from large-scale ransomware events and by enhancing failover and

recovery of global, shared systems, supported by the Global Infrastructure

organisation and the Chief Information Security Office (CISO). In 2025, ING

continued to develop, improve, and test these capabilities. Since the

external cyber threat landscape is evolving quickly, which demands

continuous improvement for the coming years.

Fraud Risk

In 2025, ING reinforced its commitment to fraud resilience, focusing on

early detection, smarter prevention, and stronger governance. Our global

strategy is designed to prevent and reduce fraud-related losses and

provide customers with tools to recognise and avoid fraud, like the ‘check

the call’ feature.

Increasing complexity and rising volumes of fraud, driven by technological

developments such as AI-enabled schemes, are already evident.

Capabilities are enhanced through predictive analytics, extended

reporting, and cross-market alignment via the Global Fraud Target

Operating Model. These efforts ensure consistent execution and

continuous improvement across countries. Collaboration remains central

to our approach. ING works closely with industry peers, regulators, and law

enforcement to address fraud as a societal challenge.

Personal & Physical Security Risk

In 2025, the complex geopolitical situation continued to pose significant

threats to the safety and security of ING’s assets and employees (e.g. wars

in Ukraine and the Middle East, hybrid warfare, and unstable political

environments). ING is monitoring these geopolitical risks closely, and

security measures and procedures are being implemented to mitigate

both current and potential impacts on ING’s assets and staff.

Rising activist actions, political extremism, and social polarisation are

creating an increasingly volatile threat landscape, heightening uncertainty

for ING and its operations. These risks require specific actions to protect

assets and people from security threats and disruptive movements,

including heightened vigilance and proactive coordination with authorities.

To strengthen and accelerate response capabilities, a dedicated global

first-line Safety and Security department was established in 2025.

Data risk management

At ING, managing Data Risk is about having the right data of good quality

readily available for business or regulatory purposes, in a secure and

compliant way. As emerging technologies such as AI continue to evolve

and data volumes expand at a rapid pace, our primary objectives are to

address data-related regulatory obligations, manage risks associated with

data-driven technologies like AI, and ensure ongoing alignment with

societal expectations. ING has set up clear governance and initiatives to

ensure the ethical handling of data, and to integrate regulatory

requirements (e.g. EU AI Act, BCBS239) in its policies and way of working.

ING’s data strategy is making steady progress, strengthening data quality

and data governance, and supporting clear accountability across the

organisation. Data Risk Management is applied to the data strategy to

oversee and anticipate business expectations (incl. regulatory

requirements), to measure (e.g. via KRIs) against our defined risk appetite

statement, as well as to monitor the status of regulatory programmes

(e.g. BCBS239). Since the Data Risk landscape is evolving rapidly, ING will

continue to enhance Data Risk Management. In the coming years ING will

invest in data literacy, scaling data capabilities, tooling and strengthening

governance for data and AI-driven technologies.


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Compliance risk

Introduction

ING aims to conduct its business activities in compliance with applicable

internal rules (including ING’s risk appetite statements) and external laws

and regulations, whilst also taking societal expectations into consideration.

Compliance risk is defined as the risk of personal harm, financial loss,

regulatory fines, litigation, business disruption and/or reputational damage

due to the impairment of ING Group’s integrity caused by a failure (or

perceived failure) to comply with applicable external laws, regulations and

market standards, societal expectations and internal ING rules.

Within ING, we apply the following compliance risk categories:

§Financial crime risk refers to the risk of the bank’s products and services

being abused for illicit purposes, generating, facilitating or disguising

financial and/or economic crimes (FEC).

§Conduct risk refers to compliance risk arising from (the perception of)

breaching our obligations towards customers and/or other parties,

including inappropriate market conduct.

§Data protection (personal data protection, data retention) risk refers to

the personal data protection risk of financial loss (regulatory fines,

reputational damage) due to not protecting the personal data rights of

individuals as required, and as to data retention risk, to having the

records being destroyed too soon or retained too long.

The Compliance organisation has the mission to drive compliance risk

management by desire and design throughout the organisation.

Compliance’s primary role is advising, challenging, and overseeing the first

line of defence in how they manage compliance risks, as well as raising

awareness and stimulating a sound compliance risk culture.

Training and awareness

At ING we believe all our people play a role in protecting our customers,

the bank and, through that, society too. A sound risk culture is promoted

by empowering our employees with the skills and knowledge they need to

manage compliance risks. In 2025, we continued to train our people with

mandatory trainings on financial crime, conduct and data protection.

Senior Management (MBB and SB) are trained on various compliance risk

topics based on a multi-year training plan.

Financial crime and fraud prevention

Financial Crime and Fraud Prevention (FCFP) in the first line of defence and

Financial Crime Compliance (FCC) in the second line of defence continue to

jointly play a major role in our aim to make sure we only engage and do

business with people and entities that meet regulatory requirements.

Knowing who we do business with is vital to keeping ING safe, secure, and

compliant. As part of our ongoing anti-money laundering efforts, we

continuously assess relationships with both new and existing customers,

monitor and screen transactions to fulfill our regulatory and reporting

obligations, whilst ensuring unusual and/or potentially suspicious

transactions are reviewed/investigated. Where applicable, we report these

to the relevant authorities.

Financial crime risk management

The day-to-day responsibility for the oversight of ING’s compliance with

our legal and regulatory obligations, in relation to financial crime risks, sits

with the global head of Financial Crime Compliance, who reports to ING’s

CCO, with oversight by the CRO. As a global financial institution combatting

financial crime, and to comply with anti-money laundering and counter-

terrorism financing (AML/CTF) laws and regulations, we have established a

reasonable and risk-based control framework to mitigate continuously

evolving financial crime risk, and seek to provide useful information to

relevant government agencies.

Operational effectiveness (OE)

ING’s global KYC policy and related control standards set the minimum

requirements and control objectives for all ING entities to guard against

involvement in financial crime activity, while reflecting relevant national

and international laws, regulations, guidance documents, and guidelines

from national, European and international authorities, (supra)national risk

assessments, and industry standards. In 2025, our focus has shifted from

foundational maturity to maintaining operational effectiveness, with

oversight and challenge from the second line of defence. This evolution is

supported by the completion of the multi-year KYC Enhancement

Programme, which strengthened our customer due diligence and

transaction monitoring capabilities.

Evolving financial crime and regulatory landscape

Financial crime continues to evolve, whether through technology, new and

sophisticated techniques used by criminals, or the results of geopolitical

events. The widespread digitalisation of the economy and use of AI has led

to a reshaping of the methods used to launder money and finance

terrorism. Criminal groups have adopted and are misusing new

technologies, AI, and anonymity-enhancing technologies, such as virtual

currencies and mixers, to commit criminal activities.

In response to this and heightened supervisory expectations, so too has

the regulatory environment evolved. The EU’s Anti-Money Laundering

Regulation (AMLR) and the establishment of the Anti-Money Laundering

Authority (AMLA) mark a significant step toward harmonised oversight

across member states, with full implementation expected by 2027.

ING actively participates in industry consultations and regulatory

dialogues to shape these frameworks, while embedding operational

effectiveness and advanced analytics into KYC and transaction monitoring

processes. These developments reflect ING’s strategic ambition to

safeguard the integrity of the financial system and strengthen resilience

against financial crime risks. In addition, we are committed to a risk-based

approach (RBA), ensuring resources are focused on higher-risk areas while

maintaining compliance with evolving global standards. This is

underpinned by investment in data-driven, continuous risk assessment

methodologies aimed at providing dynamic insights into emerging threats

and enabling proactive risk mitigation strategies.

These innovative technological capabilities enhance our cooperation with

law-enforcement agencies, industry bodies and regulators, and further

development of intelligence and data-led collaborative solutions to detect

and disrupt financial crime. In this context, this may at times include

sharing information within ING to manage our financial crime risk

exposure, in line with General Data Protection Regulation requirements

and local privacy laws and regulations.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	209

Bribery and corruption

Bribery and corruption undermine business confidence and corporate

integrity, hinder fair business competition, and harm international trade.

Bribery and corruption risks are considered as part of our client and third-

party due diligence, and financial crime risk monitoring measures. This

supports our zero-tolerance approach to bribery and corruption, which is

also part of the governance elements of our sustainability objectives and a

main principle in our Global Code of Conduct.

Customer tax compliance

Compliance with customer tax-related regulations and reporting

obligations, under the Foreign Account Tax Compliance Act (FATCA), the

Common Reporting Standard (CRS), and Mandatory Disclosure Rules, aims

to ensure that ING is not involved in facilitating tax-related financial crime,

such as tax evasion and harmful aggressive tax-avoidance schemes, on

behalf of its customers.

Sanctions

It is ING’s policy to take into consideration the applicable sanctions regimes

as imposed by international authorities and by local mandatory sanctions

law (as applicable). ING’s policy generally prohibits relationships or

transactions involving sanctioned persons and entities or comprehensively

sanctioned countries, territories and their governments. This sometimes

also means that ING’s risk appetite may be stricter than legal obligations,

and we may choose not to support certain customer relationships,

business activities and transactions, even if permitted by law.

ING continuously monitors external developments to remain proactive to

new sanctions packages or updates to existing sanctions packages.

Throughout 2025, geopolitical risk has grown (e.g. conflict in the Middle

East and the continuation of Russia’s invasion in Ukraine), and global

sanctions regimes remained increasingly active, creating a complex

regulatory and legislative environment. There has been an increasing

focus on the potential circumvention of sanctions against Russia, and the

roles of third countries and companies in facilitating any circumvention or

undermining the sanctions’ measures. This has prompted a concerted

effort by governments to impose pressure on companies operating in

these jurisdictions, and to prevent sanctions measures being sidestepped

by targeted Russian parties. ING’s sanctions programme is designed to

comply with sanctions across the multiple jurisdictions in which ING has

business operations.

Since February 2022, ING has taken measures to not engage in new

business with and in Russia and follows an active de-risking approach. The

approach aims to reduce ING’s overall exposure towards Russia, including

measures to reduce operational risks and to further ringfence activities of

ING Bank (Eurasia) JSC. On 28 January 2025, ING announced the proposed

sale of ING Bank (Eurasia) JSC to Global Development JSC. Completion of

the transaction is subject to various regulatory approvals. As of the date of

this report and as announced in September 2025, the buyer has not

received all necessary approvals yet. We continue working towards

completing the transaction and our exit from the Russian market. In the

meantime, we are in discussion with regulators on the conflicting

regulatory requirements in various jurisdictions with respect to the

activities of ING Bank (Eurasia) JSC.

As a result of frequent evaluation of the business from economic, strategic

and risk-based perspectives, ING, with limited exception, does not engage

in business involving certain countries, including Cuba, Iran, North Korea,

Sudan, Syria and the Crimea region. ING has a policy not to enter into new

relationships with clients from these countries and processes are in place

to discontinue existing relationships involving these countries.

Public-private partnerships

We continue to work with our peers, regulators and law enforcement in

public-private partnerships (PPPs) in our major markets, and on an

international level, by being part of existing PPPs and by initiating new

partnerships, such as those with German stakeholders and counterparts.

We recognise that our risk management frameworks and controls benefit

from having a direct dialogue with public partners as well as

complementing our understanding of relevant and evolving financial crime

threats and risks. Sharing and applying these insights across the

organisation helps us move beyond technical regulatory compliance and

enhances our ability to manage risks.

Conduct compliance and ethics

ING’s product governance and conduct compliance risk management

amplify that we aim to act in the interest of our customers. Focus areas

include customer protection and transparency (referred to as customer

centricity), market conduct (including counteracting market manipulation

and abuse), anti-competitive conduct, and management of conflicts of

interest.

Customer centricity

Putting our customers at the heart of what we do continues to be reflected

in ING’s Compliance framework around customer centricity. The Customer

Centricity Policy (CCP) sets central norms to meet customer needs on a

continuous basis, from the creation of a product and throughout the full

product lifecycle. In order to ensure the customer voice is reflected in the

way we measure compliance with customer centricity norms, we

developed a data driven approach to measure customer outcomes by

combining customer experience-related data with control data, increasing

our insight into trends and allowing business and Compliance to respond

to potential customer harm at an early stage. In 2025, we have

implemented the EU Accessibility Act setting the minimum norms for the

accessibility of products and services.

ESG

In line with ING’s strategy to put sustainability at the heart of what we do,

the ESG & Ethics team in Group Compliance aims to ensure a structural

and embedded approach to ESG within Compliance. Material ESG-related

topics are increasingly influenced by fast-moving regulatory changes, and

rising stakeholder expectations. To proactively manage these risks, ING is

strengthening its Compliance framework on several fronts. We are

continuing to enhance controls to prevent greenwashing, aligning ESG

commitments with evolving disclosure standards, and integrating physical

and transition risks into customer-centricity assessments. As new

regulations emerge, they are systematically incorporated into our

compliance risk management framework.


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Speak up and ethics

ING wants to create, facilitate and maintain an environment in which

employees feel encouraged and supported to speak up at all times.

Conduct ethics is about supporting and protecting our employees by

means of (i) dealing with dilemmas; (ii) setting the right environment for

ethical decisions and behaviours; and (iii) providing for an escalation/

reporting process in case of concerns, and ensuring fair consequence

management. We rely on our Orange Code, containing the values and

behaviours that guide us, the Global Code of Conduct that prevents and

protects employees from behaving unethically, and the whistleblowing

framework in case of concerns.

A new global platform that enables anonymous reporting has been

implemented across the vast majority of ING locations. We also continued

our focus on anti-retaliation, fair consequence management, deliberate

after-care and aligning best practices and data collection across different

Speak up channels.

Data protection

At ING, data protection is at the core of our strategy and business

operations. As part of our strategic priority of ‘Staying safe & secure’ our

main principle is ‘the right people using the right data for the right

purpose’, i.e. personal data usage and record retention must be strictly

necessary and based on a legitimate basis. More information can be found

in the privacy statement on our corporate website.

As a globally operating bank, our data protection governance and

technical and organisational measures aim to ensure compliance with

European and local data protection laws. A group-wide personal data

protection framework is in place and was overhauled in 2025 to remain

compliant with changing European legislation and guidelines. In addition,

we have binding corporate rules to ensure appropriate safeguards for our

internal data transfers. It is our policy that our business entities, support

functions, as well as third parties that we engage with, ensure that the

data subject is granted a level of protection equivalent to that guaranteed

by the GDPR, especially if personal data is transferred outside of the

European economic area (EEA).

Regulatory developments which potentially lead to emerging or changing

data protection risks are monitored and managed on an ongoing basis.

Advancements in technology, particularly in artificial intelligence and

digitalisation have substantially increased the complexity of personal data

processing activities. These developments demand increased attention

and monitoring to remain within risk appetite and to make sure we

comply with privacy laws and ethical standards. Therefore, we have

further strengthened our data protection risk management by refining

procedures and guidelines, particularly around risk related to technology

and AI. This ensures alignment with applicable information security

standards and enhances our cooperation with third-party providers. This

also includes our regular monitoring and reporting approach.

We will continue to enhance our data protection assessment processes

and continuously perform regular internal audits on the personal data

processing that we do for clients and employees, including ING’s

technologies. We stay closely connected to the relevant supervisory

authorities and notify them as required.


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Model risk

Introduction

Model risk is the risk of financial loss or reputational damage resulting from

decisions that are principally based on the output of models due to errors

in the development, implementation, or use of models.

Model lines of defence

ING’s model risk and control structure is based on the three-model-lines-

of-defence (MLoD) approach and defines three different management

layers with distinct roles and oversight responsibilities.

§The first MLoD is comprised of business entities which own, use, or

develop models.

§The second MLoD sets the model risk management framework,

monitors and reports on model-related risk, performs independent

model validation, and challenges 1MLoD risk management activities.

§The third MLoD is the internal audit function.

Model Risk Management (MoRM)

The ING MoRM policy framework comprises the total set of measures and

tools in place to manage model risk. ING defines and implements controls

across the model lifecycle. ING uses four classes of models that represent

their inherent level of model risk based on their criticality, financial

materiality, and complexity. The model classification determines the depth

and extent of the applied model risk management activities, including

model validation. Model validation is the independent assessment of

whether a model is valid for its intended use. Models are validated

according to procedures applicable to key model types. These procedures

are continuously being enhanced to keep up to date with regulatory and

technical developments, and industry trends.

Model risk appetite (model RAS)

The model risk appetite is designed to determine the level of model risk

ING is willing to accept in pursuit of its strategic objectives. The model RAS

metrics focus on the most material models for ING as reflected via the

model classification. These metrics are reported to the MBB monthly.

On an aggregated level, model risk is monitored via analysis of data from

the global model inventory, collected across the bank to manage ING’s

model landscape. Insights are shared with the MoRM Committee, MBB, and

other stakeholders, enabling senior management to make informed

decisions on whether to accept or further mitigate model risk.

AI risk management

In 2025, ING strengthened its commitment to responsible AI adoption by

creating an AI governance framework and control mechanisms, supported

by ethical principles that are applicable to all AI solutions. There are

dedicated staff allocated to AI risk management to support the risk

assessments in collaboration with the various risk functions. ING adopted a

qualitative Generative AI RAS (Risk Appetite Statement) focused on

customer protection, ethics, and accuracy and performance. The ING RAS

guides early-stage decision-making in areas where quantitative thresholds

are still under development, ING is committed to continue to strengthen its

AI risk management to ensure AI adoption remains safe and secure.

Business & strategy risk

Introduction

Business & strategy risk for ING has been defined as the risk inherent to

strategy decisions and internal efficiency measured by the value or

earnings loss from planning deviations, e.g. non-bank competition, internal

cost pressure, decreasing demand for loans, etc. This risk can be expressed

as earnings loss in terms of volumes, margins, expenses, and fee and

commission income. Business risk is accounted for within the economic

capital framework using a statistical model combined with a forward-

looking scenario module, which covers fee and commission income,

operating expenses, and regulatory expenses/costs.

Risk management

ING applies an explicit risk appetite statement regarding business and

strategy risk. It reflects the risks not already covered within the main risk-

type specific RAS, e.g. capturing risk costs, RWA, or NII. The underlying

economic capital risk types (expense risk, volume-margin risk, and

regulatory costs) are mitigated and managed via the financial

performance of the bank and the business units. Through this process, the

reported numbers are compared quarterly against financial projections

and discussed continuously within different parts of the organisation.


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Selected Statistical Information on Banking Operations

Reference is made to Note 1 ‘Basis of preparation and material accounting

policy information’ of the Consolidated financial statements for

information on Changes in accounting principles, estimates and

presentation of the consolidated financial statements and related notes.

The information in this section sets forth selected statistical information

regarding the Group’s operations. Information for 2025, 2024 and 2023 is

set forth under IFRS-IASB. Unless otherwise indicated, average balances,

when used, are calculated from monthly data and the distinction between

domestic and foreign is based on the location of the office where the

assets and liabilities are booked, as opposed to the domicile of the

customer. However, the Company believes that the presentation of these

amounts based upon the domicile of the customer would not result in

material differences in the amounts presented in this section.

Average balances and interest rates

The following tables show the Group’s operations, average interest-earning

assets and average interest-bearing liabilities, together with average rates,

for the periods indicated. The calculation of average balance is based on

balances as per month-end, while for certain products (such as Securities

purchased/sold under agreements to repurchase) balances can fluctuate

substantially during the month. The interest income, interest expense and

average yield figures do not reflect interest income and expense on

derivatives and other interest income and expense not considered to be

directly related to interest-bearing assets and liabilities. These items are

reflected in the corresponding interest income, interest expense and net

interest income figures in the consolidated financial statements. A

reconciliation of the interest income, interest expense and net interest

income figures to the corresponding line items in the consolidated

financial statements is presented in the following tables.


ASSETS
		Interest-earning assets
		2025			2024			2023
		Average balance	Interest income	Average yield %	Average balance	Interest income	Average yield %	Average balance	Interest income	Average yield %
		(EUR millions)			(EUR millions)			(EUR millions)
Time deposits with banks
	domestic	1,766	52	3.0	1,921	89	4.6	2,620	111	4.3
	foreign	1,633	259	15.8	1,388	290	20.9	1,236	256	20.7
Loans and advances
	domestic	202,457	7,135	3.5	187,540	7,191	3.8	184,864	6,548	3.5
	foreign	501,315	20,761	4.1	477,603	22,216	4.7	461,351	20,287	4.4
Securities purchased with agreements to resell
	domestic	31,590	893	2.8	10,904	377	3.5	17,174	343	2.0
	foreign	67,388	4,554	6.8	67,062	5,867	8.8	68,727	4,506	6.6
Interest-earning securities1
	domestic	38,192	948	2.5	35,467	799	2.3	32,511	562	1.7
	foreign	66,668	2,229	3.3	62,338	2,039	3.3	55,670	1,386	2.5
Other interest-earning assets
	domestic	26,166	829	3.2	44,302	2,160	4.9	56,611	2,720	4.8
	foreign	61,704	1,661	2.7	60,717	2,062	3.4	61,658	2,118	3.4
Total		998,880	39,319	3.9	949,242	43,089	4.5	942,421	38,839	4.1
Non-interest earning assets		61,298			65,580			54,850
Derivatives assets		26,330			26,422			30,215
Total assets		1,086,507			1,041,245			1,027,486
Percentage of assets applicable to foreign operations			70.0%			69.6%			67.8%
Other interest income:
Interest income on derivatives			11,633			15,717			13,112
Other			375			352			448
Total interest income			51,327			59,159			52,399

1Substantially all interest-earning securities held by the banking operations of the Company are taxable securities.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	213


LIABILITIES
		Interest-bearing liabilities
		2025			2024			2023
		Average balance	Interest expense	Average yield	Average balance	Interest expense	Average yield	Average balance	Interest expense	Averag e yield
		(EUR millions)		%	(EUR millions)		%	(EUR millions)		%
Time deposits from banks
	domestic	5,757	245	4.3	5,797	290	5.0	19,646	678	3.4
	foreign	7,280	187	2.6	7,806	288	3.7	11,881	308	2.6
Current accounts
	domestic	91,923	1,299	1.4	88,854	1,349	1.5	97,084	1,025	1.1
	foreign	131,769	456	0.3	125,858	577	0.5	135,088	362	0.3
Time deposits 1
	domestic	39,549	1,494	3.8	41,159	2,019	4.9	39,054	1,977	5.1
	foreign	82,171	2,886	3.5	76,510	3,293	4.3	43,111	1,876	4.4
Savings deposits
	domestic	123,227	1,415	1.1	114,398	1,531	1.3	108,789	901	0.8
	foreign	250,511	3,739	1.5	232,063	4,239	1.8	234,282	3,148	1.3
Securities sold under agreements to repurchase
	domestic	13,103	715	5.5	2,188	548	25.1	1,085	478	44.1
	foreign	45,319	3,701	8.2	54,823	5,232	9.5	64,905	4,314	6.6
Commercial paper
	domestic	18,303	520	2.8	18,072	749	4.1	13,159	484	3.7
	foreign	30,710	1,382	4.5	28,090	1,511	5.4	22,099	1,193	5.4


LIABILITIES
		Interest-bearing liabilities
		2025			2024			2023
		Average balance	Interest expense	Average yield	Average balance	Interest expense	Average yield	Average balance	Interest expense	Averag e yield
		(EUR millions)		%	(EUR millions)		%	(EUR millions)		%
Short term debt
	domestic	5,081	214	4.2	5,288	285	5.4	5,841	286	4.9
	foreign	1,414	165	11.6	1,738	131	7.6	1,669	72	4.3
Long term debt
	domestic	76,783	2,426	3.2	72,875	2,281	3.1	62,233	1,750	2.8
	foreign	26,508	722	2.7	22,835	685	3.0	19,106	549	2.9
Subordinated liabilities
	domestic	17,604	818	4.6	16,462	757	4.6	16,057	711	4.4
	foreign	129			40		0.0	0	0	0.0
Other interest‑bearing liabilities
	domestic	4,184	350	8.4	5,081	546	10.7	4,705	693	14.7
	foreign	10,261	433	4.2	7,632	266	3.5	6,639	253	3.8
Total		981,586	23,167	2.4	927,570	26,578	2.9	906,434	21,057	2.3
Non-interest bearing liabilities		27,462			36,419			37,365
Derivatives liabilities		22,241			23,236			28,452
Total liabilities		1,031,289			987,225			972,251
Group capital		55,218			54,020			55,235
Total liabilities and capital		1,086,507			1,041,245			1,027,486
Percentage of liabilities applicable to foreign operations			59.8%			59.5%			58.8%
Other interest expense:
Interest expenses on derivatives			12,936			17,030			14,927
other			267			263			253
Total interest expense			36,371			43,871			36,237
Total net interest result			14,957			15,288			16,162

1These captions do not include deposits from banks.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	214

Analysis of changes in net interest income

The following table allocates changes in the Group’s operations’ interest

income and expense and net interest result between changes in average

balances and rates for the periods indicated. Changes due to a

combination of volume and rate have been allocated to changes in

average volume. The net changes in interest income, interest expense and

net interest result, as calculated in this table, have been reconciled to the

changes in interest income, interest expense and net interest result in the

consolidated financial statements. See introduction to “Average Balances

and Interest Rates” for a discussion of the differences between interest

income, interest expense and net interest result as calculated in the

following table and as set forth in the consolidated financial statements.



		2025 over 2024			2024 over 2023
		Increase (decrease) due to changes in			Increase (decrease) due to changes in
		Average volume	Average rate	Net change	Average volume	Average rate	Net change
		(EUR millions)			(EUR millions)
Interest-earning assets
Time deposits to banks
	domestic	-7	-30	-37	-30	7	-23
	foreign	51	-82	-31	32	2	34
Loans and advances
	domestic	490	-547	-57	80	563	643
	foreign	1,054	-2,510	-1,455	810	1,119	1,929
Securities purchased with agreements to resell
	Domestic	715	-199	516	-125	159	33
	foreign	28	-1,342	-1,314	-109	1,470	1,361
Interest-earning securities
	Domestic	61	87	149	51	186	237
	foreign	142	48	190	166	486	652
Other interest-earning assets
	domestic	-884	-447	-1,331	-591	32	-560
	foreign	34	-434	-401	-32	-24	-57
Interest income
	domestic	375	-1,134	-759	-616	947	331
	foreign	1,309	-4,320	-3,011	866	3,053	3,919
Total		1,684	-5,454	-3,770	250	4,000	4,250
Other interest income				-4,062			2,510
Total interest income				-7,832			6,760


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	215



		2025 over 2024			2024 over 2023
		Increase (decrease) due to changes in			Increase (decrease) due to changes in
		Average volume	Average rate	Net change	Average volume	Average rate	Net change
		(EUR millions)			(EUR millions)
Interest-bearing liabilities
Time deposits from banks
	domestic	-2	-43	-45	-478	90	-388
	foreign	-19	-82	-101	-106	86	-20
Current accounts
	domestic	47	-97	-50	-87	411	324
	foreign	27	-148	-121	-25	240	216
Time deposits
	domestic	-79	-446	-525	107	-65	42
	foreign	244	-651	-407	1,454	-37	1,416
Savings deposits
	domestic	118	-235	-116	47	583	630
	foreign	338	-837	-500	-30	1,121	1,091
Securities sold under agreements to repurchase
	domestic	2,737	-2,571	166	486	-415	71
	foreign	-907	-624	-1,531	-670	1,588	917
Commercial paper
	domestic	10	-239	-229	181	84	265
	foreign	141	-270	-129	323	-6	318
Short term debt
	domestic	-11	-60	-71	-27	26	-1
	foreign	-24	58	34	3	56	59
Long term debt
	domestic	122	23	145	299	232	531
	foreign	110	-73	37	107	29	136
Subordinated liabilities
	domestic	53	9	61	18	27	45
	foreign



		2025 over 2024			2024 over 2023
		Increase (decrease) due to changes in			Increase (decrease) due to changes in
		Average volume	Average rate	Net change	Average volume	Average rate	Net change
		(EUR millions)			(EUR millions)
Other interest-bearing liabilities
	domestic	-96	-100	-196	55	-202	-147
	foreign	92	76	168	38	-25	13
Interest expense
	domestic	2,898	-3,758	-861	601	772	1,372
	foreign	0	-2,550	-2,550	1,094	3,052	4,147
Total		2,898	-6,309	-3,411	1,695	3,824	5,519
Other interest expense				-4,089			2,114
Total interest expense				-7,500			7,633

Net interest
	domestic	-2,523	2,624	101	-1,217	176	-1,041
	foreign	1,309	-1,769	-461	-228	1	228
Net interest		-1,214	855	-359	-1,445	176	-1,269
Other net interest result				28			396
Net interest result				-332			-873


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	216

The following table shows the interest spread and net interest margin for the past two years.



		2025	2024
		Average rate	Average rate
		%	%
Interest spread
	Domestic	0.8	0.8
	Foreign	1.9	2.0
Total		1.6	1.7
Net interest margin
	Domestic	0.0	-0.1
	Foreign	2.3	2.5
Total		1.6	1.7

Investments in debt securities

The following tables show the weighted average yield of ING’s investments on debt securities measured at

amortised cost and fair value through other comprehensive income. The weighted average yield is calculated as

follows:

Nominal value * coupon rate * remaining maturity

Nominal value * remaining maturity


Weighted average yield
2025	1 year or less	Between 1 and 5 years	Between 5 and 10 years	Over 10 years
Fair value through other comprehensive income
Government bonds	3.79%	4.16%	3.13%	3.37%
Central Bank bonds
Sub-sovereign, Supranationals and Agencies	3.39%	2.65%	2.95%	3.53%
Covered bonds	2.03%	2.51%	2.70%
Corporate bonds		1.84%	3.13%
Financial institutions bonds		2.87%	5.13%
ABS portfolio		2.46%	2.50%	2.71%

1Since substantially all investment securities held by the banking operations of the Company are taxable securities, the yields are on tax-equivalent basis.


Weighted average yield
2025	1 year or less	Between 1 and 5 years	Between 5 and 10 years	Over 10 years
Securities at amortised cost
Government bonds	2.37%	2.78%	3.09%	4.43%
Central Bank bonds	—%
Sub-sovereign, Supranationals and Agencies	2.64%	1.54%	2.81%	3.17%
Covered bonds	1.21%	1.60%	1.99%
Corporate bonds	2.25%	5.72%
Financial institutions bonds	0.53%
ABS portfolio		4.87%	3.19%	2.78%

1Since substantially all investment securities held by the banking operations of the Company are taxable securities, the yields are on tax-equivalent basis.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	217

Loan Portfolio

Loans and advances to banks and customers

Loans and advances to banks include all receivables from credit institutions, except for cash, current accounts and

deposits with other banks (including central banks). Loans and advances to customers includes lending facilities to

corporate and private customers encompass among others, loans, overdrafts and finance lease receivables.

Maturities and sensitivity of loans to changes in interest rates

The following table analyses loans and advances to banks and customers by time remaining until maturity as of

31 December 2025.



2025	1 year or less	1 year to 5 years	5 years through 15 years	After 15 years	Total
By domestic offices:
Loans to banks	11,311	874	177	0	12,362
Loans to public authorities	325	463	2,426	239	3,452
Residential mortgages	2,968	16,727	51,708	58,590	129,994
Other personal lending	905	2,335	1,166	627	5,033
Corporate Lending	24,238	33,602	10,350	602	68,792
Total domestic offices	39,747	54,001	65,828	60,057	219,633

By foreign offices:
Loans to banks	6,915	1,384	542	0	8,841
Loans to public authorities	7,047	4,551	6,802	1,183	19,583
Residential mortgages	15,886	59,817	111,120	58,280	245,103
Other personal lending	9,904	17,035	6,148	1,602	34,690
Corporate Lending	90,064	108,820	26,702	1,396	226,981
Total foreign offices	129,815	191,608	151,314	62,461	535,198
Total gross loans and advances to banks and customers	169,562	245,609	217,142	122,518	754,831

The following table analyzes loans and advances to banks and customers by interest rate sensitivity by maturity

as of 31 December 2025 for loans and advances due after one year.



2025	Predetermined interest rates	Floating or adjustable interest rates 1
Loans to banks	340	2,637
Loans to public authorities	11,329	4,334
Residential mortgages	247,567	108,676
Other personal lending	23,528	5,386
Corporate Lending	54,924	126,548
Total	337,688	247,581

1Loans that have an interest rate that remains fixed for more than one year and which can then be changed are classified as “adjustable interest rates”.

Allowance for credit losses

The following table presents the movements in allocation of the provision for loan losses on loans accounted for as

loans and advances to banks and customers for 2025, 2024 and 2023 under IFRS-IASB.


Movements in allocation of the provision for loan losses on loans
	2025	2024	2023
Balance on 1 January	6,049	5,839	6,101
Impact of changes in accounting policies			95
Write-offs	-937	-1,017	-1,111
Recoveries	58	69	71
Net write-offs	-879	-948	-1,039
Additions and other adjustments (included in value Adjustments to receivables of the Banking operations)	932	1,157	683
Balance on 31 December	6,101	6,049	5,839
Average loans and advances to banks and customers	739,101	690,544	671,424
Ratio of net charge‑offs to average loans and advances to banks and customers	0.12%	0.14%	0.15%
Ratio of allowance for credit losses to total loans and advances to banks and customers outstanding	0.81%	0.85%	0.88%

Additions to loan loss provisions have increased compared to 2024. Loan loss provisions are influenced by

developments in general macroeconomic conditions as well as certain individual exposures. Reference is made to

Note 1 ‘Basis of preparation and material accounting policy information’ and ‘Additional information – Risk

Management’ for detailed information on loan loss provisioning.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	218

Deposits

Reference is made to ‘Additional information – Average balances and interest rates’ for detailed information on

average amount of and the average rate paid on deposit categories.

For the years ended 31 December 2025, 2024 and 2023 the aggregate amount of deposits by foreign depositors in

domestic offices was EUR 36,625 million, EUR 38,419 million and EUR 37,360 million respectively.

Uninsured deposits

For the years ended 31 December 2025 and 2024 the amount of uninsured deposits, which were not covered by

DGS, was EUR 222,384 million and EUR 202,968 million, respectively.

Deposit guarantee schemes (DGS) reimburse a limited amount to compensate depositors whose bank has failed. A

fundamental principle underlying DGS is that they are funded entirely by banks, and that no taxpayer funds are

used. Under EU rules, the Deposit Guarantee Scheme (DGS) guarantees deposits up to a maximum of EUR 100,000

per depositor in case of a bank failure.

On 31 December 2025, the amount of time deposits in excess of (local) deposit insurance regime and time

deposits which are otherwise uninsured is as follows:



	Time deposits in excess on deposit insurance regime	Other uninsured Time deposits
	(EUR millions)	(EUR millions)
3 months or less	17,369	22,479
6 months or less but over 3 months	5,119	5,903
12 months or less but over 6 months	3,326	4,784
Over 12 months	332	3,798
Total	26,147	36,964

For further detailed information on deposits reference is made to Note 12 'Deposits from banks' and Note 13

'Customer deposits' of the consolidated financial statements.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-221

Report of Independent Registered Public Accounting Firm

To the Shareholders and the Supervisory Board of ING Groep N.V.

Opinion on the Consolidated Financial Statements

We have audited the accompanying consolidated statements of

financial position of ING Groep N.V. and subsidiaries (‘the Company’)

as of December 31, 2025 and 2024, the related consolidated

statements of profit or loss, comprehensive income, changes in equity,

and cash flows for each of the years in the three year period ended

December 31, 2025, and the related notes and specific disclosures

described in Note 1 as being part of the consolidated financial

statements (collectively, the consolidated financial statements).

In our opinion, the consolidated financial statements present fairly, in all

material respects, the financial position of the Company as of

December 31, 2025 and 2024, and the results of its operations and its

cash flows for each of the years in the three year period ended

December 31, 2025, in conformity with International Financial Reporting

Standards as issued by the International Accounting Standards Board.

We also have audited, in accordance with the standards of the Public

Company Accounting Oversight Board (United States) (PCAOB), the

Company’s internal control over financial reporting as of December 31,

2025, based on criteria established in Internal Control – Integrated

Framework (2013) issued by the Committee of Sponsoring

Organizations of the Treadway Commission, and our report dated

February 23, 2026 expressed an unqualified opinion on the

effectiveness of the Company’s internal control over financial reporting.

Basis for Opinion

These consolidated financial statements are the responsibility of the

Company’s management. Our responsibility is to express an opinion on

these consolidated financial statements based on our audits.

We are a public accounting firm registered with the PCAOB and are

required to be independent with respect to the Company in accordance

with the U.S. federal securities laws and the applicable rules and

regulations of the Securities and Exchange Commission and the

PCAOB.

We conducted our audits in accordance with the standards of the

PCAOB. Those standards require that we plan and perform the audit to

obtain reasonable assurance about whether the consolidated financial

statements are free of material misstatement, whether due to error or

fraud. Our audits included performing procedures to assess the risks of

material misstatement of the consolidated financial statements, whether

due to error or fraud, and performing procedures that respond to those

risks. Such procedures included examining, on a test basis, evidence

regarding the amounts and disclosures in the consolidated financial

statements. Our audits also included evaluating the accounting

principles used and significant estimates made by management, as well

as evaluating the overall presentation of the consolidated financial

statements. We believe that our audits provide a reasonable basis for

our opinion.

Critical Audit Matter

The critical audit matter communicated below is a matter arising from

the current period audit of the consolidated financial statements that

was communicated or required to be communicated to the audit

committee and that: (1) relates to accounts or disclosures that are

material to the consolidated financial statements and (2) involved our

especially challenging, subjective, or complex judgements. The

communication of a critical audit matter does not alter in any way our

opinion on the consolidated financial statements, taken as a whole, and

we are not, by communicating the critical audit matter below, providing

a separate opinion on the critical audit matter or on the accounts or

disclosures to which it relates.

Assessment of expected credit losses on loans and

advances to customers and loans and advances to

banks

As discussed in the Credit Risk section on pages 160 - 187 and in Note

3 and Note 7 in the consolidated financial statements, the loans and

advances to customers amount to EUR 728 billion and loans and

advances to banks amount to EUR 21 billion as at December 31, 2025.

These loans and advances are measured at amortised cost, less

expected credit losses (‘ECL’) of EUR 5.9 billion. For collectively

determined ECL, management uses models that estimate expected

credit losses using three components: probability of default (‘PD’), loss

given default (‘LGD’) and exposure at default (‘EAD’). Management also

applied forward looking economic scenarios with associated weights.

Relevant macroeconomic factors include the gross domestic product

(‘GDP’), house price index (‘HPI’) and unemployment rate. The recent

economic conditions are outside the bounds of historical experience

used to develop ECL model methodologies and result in greater

uncertainties to estimate ECLs. These uncertainties are considered by

management in their assessment of whether judgemental overlays to

model-based provisions need to be applied. For individually determined

provisions, management estimates ECL using the amount and timing of

future expected recovery scenarios and applying probability weights if

more than one recovery scenario is present.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-222

We identified the assessment of ECL on loans and advances to

customers and loans and advances to banks as a critical audit matter

because of the significant and complex auditor judgement and

specialized skills and knowledge required to evaluate the following

elements of the overall ECL estimate:

•The judgements used to develop the model-driven PD and LGD

parameters.

•The use of forward-looking macroeconomic forecasts in ECL,

including determining macroeconomic factors such as GDP, HPI and

unemployment rate.

•The consistent identification and application of criteria for significant

increase in credit risk (‘SICR’).

•The determination of management overlays to the modelled ECL

considering the volatility and uncertainty in the economic

environment combined with the delay in which the models capture

emerging risks.

•The determination of the amount and timing of expected future

recovery cash flows for individual loan provision assessments for

impaired loans and advances and the probability weights applied in

the presence of more than one recovery scenario.

The following are the primary procedures we performed to address this

critical audit matter.

•We evaluated the design and tested the operating effectiveness of

certain internal controls related to the estimation of ECL for loans

and advances to customers and loans and advances to banks. This

included controls relating to the selection of key assumptions

(including PD, LGD and macroeconomic forecasts), review and

authorization of model outputs, governance and monitoring of the

ECL process, determination of credit risk ratings, the estimation of

future recovery cash flows of individual loan loss provisions and

associated scenario weights assigned and the determination of

management overlays to the modelled ECL.

•We involved credit risk professionals with specialized skills and

knowledge who assisted in evaluating the assumptions used to

determine the PD and LGD parameters in models used by the

Company to determine the collective provisions, including the

evaluation of the recalibrated and redeveloped credit risk models.

This included reperforming back-testing of certain models to

evaluate the current model performance and evaluation of the

identification of SICR in loans and advances by challenging the

scope of management’s criteria used in staging assessments,

consistent application of the thresholds applied within each criterion,

and the ability of staging criteria to identify SICR prior to loans and

advances being credit impaired. In addition, the credit risk

professionals assisted in testing management overlays recorded.

•We involved economic professionals with specialized skills and

knowledge, who assisted in assessing the Company’s methodology

to determine the macroeconomic forecasts used in determining the

ECL. We tested the reasonableness of management’s forecasts

against other external benchmarks and our own internal forecasts.

•We involved valuation and credit risk professionals with specialized

skills and knowledge, who assisted in assessing the methodologies,

cash flows and collateral values used in expected future recovery

cash flow assessments of individual loan loss provisions for impaired

loans and advances and in challenging management’s use of

recovery scenarios and expected cash flows by comparing against

industry trends and comparable benchmarks and recalculating

recovery amounts.

/s/ KPMG Accountants N.V.

We have served as the Company’s auditor since 2016.

Utrecht, The Netherlands

February 23, 2026


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-223

Consolidated statement of financial position

As at 31 December



in EUR million	2025	2024		2025	2024
Assets			Liabilities
Cash and balances with central banks 2	52,889	70,353	Deposits from banks 12	18,517	16,723
Loans and advances to banks 3	21,204	21,770	Customer deposits 13	721,373	691,661
Financial assets at fair value through profit or loss 4,6			Financial liabilities at fair value through profit or loss 14
– Trading assets	55,730	72,897	– Trading liabilities	23,427	35,255
– Non-trading derivatives	1,657	2,463	– Non-trading derivatives	1,338	2,101
– Designated as at fair value through profit or loss	3,448	5,740	– Designated as at fair value through profit or loss	55,768	49,543
– Mandatorily at fair value through profit or loss	72,322	56,481	Current tax liabilities	411	276
Financial assets at fair value through other comprehensive income 5,6	56,662	46,389	Deferred tax liabilities 34	1,896	1,209
Securities at amortised cost 6	53,867	50,273	Provisions 15	941	774
Loans and advances to customers 7	727,733	683,611	Other liabilities 16	11,989	12,369
Investments in associates and joint ventures 8	1,607	1,679	Debt securities in issue 17	151,231	142,367
Property and equipment 9	2,478	2,434	Subordinated loans 18	18,100	17,878
Intangible assets 10	1,510	1,334	Total liabilities	1,004,990	970,158
Current tax assets	458	485
Deferred tax assets 34	788	1,001	Equity 19
Other assets 11	7,975	6,945	Share capital and share premium	17,147	17,148
			Other reserves	-3,080	-687
			Retained earnings	40,016	36,243
			Shareholders’ equity (parent)	54,083	52,703
			Non-controlling interests	1,255	995
			Total equity	55,339	53,698

Total assets	1,060,329	1,023,856	Total liabilities and equity	1,060,329	1,023,856

References relate to the accompanying notes. These are an integral part of the Consolidated financial statements.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-224

Consolidated statement of profit or loss

For the years ended 31 December



in EUR million	2025	2024	2023		2025	2024	2023

Interest income using effective interest rate method	43,760	49,474	44,658	Addition to loan loss provisions	1,304	1,194	520
Other interest income	7,568	9,685	7,741	Staff expenses 25	7,600	7,184	6,725
Total interest income	51,327	59,159	52,399	Other operating expenses 26	4,984	4,937	4,839
				Total expenses	13,887	13,315	12,084
Interest expense using effective interest rate method	-29,718	-34,878	-28,510
Other interest expense	-6,653	-8,993	-7,726	Result before tax	11,791	7,772	6,037
Total interest expense	-36,371	-43,871	-36,237
				Taxation 34	3,192	2,181	1,662
Net interest income 20	14,957	15,288	16,162	Net result	8,599	5,592	4,374

Fee and commission income	6,297	5,604	5,109	Net result attributable to:
Fee and commission expense	-1,696	-1,596	-1,514	Non-controlling interests	275	258	235
Net fee and commission income 21	4,602	4,008	3,595	Shareholders of the parent	8,324	5,334	4,140
					8,599	5,592	4,374
Valuation results and net trading income 22	5,789	1,614	-1,732
Investment income 23	129	13	95
Share of result from associates and joint ventures 8	209	205	149
Impairment of associates and joint ventures 8	-9	-35	-5	in EUR
Net result on derecognition of financial assets measured at amortised cost	0	-2	3	Earnings per ordinary share 28
Other net income 24	3	-3	-147	Basic earnings per ordinary share	2.78	1.65	1.16
Total income	25,678	21,087	18,121	Diluted earnings per ordinary share	2.78	1.65	1.16

References relate to the accompanying notes. These are an integral part of the Consolidated financial statements.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-225

Consolidated statement of comprehensive income

For the years ended 31 December



in EUR million	2025	2024	2023
Net result	8,599	5,592	4,374

Other comprehensive income
Items that will not be reclassified to the statement of profit or loss:
Unrealised revaluations property in own use	7	3	10
Remeasurement of the net defined benefit asset/liability	-4	-16	-85
Change in fair value of equity instruments at fair value through other comprehensive income	-364	664	-30
Changes in fair value related to changes in own credit risk for financial liabilities designated at fair value through profit or loss	-34	-46	-39

Items that may subsequently be reclassified to the statement of profit or loss:
Change in fair value of debt instruments at fair value through other comprehensive income	457	-258	67
Realised gains/losses on debt instruments at fair value through other comprehensive income reclassified to the statement of profit or loss	-21	63	9
Changes in cash flow hedge reserve	763	383	1,138
Exchange rate differences	-774	563	-85
Total other comprehensive income	30	1,357	985
Total comprehensive income	8,628	6,948	5,360

Total comprehensive income attributable to:
Non-controlling interests	456	303	444
Shareholders of the parent	8,173	6,645	4,916
	8,628	6,948	5,360

Each component of the other comprehensive income is presented after taxation. For the disclosure on the income tax effects on each component, reference is made to Note 34 'Taxation'.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-229

Consolidated statement of cash flows



in EUR million, for the years ended 31 December		2025	2024	2023
Cash flows from operating activities
Result before tax		11,791	7,772	6,037
Adjusted for:	– Depreciation and amortisation	665	673	674
	– Addition to loan loss provisions	1,304	1,194	520
	– Revaluations	1,070	1,012	1,806
	– Exchange rate differences and other	-703	869	260
Taxation paid		-2,366	-2,754	-2,700
Changes in:	– Loans and advances to banks, not available on demand	3,546	-7,736	12,693
	– Deposits from banks, not payable on demand	1,093	-7,818	-31,804
	– Trading assets	17,211	-12,663	-3,359
	– Trading liabilities	-11,829	-1,964	-1,869
	– Loans and advances to customers	-58,368	-34,401	-5,816
	– Customer deposits	36,212	41,090	8,513
	– Non–trading derivatives	1,486	-54	2,409
	– Assets designated at fair value through profit or loss	1,221	40	260
	– Assets mandatorily at fair value through profit or loss	-18,984	274	-7,402
	– Other assets	-914	263	1,727
	– Other financial liabilities at fair value through profit or loss	10,043	-7,800	4,391
	– Provisions and other liabilities	1,143	-542	2,320
Net cash flow from/(used in) operating activities		-6,380	-22,544	-11,340

Cash flows from investing activities
Investments and advances:	- Associates and joint ventures	-1	-26	-55
	- Financial assets at fair value through other comprehensive income	-43,294	-21,091	-19,995
	– Securities at amortised cost1	-152,945	-110,052	-49,614
	– Property and equipment	-351	-332	-246



		2025	2024	2023
	– Other investments	-421	-383	-310
Disposals and redemptions:	– Associates and joint ventures	225	107	164
	- Financial assets at fair value through other comprehensive income	33,095	16,949	11,913
	– Securities at amortised cost1	147,953	108,732	49,525
	– Property and equipment	39	50	57
	– Other investments	4	13	15
Net cash flow from/(used in) investing activities		-15,697	-6,033	-8,545

Cash flows from financing activities
Proceeds from debt securities1		150,409	124,701	116,436
Repayments of debt securities1		-135,220	-113,014	-90,574
Proceeds from issuance of subordinated loans		3,734	4,603	2,225
Repayments of subordinated loans		-2,808	-2,931	-2,894
Repayments of principal portion of lease liabilities		-282	-290	-291
Purchases of treasury shares		-3,705	-3,817	-3,531
Dividends and other cash distributions paid		-3,884	-3,879	-2,967
Net cash flow from/(used in) financing activities		8,245	5,374	18,404


Net cash flow		-13,832	-23,203	-1,481

Cash and cash equivalents at beginning of year		69,069	93,012	95,391
Effect of exchange rate changes on cash and cash equivalents		-1,089	-740	-898
Cash and cash equivalents at end of year		54,148	69,069	93,012

1 Cash flows are reported on a gross basis and include investments and borrowings of short term securities.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-230

Consolidated statement of cash flows - continued


Cash and cash equivalents
in EUR million	2025	2024	2023
Treasury bills and other eligible bills included in securities at AC	0	37	0
Deposits from banks	-7,065	-6,303	-5,132
Loans and advances to banks	8,324	4,982	7,931
Cash and balances with central banks	52,889	70,353	90,214
Cash and cash equivalents at end of year	54,148	69,069	93,012

Cash and cash equivalents includes only deposits from banks and loans and advances to banks that are payable

on demand.

Included in cash and cash equivalents are minimum mandatory reserve deposits held at various central banks.

Reference is made to Note 39 'Transfer of financial assets, assets pledged and received as collateral' for restrictions

on cash and balances with central banks.


Changes in liabilities arising from financing activities
	Debt securities in issue			Subordinated Loans			Lease liabilities
in EUR million	2025	2024	2023	2025	2024	2023	2025	2024	2023
Opening balance	142,367	124,670	95,918	17,878	15,401	15,786	1,116	1,162	1,174
Cash flows:
Additions	150,409	124,701	116,436	3,734	4,603	2,225
Redemptions / Disposals	-135,220	-113,014	-90,574	-2,808	-2,931	-2,894	-282	-290	-291
Non cash changes:
Amortisation	597	1,098	764	21	28	34	27	27	28
Other	-51	261	502	22	24	12	203	212	256
Changes in unrealised revaluations	45	1,139	2,680	287	188	473
Foreign exchange movement	-6,917	3,512	-1,057	-1,035	565	-235	-15	5	-4
Closing balance	151,231	142,367	124,670	18,100	17,878	15,401	1,050	1,116	1,162

Part of Debt securities in issue and subordinated loans are subject to fair value hedge accounting. Hence, changes

in unrealised revaluations represent fair value adjustments to the hedged item attributable to the hedged interest

rate risk. Reference is made to the paragraph 'fair value hedge accounting' in Note 36 'Derivatives and hedge

accounting'.

The table below presents the interest and dividend received and paid.



in EUR million	2025	2024	2023
Interest received	51,600	57,200	51,029
Interest paid	-37,666	-41,191	-33,734
	13,935	16,009	17,295

Dividend received	319	235	205
Dividends and other cash distributions paid	-3,884	-3,879	-2,967

Dividends received from associates and joint ventures are included in investing activities; interest received, interest

paid and other dividends received are included in operating activities; and dividend paid is included in financing

activities in the Consolidated statement of cash flows.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-231

Notes to the Consolidated financial statements

1 Basis of preparation and material accounting policy information

1.1 Reporting entity and authorisation of the Consolidated financial statements

ING Groep N.V. (Naamloze Vennootschap) is a company domiciled in Amsterdam, the Netherlands. Commercial

31 December 2025, comprise ING Groep N.V. (the Parent company) and its subsidiaries, together referred to as

ING Group. ING Group is a global financial institution with a strong European base, offering a wide range of retail

and wholesale banking services to customers.

The ING Group Consolidated financial statements, as at and for the year ended 31 December 2025, were

authorised for issue in accordance with a resolution of the Executive Board on 23 February 2026. The Executive

Board has the power to amend the financial statements as long as these are not adopted by the General Meeting

of Shareholders. The General Meeting of Shareholders may decide not to adopt the financial statements, but may

not amend these.

1.2 Basis of preparation of the Consolidated financial statements

The ING Group Consolidated financial statements have been prepared in accordance with International Financial

Reporting Standards as issued by the International Accounting Standards Board for purposes of reporting with the

U.S. Securities and Exchange Commission (SEC), including financial information contained in this Annual report on

Form 20-F. The term ‘IFRS-IASB’ is used to refer to IFRS Accounting Standards as issued by the International

Accounting Standards Board, including the decisions ING Group made with regard to the options available under

IFRS-IASB.

The ING Group Consolidated financial statements have been prepared on a going concern basis and there are no

significant doubts about the ability of ING Group to continue as a going concern.

The Consolidated financial statements are presented in euros and rounded to the nearest million, unless stated

otherwise. Amounts may not add up due to rounding.

1.2.1 Presentation of Risk management disclosures

To improve transparency, reduce duplication, and present related information in one place, certain disclosures on

the nature and extent of risks related to financial instruments required by IFRS 7 ‘Financial instruments:

Disclosures’ are included in the ‘Risk management’ section of the Annual Report.

These disclosures are an integral part of ING Group Consolidated financial statements and are indicated in the ‘Risk

management’ section by the symbol (*). Chapters, paragraphs, graphs or tables within the 'Risk management'

section that are indicated with this symbol in the respective headings or table header are considered to be an

integral part of the Consolidated financial statements.

1.2.2 Reconciliation between IFRS-EU and IFRS-IASB

The published 2025 Consolidated financial statements of ING Group are prepared in accordance with IFRS-EU. IFRS-

EU refers to International Financial Reporting Standards (‘IFRS’) as adopted by the European Union (EU), including

the decisions ING Group made with regard to the options available under IFRS as adopted by the EU. IFRS-EU differs

from IFRS-IASB in respect of certain paragraphs in IAS 39 ‘Financial Instruments: Recognition and Measurement’

regarding hedge accounting for portfolio hedges of interest rate risk.

Under IFRS-EU, ING Group applies fair value hedge accounting for portfolio hedges of interest rate risk (fair value

macro hedges) in accordance with the EU carve-out version of IAS 39. Particularly, it is applied to portfolio-based

hedging strategies for retail lending (mortgages) and core deposits. Under the EU IAS 39 carve-out, hedge

accounting may be applied, in respect of fair value macro hedges, to core deposits. In addition, and in general to

any hedge accounting relationship under the EU IAS 39 carve-out, the hedge effectiveness requirements are less

strict than under IFRS-IASB and hedge ineffectiveness is only recognised when the revised estimate of the amount

of cash flows in scheduled time buckets falls below the original designated amount of that bucket and is not

recognised when the revised amount of cash flows in scheduled time buckets is more than the original designated

amount. Under IFRS-IASB, hedge accounting for fair value macro hedges cannot be applied to core deposits and

ineffectiveness arises whenever the revised estimate of the amount of cash flows in scheduled time buckets is

either more or less than the original designated amount of that bucket.

This information under IFRS-IASB is prepared by reversing the hedge accounting impacts that are applied under

the EU ‘carve-out’ version of IAS 39. Financial information under IFRS-IASB accordingly does not take into account


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-232

the possibility that had ING Group applied IFRS-IASB as its primary accounting framework it might have applied

alternative hedge strategies where those alternative hedge strategies could have qualified for IFRS-IASB compliant

hedge accounting. These decisions could have resulted in different shareholders’ equity and net result amounts

compared to those indicated in this Annual Report on Form 20-F.

In 2025 forward interest rates Increased resulting in a positive EU IAS 39 carve out adjustment after tax of EUR

1,996 million (2024: EUR 1,058 million negative; 2023: EUR 3,147 million negative). The impact of the adjustment is

mainly reflected in line item 'Valuation results and net trading income' in the statement of profit or loss. A

reconciliation between IFRS-EU and IFRS-IASB is included below.

Both IFRS-EU and IFRS-IASB differ in several areas from accounting principles generally accepted in the United

States of America (US GAAP).


Reconciliation net result under IFRS-EU and IFRS-IASB
in EUR million	2025	2024	2023
In accordance with IFRS-EU (attributable to the shareholders of the parent)	6,327	6,392	7,287
Adjustment of the EU IAS 39 carve-out	2,643	-1,528	-4,455
Tax effect of the adjustment	-647	470	1,308
Effect of adjustment after tax	1,996	-1,058	-3,147
In accordance with IFRS-IASB (attributable to the shareholders of the parent)	8,324	5,334	4,140


Reconciliation shareholders’ equity under IFRS-EU and IFRS-IASB
in EUR million	2025	2024	2023
In accordance with IFRS-EU (attributable to the shareholders of the parent)	49,698	50,314	51,240
Adjustment of the EU IAS 39 carve-out	6,022	3,378	4,902
Tax effect of the adjustment	-1,636	-989	-1,457
Effect of adjustment after tax	4,386	2,389	3,444
In accordance with IFRS-IASB Shareholders’ equity	54,083	52,703	54,684

1.3 Changes to accounting policies and presentation

ING Group has consistently applied its accounting policies to all periods presented in these Consolidated financial

statements.

During 2025, ING Group has revised the presentation in Note 26 'Other operating expenses', to enhance its

relevance and improve comparability. Consequently, comparative figures for 2024 and 2023 have been updated

accordingly.

1.3.1 Changes in IFRS effective in 2025

The following amendments to IFRS became effective in the current reporting period with no significant impact for

ING Group:

§Amendments to IAS 21 'The Effects of Changes in Foreign Exchange Rates': Lack of Exchangeability (issued in

August 2023). Amendments provide guidance on determining exchange rates when a currency lacks

exchangeability, including estimation methods and disclosure requirements.

1.3.2 Upcoming changes in IFRS after 2025

ING Group has not early adopted any of the following Standards, interpretations or amendments that have been

issued but are not yet effective:

Effective in 2026:

§Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosures': Classification and

Measurement of Financial Instruments (issued in May 2024). The amendments clarify that a financial liability is

derecognised on the ‘settlement date’ and introduce an accounting policy choice to derecognise financial

liabilities settled using an electronic payment system before the settlement date. Other clarifications relate to

the classification of financial assets with ESG linked features, non-recourse loans and contractually linked

instruments. Further, additional disclosure requirements introduced for equity investments at fair value

through other comprehensive income (FVOCI) and financial instruments with contingent cash flow features.

§Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosures': Contracts

Referencing Nature-dependent Electricity (issued in December 2024). Amendments clarify accounting for

renewable electricity contracts, including own-use and hedge accounting and related disclosures.

§Annual Improvements to IFRS Accounting Standards: Volume 11 (issued in July 2024). Amendments include

minor clarifications and corrections across a number of Standards to improve consistency and clarity.

The implementation of the above amendments is expected to have no significant impact on ING Group's

Consolidated financial statements as they become effective.

Effective in 2027:

§Amendments to IAS 21 'The Effects of Changes in Foreign Exchange Rates': Translation to a hyperinflationary

presentation currency (issued in November 2025). Amendments clarify accounting when translating from a

non-hyperinflationary functional currency to a hyperinflationary presentation currency. There is no impact

expected on ING Group's financial statements.

§New Standard IFRS 18 'Presentation and Disclosure in Financial Statements' (issued in April 2024). IFRS 18

replaces IAS 1 'Presentation of Financial Statements', carrying forward many of the requirements in IAS 1

unchanged and complementing them with new requirements. In addition, some paragraphs from IAS 1 have

been moved to IAS 8 'Accounting Policies, Changes in Accounting Estimates and Errors' and IFRS 7.

Furthermore, the IASB has made minor amendments to IAS 7 'Statement of Cashflows' and IAS 33 'Earnings per

Share'. IFRS 18 introduces new requirements to:


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-233

–present specified categories (operating, investing, financing, income tax and discontinued operations) and

defined subtotals in the statement of profit or loss;

–provide disclosures on management-defined performance measures (MPMs) in the notes to the financial

statements; and

–improve aggregation and disaggregation.

The implementation of IFRS 18 is expected to have no significant impact on ING Group's consolidated financial

statements as it only affects the presentation and disclosure of items in the financial statements and does not

change the underlying recognition or measurement of assets, liabilities, income or expenses.

ING Group is currently assessing the impact the amendments will have on the Consolidated financial statements.

To date, the following potential impacts have been identified:

§IFRS 18 will not affect ING's net profit, but will reclassify income and expenses into new categories in the

statement of profit or loss and introduce a new subtotal line item 'operating profit'.

§The line items presented in the primary financial statements might change as a result of the enhanced

principles introduced on 'aggregation and disaggregation'. ING does not expect there to be a significant change

in the information that is currently disclosed in the notes because the requirements to disclose material

information remain unchanged.

§New disclosure requirements for management-defined performance measures (MPMs).

§For the statement of cash flows, the starting point for calculating cash flows from operating activities will

change to 'operating profit' as noted above.

In addition, in May 2024, the IASB also issued a new accounting Standard IFRS 19 'Subsidiaries without Public

Accountability: Disclosures'. However, it is not applicable for the consolidated financial statements of ING Group.

1.4 Significant judgements and critical accounting estimates and assumptions

The preparation of the Consolidated financial statements requires management to make judgements in the

process of applying its accounting policies and to use estimates and assumptions. The estimates and assumptions

affect the reported amounts of the assets and liabilities and the amounts of the contingent assets and contingent

liabilities at the balance sheet date, as well as reported income and expenses for the year. The actual outcome

may differ from these estimates. The process of setting assumptions is subject to internal control procedures and

approvals.

ING Group has identified areas that require management to make significant judgements and use critical

accounting estimates and assumptions based on the information and financial data that may or may not change

in future periods.

These areas are:

§Loan loss provisions (financial assets) (refer to Note 1.5.6 ‘Impairment of financial assets');

§The determination of the fair values of financial assets and liabilities (refer to Note 1.5.3 for ‘Fair values of

financial assets and liabilities’);

§Investment in associate - assessment of additional impairment losses or reversal of previous impairment losses

(refer to Note 1.10 ‘Investment in associates and joint ventures');

§Investment in associate - determination of significant influence over associates (refer to Note 1.10 'Investment

in associates and joint ventures'); and

§Provisions (refer to Note 1.15 ‘Provisions, contingent liabilities and contingent assets’).

In addition, in January 2025 ING has reached an agreement on the sale of the business in Russia (ING Bank

(Eurasia) JSC), subject to several conditions, including substantive and uncertain regulatory approvals. Judgement

is required to evaluate the probability of the sale. Given the prevailing uncertainties around substantive regulatory

approvals as at 31 December 2025, no loss was recognised for the year ended 31 December 2025 and assets and

liabilities of the disposal group were not classified as held for sale. Reference is made to Note 32 'Potential sale of

ING Bank (Eurasia) JSC'.

In March 2024 ING repaid the final EUR 6 billion of its Targeted Longer-Term Refinancing Operations (TLTRO) III

participation. As a result, accounting for TLTRO is no longer an area of significant judgement in 2025 and 2024,

while it was as such in 2023.

1.5 Financial instruments

ING Group applies IFRS 9 ‘Financial Instruments’ to the recognition, classification and measurement, and

derecognition of financial assets and financial liabilities and the impairment of financial assets. ING Group applies

the requirements of IAS 39 ‘Financial Instruments: Recognition and Measurement’ for hedge accounting purposes.

1.5.1 Recognition and derecognition of financial instruments

Recognition of financial assets

Financial assets are recognised in the balance sheet when ING Group becomes a party to the contractual

provisions of the instrument. For a regular way purchase or sale of a financial asset, trade date and settlement

date accounting is applied, depending on the classification of the financial asset.

Derecognition of financial assets

Financial assets are derecognised when the rights to receive cash flows from the financial assets have expired or

where ING Group has transferred the rights to receive the cash flows from the financial asset or assumed an

obligation to pass on the cash flows and has transferred substantially all the risks and rewards of the asset. If ING

Group neither transfers nor retains substantially all the risks and rewards of ownership of a financial asset, it

derecognises the financial asset if it no longer has control over the asset. The difference between the carrying

amount of a financial asset that has been derecognised and the consideration received is recognised in profit or

loss.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-234

Recognition of financial liabilities

Financial liabilities are recognised on the date that the entity becomes a party to the contractual provisions of the

instrument.

Derecognition of financial liabilities

Financial liabilities are derecognised when the obligation specified in the contract is discharged, cancelled or

expired. The difference between the carrying amount of a financial liability that has been extinguished and the

consideration paid is recognised in profit or loss.

1.5.2 Classification and measurement of financial instruments

Financial assets

ING Group classifies its financial assets in the following measurement categories:

§those to be measured subsequently at fair value (either through OCI, or through profit or loss); and

§those to be measured at amortised cost (AC).

At initial recognition, ING Group measures a financial asset at its fair value plus, in the case of a financial asset not

at FVPL, transaction costs that are directly attributable to the acquisition of the financial asset. Transaction costs

of financial assets carried at fair value through profit or loss (FVPL) are expensed in the statement of profit or loss.

Financial assets – Debt instruments

The classification depends on the entity’s business model for managing the financial assets and the contractual

terms of the cash flows at initial recognition.

Business models

Business models are classified as Hold to Collect (HtC), Hold to Collect and Sell (HtC&S) or Other depending on how

a portfolio of financial instruments as a whole is managed. ING Group’s business models are based on the existing

management structure of the bank, and refined based on an analysis of how businesses are evaluated and

reported, how their specific business risks are managed, and on historic and expected future sales. Sales are

permissible in a HtC business model when these are due to an increase in credit risk, take place close to the

maturity date (where the proceeds from the sales approximate the collection of the remaining contractual cash

flows), are insignificant in value (both individually and in aggregate) or are infrequent.

Contractual cash flows Solely Payments of Principal and Interest (SPPI)

The contractual cash flows of a financial asset are assessed to determine whether they represent SPPI. Interest

includes consideration for the time value of money, credit risk and for other basic lending risks such as

consideration for liquidity risk and costs associated with holding the financial asset for a particular period of time.

In addition, interest can include a profit margin that is consistent with a basic lending arrangement. Financial

assets with embedded derivatives are considered in their entirety when determining whether their cash flows are

SPPI.

In assessing whether the contractual cash flows are SPPI, ING Group considers the contractual terms of the

instrument. This includes assessing whether the financial asset contains a contractual term that could change the

timing or amount of contractual cash flows such that it would not meet this condition.

Based on the entity’s business model for managing the financial assets and the contractual terms of the cash

flows, there are three measurement categories into which ING Group classifies its debt instruments:

§Amortised Cost (AC):

Debt instruments that are held for collection of contractual cash flows under a HtC business model where those

cash flows represent SPPI are measured at AC. Interest income from these financial assets is included in

Interest income using the Effective Interest Rate (EIR) method. Any gain or loss arising on derecognition is

recognised directly in profit or loss. Impairment losses are presented as a separate line item in the statement of

profit or loss.

§FVOCI:

Debt instruments that are held for collection of contractual cash flows and for selling the financial assets under

a HtC&S business model, where the assets’ cash flows represent SPPI, are measured at FVOCI. Movements in

the carrying amount are recognised in OCI, except for the recognition of impairment gains or losses, interest

revenue and foreign exchange gains and losses which are recognised in profit or loss. When the financial asset

is derecognised, the cumulative gain or loss previously recognised in OCI is reclassified from equity to profit or

loss and presented in Investment income or Other net income, based on the specific characteristics of the

business model. Interest income from these financial assets is included in Interest income using the EIR

method. Impairment losses are presented as a separate line item in the statement of profit or loss.

§FVPL:

Debt instruments that do not meet the criteria for AC or FVOCI are measured at FVPL. This includes debt

instruments that are held-for-trading (presented separately as Trading assets) and all other debt instruments

that do not meet the criteria for AC or FVOCI (presented separately as Mandatorily at FVPL). ING Group may in

some cases, on initial recognition, irrevocably designate a financial asset as classified and measured at FVPL.

This is the case where doing so eliminates or significantly reduces an accounting mismatch that would

otherwise arise on assets measured at AC or FVOCI. Fair value movements on trading securities, trading loans

and deposits (mainly reverse repos) are presented fully within valuation result and net trading income. This

also includes interest. The interest arising on financial assets designated as at FVPL is recognised in profit or

loss and presented within Other interest income or Other interest expense in the period in which it arises. The

interest arising on a debt instrument that is part of a hedge relationship, but not subject to hedge accounting,

is recognised in profit or loss and presented within Other interest income or Other interest expense in the

period in which it arises.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-235

ING Group reclassifies debt instruments if, and only if, its business model for managing those financial assets

changes. Such changes in business models are expected to be very infrequent. There have been no

reclassifications during the reporting period.

Financial assets – Equity instruments

All equity investments are measured at fair value. ING Group applies the fair value through OCI option to

investments which are considered strategic, consisting of investments that add value to ING Group’s core banking

activities.

There is no subsequent recycling of fair value gains and losses to profit or loss following the derecognition of

investments if elected to be classified and measured as FVOCI. However, the cumulative gain or loss is transferred

within equity to retained earnings on derecognition of such equity instruments. Dividends from such investments

continue to be recognised in profit or loss as investment income when ING Group’s right to receive payments is

established. Impairment requirements are not applicable to equity investments classified and measured as FVOCI.

Other remaining equity investments are measured at FVPL. All changes in the fair value are recognised in

Valuation result and Net trading income in the Consolidated statement of profit or loss.

Financial liabilities

Financial liabilities are classified and subsequently measured at AC, except for financial guarantee contracts,

derivatives and liabilities designated at FVPL. Financial liabilities classified and measured at FVPL are presented as

follows:

§The amount of change in the fair value that is attributable to changes in own credit risk of the liability

designated at FVPL is presented in OCI. Upon derecognition this Debit Valuation Adjustment (DVA) impact does

not recycle from OCI to profit or loss; and

§The remaining amount of change in the fair value is presented in profit or loss in ‘Valuation results and net

trading income’. Interest on financial liabilities at FVPL is also recognised in the valuation result, except for

items voluntarily designated as FVPL, for which interest is presented within ‘Other interest income (expense)'.

A financial guarantee contract is a contract that requires ING Group to make specified payments to reimburse the

holder for a loss it incurs because a specified debtor fails to make payment when due in accordance with the

original or modified terms of a debt instrument. Such a contract is initially recognised at fair value and is

subsequently measured at the higher of (a) the amount determined in accordance with impairment provisions of

IFRS 9 ‘Financial instruments’ (see section 'Impairment of financial assets') and (b) the amount initially recognised

less, when appropriate, cumulative amortisation recognised in accordance with the revenue recognition principle

of IFRS 15 ‘Revenue from contracts with customers’.

Repurchase transactions and reverse repurchase transactions

Securities sold subject to repurchase agreements (repos), securities lending and similar agreements continue to be

recognised in the Consolidated statement of financial position as ING Group continues to be exposed to

substantially all risks and rewards of the transferred financial asset. The counterparty liability is designated and

measured at FVPL if the asset is measured mandatorily at FVPL. Otherwise, the counterparty liability is included in

Deposits from banks, Customer deposits, or Trading.

Securities purchased under agreements to resell (reverse repos), securities borrowings and similar agreements are

not recognised in the Consolidated statement of financial position as the counterparty continues to be exposed to

substantially all risks and rewards of the transferred security. Based on the business model assessment and

counterparty, the consideration paid to purchase securities is recognised as Loans and advances to customers,

Loans and advances to banks, financial assets mandatorily at FVPL or Trading assets.

1.5.3 Fair values of financial assets and liabilities

All financial assets and liabilities are recognised initially at fair value. The fair value of a financial instrument on

initial recognition is generally its transaction price (that is, the fair value of the consideration given or received).

However, if there is a material difference between the transaction price and the fair value of financial instruments

whose fair value is based on a valuation technique using significant unobservable inputs, the entire 'day one'

difference (a ‘Day One Profit or Loss’) is deferred. ING Group defers the Day One Profit or Loss relating to financial

instruments classified as Level 3 and financial instruments with material unobservable inputs into CVA which are

not necessarily classified as Level 3. The deferred Day One Profit or Loss is recognised in the statement of profit or

loss over the life of the transaction until the transaction matures, or until the significant unobservable inputs

become observable, or until the significant unobservable inputs become non-significant. In all other cases, ING

Group recognises the difference as a gain or loss at inception.

Subsequently, except for financial assets and financial liabilities measured at amortised cost, all the other financial

assets and liabilities are measured at fair value.

Fair value is defined as the price that would be received to sell an asset or paid to transfer a liability in an orderly

transaction between market participants at the measurement date. It assumes that market participants would

use and take into account the characteristics of the asset or liability when pricing the asset or liability. Fair values

of financial assets and liabilities are based on unadjusted quoted market prices where available. Such quoted

market prices are primarily obtained from exchange prices for listed financial instruments. Where an exchange

price is not available, quoted prices in an active market may be obtained from independent market vendors,

brokers, or market makers. In general, positions are valued at the bid price for a long position and at the offer price

for a short position or are valued at the price within the bid-offer spread that is most representative of fair value in

the circumstances. In some cases where positions are marked at mid-market prices, a fair value adjustment is

calculated.


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For certain financial assets and liabilities, quoted market prices are not available. For such instruments, fair value is

determined using valuation techniques. These range from discounting of cash flows to various valuation models,

where relevant pricing factors including the market price of underlying reference instruments, market parameters

(volatilities, correlations and credit ratings), and customer behaviour are taken into account. ING Group maximises

the use of market observable inputs and minimises the use of unobservable inputs in determining the fair value. It

can be subjective dependent on the significance of the unobservable input to the overall valuation. All valuation

techniques used are subject to internal review and approval. Most data used in these valuation techniques are

validated on a daily basis when possible.

When a group of financial assets and liabilities are managed on the basis of their net risk exposures, the fair value

of a group of financial assets and liabilities are measured on a net portfolio level.

To include credit risk in fair value, ING Group applies both Credit and Debit Valuation Adjustments (CVA, DVA, also

known as Bilateral Valuation Adjustments or BVA). Own issued debt and structured notes that are designated at

FVPL are adjusted for ING Group’s own credit risk by means of a DVA. To include the funding risk, ING Group applies

an additional ‘Funding Valuation Adjustment’ (FVA) to the uncollateralised derivatives based on the market price of

funding liquidity. ING Group also applies to certain positions other valuation adjustments to arrive at the fair value,

such as Bid-Offer adjustments, Model Risk Adjustments and Collateral Valuation Adjustments (CollVA).



	Significant judgements and critical accounting estimates and assumptions: §Even if market prices are available, when markets are less liquid there may be a range of prices for the same security from different price sources. Selecting the most appropriate price requires judgement and could result in different estimates of fair value. §Valuation techniques are subjective in nature and significant judgement is involved in establishing fair values for certain financial assets and liabilities. Valuation techniques involve various assumptions regarding pricing factors. The use of different valuation techniques and assumptions could produce significantly different estimates of fair value. §Price testing is performed to assess whether the process of valuation has led to an appropriate fair value of the position and to minimise the potential risks of economic losses due to incorrect or misused models. §Assessing whether a market is active, and whether an input is observable and significant, requires judgement. ING Group categorises its financial instruments that are either measured in the statement of financial position at fair value or of which the fair value is disclosed, into a three-level hierarchy based on the observability and significance of the valuation inputs. The use of different approaches to assess whether a market is active, whether an input is observable, and whether an unobservable input is significant could produce different classification within the fair value hierarchy as well as potentially different deferral of the Day One Profit or Loss. §Reference is made to Note 35 'Fair value of assets and liabilities' and to the ‘Market risk’ paragraph in the ‘Risk management’ section of the Annual Report for the basis of the determination of the fair value of financial instruments and related sensitivities.

1.5.4 Derivatives and hedge accounting

IFRS 9 includes an accounting policy choice to defer the adoption of IFRS 9 hedge accounting and to continue with

hedge accounting under IAS 39. ING Group decided to exercise this accounting policy choice and did not adopt IFRS

9 hedge accounting as of 1 January 2018.

Derivatives are initially recognised at fair value on the date on which a derivative contract is entered into and are

subsequently measured at fair value. Fair values are obtained from quoted market prices in active markets,

including market transactions and valuation techniques (such as discounted cash flow models and option pricing

models), as appropriate. All derivatives are carried as assets when their fair value is positive and as liabilities when

their fair value is negative. Fair value movements on derivatives are presented in profit or loss in 'Valuation result

and net trading income', except for derivatives in either a formal hedge relationship or so-called economic hedges

that are not in a formal hedge accounting relationship where a component is presented separately in interest

result in line with ING Group’s risk management strategy.


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Embedded derivatives are separated from financial liabilities and other non-financial contracts and accounted for

as a derivative if, and only if:

1.The economic characteristics and risks of the embedded derivative are not closely related to the economic

characteristics and risks of the host contract;

2.A separate instrument with the same terms as the embedded derivative would meet the definition of a

derivative; and

3.The combined instrument is not measured at fair value with changes in fair value reported in profit or loss.

If an embedded derivative is separated, the host contract is accounted for as a similar free-standing contract.

The method of recognising the resulting fair value gain or loss depends on whether the derivative is designated as

a hedging instrument, and if so, the nature of the item being hedged. ING Group designates certain derivatives as

hedges of the fair value of recognised assets or liabilities or firm commitments (fair value hedge), hedges of highly

probable future cash flows attributable to a recognised asset or liability or a forecast transaction (cash flow

hedge), or hedges of a net investment in a foreign operation. Hedge accounting is used for derivatives designated

in this way provided certain criteria are met.

At the inception of the transaction, ING Group documents the relationship between hedging instruments and

hedged items, its risk management objective, together with the methods selected to assess hedge effectiveness.

ING Group also documents its assessment, both at hedge inception and on an ongoing basis, of whether the

derivatives that are used in hedging transactions are highly effective in offsetting changes in fair values or cash

flows of the hedged items.

Fair value hedges

Changes in the fair value of derivatives that are designated and qualify as fair value hedges are recognised in the

statement of profit or loss, together with fair value adjustments to the hedged item attributable to the hedged

risk. If the hedge relationship no longer meets the criteria for hedge accounting, the cumulative adjustment of the

hedged item is, in the case of interest-bearing instruments, amortised through the statement of profit or loss over

the remaining term of the original hedge or recognised directly when the hedged item is derecognised. For non-

interest bearing instruments, the cumulative adjustment of the hedged item is recognised in the statement of

profit or loss only when the hedged item is derecognised.

Cash flow hedges

The effective portion of changes in the fair value of derivatives that are designated and qualify as cash flow hedges

are recognised in the Other Comprehensive Income. The gain or loss relating to the ineffective portion is

recognised immediately in the statement of profit or loss. Amounts accumulated in the Other Comprehensive

Income are recycled to the statement of profit or loss in the periods in which the hedged item affects net result.

When a hedging instrument expires or is sold, or when a hedge no longer meets the criteria for hedge accounting,

any cumulative gain or loss existing in the Other Comprehensive Income at that time remains in the Other

Comprehensive Income and is recognised when the forecast transaction is ultimately recognised in the statement

of profit or loss. When a forecast transaction is no longer expected to occur, the cumulative gain or loss that was

reported in the Other Comprehensive Income is transferred immediately to the statement of profit or loss.

Net investment hedges

Hedges of net investments in foreign operations are accounted for in a similar way to cash flow hedges. Any gain

or loss on the hedging instrument relating to the effective portion of the hedge is recognised in the Other

Comprehensive Income and the gain or loss relating to the ineffective portion is recognised immediately in the

statement of profit or loss. Gains and losses accumulated in the Other Comprehensive Income are included in the

statement of profit or loss when the foreign operation is disposed.

Benchmark rate reform – specific policies for hedges directly affected by the benchmark rate reform

As explained in the ‘Impact of the benchmark rate reform’ paragraph of the ‘Risk management’ section, a

fundamental review of important interest rate benchmarks has been carried out, and is still ongoing for some of

them (for instance, WIBOR). Interest Rate Benchmark Reform Phase 1 and Phase 2 amendments to IFRS provide

specific reliefs that allow hedge accounting relationships to continue when the benchmark rate reform is ongoing.

Phase 1 reliefs remained relevant for ING Group as at 31 December 2025 for WIBOR hedges, and will cease to apply

once uncertainty about the timing and amount of the benchmark rate-based cash flows is resolved, or when the

hedging instrument is discontinued. ING Group’s policy is to cease applying Phase 1 reliefs when the relevant

contract (hedging instrument or hedged item) is modified. When this occurs, Phase 2 reliefs become applicable still

allowing hedge accounting relationships to continue. Refer to note ‘Risk management/Impact of the benchmark

rate reform’ for further details on WIBOR transition and ING’s exposures related to WIBOR that have yet to

transition.

Non-trading derivatives that do not qualify for hedge accounting

Derivative instruments that are used by ING Group as part of its risk management strategies, but which do not

qualify for hedge accounting under ING Group’s accounting policies, are presented as non-trading derivatives. Non-

trading derivatives are measured at fair value with changes in the fair value taken to the statement of profit or

loss.


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1.5.5 Offsetting of financial assets and financial liabilities

Financial assets and financial liabilities are offset, and the net amount is reported in the statement of financial

position, when ING Group has a current legally enforceable right to set off the recognised amounts and intends to

either settle on a net basis or to realise the asset and settle the liability simultaneously. Offsetting is applied to

derivatives, repurchase and reverse repurchase agreements and cash pooling agreements. A significant portion of

offsetting is applied to derivatives and related cash margin balances, which are either directly cleared through

central clearing parties or cleared through clearing members of central clearing parties. For more information,

reference is made to Note 40 ‘Offsetting financial assets and liabilities’.

1.5.6 Impairment of financial assets

An Expected Credit Loss (ECL) model is applied to financial assets accounted for at AC or FVOCI such as loans, debt

securities and lease receivables, as well as off-balance sheet items such as undrawn loan commitments, certain

financial guarantees issued, and undrawn committed revolving credit facilities. Under the ECL model, ING Group

calculates the ECL by considering on a discounted basis the cash shortfall it would incur in case of a default and

multiplying the shortfall by the probability of a default occurring. The ECL is the sum of the probability-weighted

outcomes. The ECL estimates are unbiased and include reasonable and supportable information about past

events, current conditions, and forecasts of future economic conditions. ECL is recognised on the balance sheet as

loan loss provisions (LLP).

Three-stage approach

Financial assets are classified in one of the below three stages at each reporting date. A financial asset can move

between stages during its lifetime. The stages are based on changes in credit quality since initial recognition and

defined as follows:

§Stage 1

Financial assets that have not had a significant increase in credit risk since initial recognition (i.e. no Stage 2 or

3 triggers apply). Assets are classified as Stage 1 upon initial recognition (with the exception of purchased or

originated credit impaired (POCI) assets) and ECL is determined by the probability that a default occurs in the

next 12 months (12 months ECL);

§Stage 2

Financial assets showing a significant increase in credit risk since initial recognition. For assets in Stage 2 , ECL

reflects an estimate on the credit losses over the remaining maturity of the asset (lifetime ECL); or

§Stage 3

Financial assets that are credit-impaired. Also for these assets, ECL is determined over the remaining maturity

of the asset.

Significant increase in credit risk

ING Group established a framework, incorporating quantitative and qualitative indicators, to identify and assess

significant increases in credit risk (SICR). This is used to determine the appropriate ECL Stage for each financial

asset. Reference is made to the ‘Criteria for identifying a significant increase in credit risk (SICR)’ in the ‘Risk

management’ section of the Annual Report.

An asset that is in Stage 2 will move back to Stage 1 when none of the above criteria are in place anymore.

However, if the asset was moved to Stage 2 based on the forbearance status, then the asset stays in Stage 2 for at

least 24 months. If the asset was classified as Stage 2 due to the '30 days past due' trigger, then the asset is

moved back to Stage 1 only after three months from when the trigger no longer applies.

Credit-impaired financial assets (Stage 3)

Financial assets are assessed for credit-impairment at each reporting date and more frequently when

circumstances warrant further assessment. Evidence of credit-impairment includes arrears of over 90 days on any

material credit obligation, indications that the borrower is experiencing significant financial difficulty, a breach of

contract, bankruptcy or distressed restructuring. The definition of 'credit-impaired' under IFRS 9 (Stage 3) is aligned

with the definition of 'default' used by ING Group for internal risk management purposes, which is also the

definition used for regulatory purposes.

An asset (other than a POCI asset) that is in Stage 3 will move back to Stage 2 when, as at the reporting date, it is

no longer considered to be credit-impaired, subject to certain probation periods. The asset will migrate back to

Stage 1 when its credit risk at the reporting date is no longer considered to have increased significantly since initial

recognition.

Macroeconomic scenarios

ING Group has established a quarterly process whereby forward-looking macroeconomics scenarios and

probability weightings are developed for the purpose of ECL. ING Group applies data predominantly from a leading

service provider enriched with the internal ING Group view. A baseline, up-scenario and down-scenario are

determined to reflect an unbiased and probability-weighted ECL amount. As a baseline scenario, ING Group applies

the market-neutral view combining consensus forecasts for economic variables such as unemployment rates, GDP

growth, house prices, commodity prices, and short-term interest rates. Applying market consensus in the baseline

scenario ensures unbiased estimates of the expected credit losses.

The alternative scenarios are based on observed forecast errors in the past, adjusted for the risks affecting the

economy today and the forecast horizon. The probabilities assigned are based on the likelihoods of observing the

three scenarios and are derived from confidence intervals on a probability distribution. The forecasts for the

economic variables are adjusted on a quarterly basis.

The probability weights applied to each of the three scenarios

ING Group uses three macroeconomic scenarios when determining IFRS 9 ECL (baseline, upside and downside). The

management approach used to determine the weights of each scenario and in selecting the parts of the


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-239

distribution of forecast errors from which the weights are derived is disclosed in the 'Alternative Scenarios and

Probability Weights' section. Additionally, this approach is detailed in the sensitivity analysis within the 'Risk

management' section of the Annual Report.

Measurement of ECL

ING Group applies a collective assessment method to measure ECL for Stage 1, Stage 2, and certain Stage 3 assets.

Other credit-impaired assets subject to ECL measurement apply the individual assessment method.

Collectively assessed assets (Stages 1 to 3)

For collective assessed assets, ING Group applies a model-based approach. ECL is determined by, expressed

simplistically, multiplying the probability of default (PD) with the loss given default (LGD) and exposure at default

(EAD), adjusted for the time value of money. Assets that are collectively assessed are grouped on the basis of

similar credit-risk characteristics, taking into account the loan type, industry, geographic location, collateral type,

past due status and other relevant factors. These characteristics are relevant to the estimation of future cash flows

for groups of such assets by being indicative of the debtors’ ability to pay all amounts due according to the

contractual terms of the assets being evaluated and the loss in case the debtor is not able to pay all amounts due.

For Stage 3 assets, the PD equals 100% and the LGD and EAD represent a lifetime view of the losses based on

characteristics of defaulted facilities.

For the measurement of ECL, ING Group’s expected credit loss models (PD, LGD, EAD) used for regulatory purposes

have been adjusted. These adjustments include removing embedded prudential conservatism (such as floors) and

converted through-the-cycle estimates to point-in-time estimates. The models assess ECL on the basis of forward-

looking macroeconomic forecasts and other inputs. For most financial assets, the expected life is limited to the

remaining maturity. For overdrafts and certain revolving credit facilities, such as credit cards, the maturity is

estimated based on historical data as these do not have a fixed term or repayment schedule.

Individually assessed assets (Stage 3)

ING Group estimates ECL for individually significant credit-impaired financial assets within Stage 3 on an individual

basis. ECL for these Individually assessed assets are determined using the discounted expected future cash flow

method. To determine expected future cash flows, one or more scenarios are used. Each scenario is analysed

based on the probability of occurrence and includes forward-looking information.

In determining the scenarios, all relevant factors impacting the future cash flows are taken into account. These

include expected developments in credit quality, business and economic forecasts, and estimates of if/when

recoveries will occur, taking into account ING Group’s restructuring/recovery strategy.

The best estimate of ECL is calculated as the weighted-average of the shortfall (gross carrying amount minus

discounted expected future cash flow using the original EIR) per scenario, based on best estimates of expected

future cash flows. Recoveries can arise from, among other things, repayment of the loan, collateral recovery and

the sale of the asset. Cash flows from collateral and other credit enhancements are included in the measurement

of ECL of the related financial asset when it is part of or integral to the contractual terms of the financial asset and

the credit enhancement is not recognised separately. For the individual assessment, with granular (company- or

asset-specific) scenarios, specific factors can have a larger impact on the future cash flows than macroeconomic

factors.

When a financial asset is credit-impaired, interest income is no longer recognised based on the gross carrying

amount of the asset. Instead, interest income is calculated by applying the original effective interest rate to the

amortised cost of the asset, which is the gross carrying amount less the related loan loss provision.

Purchased or Originated Credit Impaired (POCI) assets

POCI assets are financial assets that are credit-impaired on initial recognition. Impairment on a POCI asset is

determined based on lifetime ECL from initial recognition. POCI assets are recognised initially at an amount net of

ECL and are measured at AC using a credit-adjusted effective interest rate. In subsequent periods, any changes to

the estimated lifetime ECL are recognised in profit or loss. Favourable changes are recognised as an impairment gain

if the lifetime ECL at the reporting date is lower than the estimated lifetime ECL at initial recognition.

Write-off and debt forgiveness

Loans and debt securities are written off (either partially or in full) when there is no reasonable expectation of

recovery and/or collectability of amounts due. The following events can lead to a write-off:

§After a restructuring has been completed and there is a high improbability of recovery of part of the remaining

loan exposure (including partial debt forgiveness);

§In a bankruptcy liquidation scenario;

§After divestment or sale of a credit facility at a discount; and

§Specific fraud cases with no recourse options.

When a loan is uncollectable, it is written off against the related loan loss provision. Subsequent recoveries of

amounts previously written off are recognised in ‘Addition to loan loss provisions’ in the Consolidated statement of

profit or loss.

Debt forgiveness (or debt settlement) involves write-off, but also involves the forgiveness of a legal obligation, in

whole or in part. This means that ING Group forfeits the legal right to recover the debt. As a result, the financial

asset needs to be derecognised.


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Presentation of ECL

ECL for financial assets measured at AC is deducted from the gross carrying amount of the assets. For debt

instruments at FVOCI, the ECL is recognised in OCI, instead of deducting it from the carrying amount of the asset.

ECL also reflects any credit losses related to the portion of the loan commitment that is expected to be drawn

down over the remaining life of the instrument. The ECL on issued financial guarantee contracts, in scope of IFRS 9

and not measured at FVPL, is recognised as liabilities and presented in Other provisions. ECL are presented in profit

or loss in Addition to loan loss provision.



	Significant judgements and critical accounting estimates and assumptions: The calculation of ECL requires a number of judgements and estimates. In particular: §ING Group makes various assumptions about the risk of default, the credit loss rates in case of a default and expected future cash flows. For collective provisions, ING Group applies significant judgement when estimating modelled parameters such as PD, LGD and EAD, including the selection and calibration of relevant models. For stage 3 individual provisioning, the determination and probabilities of restructuring and recovery scenarios, as well as the amount and timing of expected future cash flows, may be particularly subjective. §Forward-looking macroeconomic scenarios used in impairment assessments are uncertain in nature. The use of alternate forward-looking macroeconomic scenarios can produce significantly different estimates of ECL. This is demonstrated in the sensitivity analysis in the ‘Risk Management’ section of the annual report, where the un-weighted ECL under each of the three scenarios for some significant portfolios is disclosed. §When determining whether the credit risk on a financial asset has increased significantly (criteria for identifying a significant increase in credit risk), ING Group considers reasonable and supportable information to compare the risk of default occurring at reporting date with the risk of a default occurring at initial recognition of the financial asset. Whilst judgement is required in applying a PD rating to each financial asset, there is significant judgement used in determining the Stage allocation PD banding thresholds. The process of comparing a financial asset’s PD with the PD banding thresholds determines its ECL Stage. Assets in Stage 1 are allocated a 12-month ECL, and those in Stage 2 are allocated a lifetime ECL, and the difference is often significant. As such, the judgement made in assigning financial asset PDs and the PD banding thresholds constitutes a significant judgement. Analysis of the sensitivity associated with the assessment of a significant increase in credit risk is presented in the ‘Risk Management’ section of the Annual Report. §Judgement is exercised in management’s evaluation of whether there is objective evidence that exposures are credit-impaired. §To reflect the risks that are not properly captured by the ECL models (including climate risk), a number of management adjustments to the model-based ECL were necessary as at 31 December 2025, which required significant judgement. Reference is made to the ‘Management adjustments applied this reporting period’ paragraph in the ‘risk management’ section of the Annual Report.


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1.5.7 Modification of financial instruments

In certain circumstances, ING Group grants borrowers postponement, reduction of loan principal and/or interest

payments on a temporary period of time to maximise collection opportunities, and if possible, avoid default,

foreclosure, or repossession. When such postponement, reduction of loan principal and/or interest payments are

executed based on credit concerns, they are also referred to as forbearance (refer to the ‘Risk management’

section of the Annual Report for more details) and require analysis on whether the contractual terms have been

substantially modified or not. A similar assessment is needed when contractual terms are modified for reasons

other than forbearance.

ING Group determines whether there has been a substantial modification using both quantitative and qualitative

factors. If the modification results in a substantial modification of the terms of the loan, the original loan is

derecognised and a new loan is recognised at fair value at the modification date. In case of a non-substantial

modification, a modification gain or loss is recognised in profit or loss.

1.5.8 Accounting for Targeted Longer-Term Refinancing Operations (TLTRO)

ING Group participated in the Targeted Longer-Term Refinancing Operations (TLTRO III), which mainly affected

comparative periods as, in March 2024, ING repaid the final EUR 6 billion of its TLTRO III participation. ING Group

considered TLTRO funding provided by the ECB to banks to be on market terms on the basis that the ECB has

established a separate market with TLTRO programmes. They have specific terms which are different from other

sources of funding available to banks, including those provided by the ECB. Consequently, the rate under TLTRO

was considered to be a market conforming rate and TLTRO funding was recognised fully as a financial liability.

ING Group interpreted the whole rate set by the ECB under TLTRO as a floating rate on the financial liability, being

the market rate for each specific period in time. This resulted in discrete rates for discrete interest periods over the

life of TLTRO. The change in the applicable rate between interest periods was seen as a change in the floating rate

and was accounted for prospectively. Similarly, if the ECB announced changes in the rate for the amounts already

drawn under the existing TLTRO, then such changes also represented a change in a floating rate. Following this,

such changes led to the recognition of an increased/decreased interest in the relevant period of life of the

exposure, rather than by the recognition of an immediate modification gain or loss at the moment of the change

of terms by the ECB. If the change related to the periods already passed, the impact for those past periods was

recognised in profit or loss immediately. Reference is made to Note 20 ‘Net interest income’ for the presentation of

ING Group’s participation in TLTRO programmes.

1.5.9 Financial guarantees purchased (ING as holder)

When ING purchases a financial guarantee, it assesses whether the guarantee is integral or non‑integral to the

related loan.

Integral financial guarantees are not accounted for separately but included in the accounting for the loan under

IFRS 9:

§For loans measured at amortised cost or FVOCI, the guarantee is reflected in the expected credit loss (ECL)

measurement. Premiums paid are treated as transaction costs and recognised as part of Interest income using

the effective interest rate method.

§For loans measured at FVTPL, the guarantee is included in the fair value of the loan. Premiums paid are treated

as transaction costs and recognised within Fee and commission expense.

Non‑integral financial guarantees are accounted for separately, within Other assets, by analogy to

reimbursements under IAS 37 'Provisions, Contingent Liabilities and Contingent Assets':

§For loans measured at amortised cost or FVOCI, a compensation right asset is recognised and measured based

on ECL, provided recovery is virtually certain.

§Changes in compensation right assets are recognised as a reduction in risk costs within Addition to loan loss

provisions line in profit or loss. Premiums paid are recognised within Fee and commission expense.

§For loans measured at FVTPL, non‑integral financial guarantees are designated at FVTPL, with premiums

recognised within Fee and commission expense.

1.6 Consolidation

ING Group comprises ING Groep N.V. (the Parent Company), ING Bank N.V. and all other subsidiaries. Subsidiaries

are entities controlled by ING Groep N.V. Control exists if ING Groep N.V. is exposed to or has rights to variable

returns and has the ability to affect those returns through the power over the subsidiary.

For interests in structured entities, the existence of control requires judgement as these entities are designed so

that voting or similar rights are not the dominant factor in deciding who controls the entity. This judgement

includes, for example, the involvement in the design of the structured entity, contractual arrangements that give

rights to direct the structured entities' relevant activities and commitment to ensure that the structured entity

operates as designed.

Transactions between ING Groep N.V. and its subsidiaries are eliminated on consolidation. Reference is made to

Note 43 'Principal subsidiaries, investments in associates and joint ventures' for a list of principal subsidiaries and

their statutory place of incorporation. A description of ING’s activities involving structured entities is included in

Note 44 'Structured entities'.

A list containing the information referred to in Section 379 (1), Book 2 of the Dutch Civil Code has been filed with

the office of the Commercial Register of Amsterdam, in accordance with Section 379 (5), Book 2 of the Dutch Civil

Code.


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ING Groep N.V. and its Dutch group companies are subject to legal restrictions regarding the amount of dividends

they can pay to their shareholders. The Dutch Civil Code contains the restriction that dividends can only be paid up

to an amount equal to the excess of the company’s own funds over the sum of the paid-up capital and reserves

required by law. Certain Group companies are also subject to other restrictions in certain countries, in addition to

the restrictions on the amount of funds that may be transferred in the form of dividends, or otherwise, to the

parent company.

Furthermore, in addition to the restrictions regarding the minimum capital requirements that are imposed by

industry regulators in the countries in which the subsidiaries operate, other limitations exist in certain countries.

1.7 Segment reporting

An operating segment is a distinguishable component of ING Group, engaged in providing products or services,

whose operating results are regularly reviewed by the Executive Board of ING Group and the Management Board

Banking (together they make up the Chief Operating Decision Maker (CODM)) who decide which resources to

allocate to the segment and assess its performance.

The CODM reviews and assesses ING Group's performance primarily by line of business. As a result, ING identified

five operating segments which are also disclosed as reportable segments.

1.8 Hyperinflation accounting

Since the second quarter of 2022, Türkiye has been considered a hyperinflationary economy for accounting

purposes. As ING Group has a subsidiary in Türkiye, ING Group has applied IAS 29 ‘Financial Reporting in

Hyperinflationary Economies’ to its operations since then. IAS 29 continued to be relevant for ING’s operations in

Türkiye in 2023, 2024 and 2025. Under IAS 29, the results of the operations in Türkiye should be stated in terms of

the current purchasing power at the reporting date. For that, the consumer price index (CPI) as determined by the

Turkish Statistical Institute was used. The CPI for Türkiye (2003=100) at 31 December 2025 was 3,513.87, at 31

December 2024 was 2,684.55 and at 31 December 2023 it was 1,859.38 (movement 2025: 30.89%, 2024: 44.38%,

2023: 64.77%). The effect of such restatement for inflation in the current period of the statement of

comprehensive income and the balance sheet has been recognised in the statement of profit or loss within ‘Other

net income’ as a ‘Net monetary gain or loss’. The net monetary loss for the period represents the loss of

purchasing power by the net monetary position (monetary assets exceeding monetary liabilities) of ING Türkiye.

After the application of the above restatement procedures in Turkish Lira under IAS 29, the financial position and

the results for the period of ING Türkiye were translated and presented in EUR at the exchange rate on 31

December 2025. For the statement of comprehensive income this is in contrast with the usual translation

procedures where items of comprehensive income are translated at the exchange rate at the date of transaction.

Furthermore, ING Group chose to present both the restatement effect resulting from restating ING Group’s interest

in the equity of ING Türkiye as required by IAS 29, and the translation effect from translating at a closing rate that

differs from the previous closing rate, in the Currency translation reserve.

1.9 Foreign currency translation

Functional and presentation currency

Items included in the financial statements of each of ING Group’s entities are measured using the currency of the

primary economic environment in which the entity operates (the functional currency). The Consolidated financial

statements are presented in euros, which is ING Group’s presentation currency.

Transactions and balances

Foreign currency transactions are translated into the functional currency using the exchange rate prevailing at the

date of the transactions. Exchange rate differences resulting from the settlement of such transactions and from

the translation at year-end exchange rates of monetary assets and liabilities denominated in foreign currencies

are recognised in the statement of profit or loss, except when deferred in equity as part of qualifying cash flow

hedges or qualifying net investment hedges.

Non-monetary items that are measured in terms of historical cost in a foreign currency are translated using the

exchange rate at the date of the transaction.

Exchange rate differences on non-monetary items, measured at fair value through profit or loss, are reported as part

of the fair value gain or loss. Non-monetary items are retranslated at the date the fair value is determined. Exchange

rate differences on non-monetary items measured at fair value through other comprehensive income are included in

other comprehensive income and get accumulated in the revaluation reserve in equity.

Exchange rate differences in the statement of profit or loss are generally included in ‘Valuation results and net

trading income’. Reference is made to Note 22 ‘Valuation results and net trading income’, which discloses the

amounts included in the statement of profit or loss. Exchange rate differences relating to the disposal of debt and

FVPL equity securities are considered to be an inherent part of the capital gains and losses recognised in Investment

income. As mentioned below, in Group companies relating to the disposals of group companies, any exchange rate

difference deferred in equity is recognised in the statement of profit or loss in ‘Result on disposal of group companies’.

Reference is also made to Note 19 ‘Equity’, which discloses the amounts included in the statement of profit or loss.

Group companies

The results and financial positions of all group companies that have a functional currency different from the

presentation currency are translated into the presentation currency as follows:

§Assets and liabilities are translated at the closing rate at the date of the statement of financial position;

§Income and expenses are translated at average exchange rates (unless this average is not a reasonable

approximation of the cumulative effect of the rates prevailing on the transaction dates, in which case income


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-243

and expenses are translated at the dates of the transactions). However, under hyperinflation accounting,

income and expenses of ING Türkiye are translated at the closing rate; and

§All resulting exchange rate differences are recognised in a separate component of equity.

On consolidation, exchange rate differences arising from the translation of a monetary item that forms part of the

net investment in a foreign operation, and of borrowings and other instruments designated as hedges of such

investments, are taken to shareholders’ equity. When a foreign operation is sold, the corresponding exchange rate

differences are recognised in the statement of profit or loss as part of the gain or loss on sale.

Goodwill and fair value adjustments arising from the acquisition of a foreign operation are treated as assets and

liabilities of the foreign operation and translated at the exchange rate prevailing at the balance sheet date.

1.10 Investment in associates and joint ventures

Associates are all entities over which ING Group has significant influence but not control. Significant influence is the

ability to participate in the financial and operating policies of the investee. It generally results from a shareholding

of between 20% and 50% of the voting rights or through situations including, but not limited to one or more of the

following:

§Representation on the board of directors;

§Participation in the policymaking process; and

§Interchange of managerial personnel.

Joint ventures are entities over which ING Group has joint control.

Investments in associates and joint ventures are initially recognised at cost and subsequently accounted for using

the equity method of accounting. ING Group’s investment in associates and joint ventures (net of any

accumulated impairment loss) includes goodwill identified on acquisition. ING Group’s share of its associates and

joint ventures post-acquisition profits or losses is recognised in the statement of profit or loss, and its share of

post-acquisition changes in reserves is recognised in equity. The cumulative post-acquisition changes are adjusted

against the carrying amount of the investment. When ING Group’s share of losses in an associate or joint venture

equals or exceeds its interest in the associate or joint venture, including any long-term interests in the associate

like uncollateralised loans that are neither planned nor likely to be settled in the foreseeable future, ING Group

does not recognise further losses, unless it has incurred obligations or made payments on behalf of the associate

or joint venture.

Unrealised gains on transactions between ING Group and its associates and joint ventures are eliminated to the

extent of ING Group’s interest in the associates and joint ventures. Unrealised losses are also eliminated unless

they provide evidence of an impairment of the asset transferred. Accounting policies of associates and joint

ventures have been changed where necessary to ensure consistency with the policies adopted by ING Group.

The recoverable amount, being the higher of fair value less cost of disposal and value in use, of the investment in

associate and joint venture is determined when there is an indication of potential (reversal of) impairment. In case

of an indication of potential impairment, an impairment loss is recognised when the carrying amount of the

investment exceeds its recoverable amount. Goodwill on acquisitions of interests in associates and joint ventures is

not tested separately for impairment, but is assessed as part of the carrying amount of the investment. An

impairment loss is subsequently reversed if there is indication of a reversal and there is a change in the estimates

used to determine the recoverable amount. In case of an indication of a potential reversal of impairment, an

impairment loss is reversed to the extent that the recoverable amount exceeds its carrying amount, but cannot

exceed the original impairment loss.

The reporting dates of certain associates and joint ventures can differ from the reporting date of the Group, but by

no more than three months.


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	Significant judgements and critical accounting estimates and assumptions:
	Potential impairment and reversal assessment Identification of impairment indicators as well as indicators of potential reversal of previous impairments of ING Group’s investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), an associate, requires significant judgement. When there is objective evidence of impairment or indicators that prior period impairment losses no longer exist or may have decreased, value in use (VIU) needs to be determined. Estimation of VIU involves significant estimates and management assumptions. See Note 8 ‘Investment in associates and joint ventures’. Determination of significant influence over associates It is presumed that an entity has significant influence when it holds 20% or more of the voting power of the investee. Conversely, it is presumed that an entity does not have significant influence when voting power is less than 20% in the investee. Depending on the facts and circumstances, the presumption is rebutted when ING can clearly demonstrate whether or not it has power to participate in the investee’s financial and operating policy decisions. The consideration of all relevant factors requires judgement, including, amongst others, the investment purpose, investee’s governance structure and legal regime, ability to obtain meaningful board representation and participation in policymaking decisions. Refer to Note 5 'Financial assets at fair value through other comprehensive income' regarding ING’s accounting for its investment in Van Lanschot Kempen.

1.11 Property and equipment

Property in own use

Land and buildings held for own use are stated at fair value at the balance sheet date. Depreciation is recognised

on a straight-line basis over the estimated useful life (in general 20–50 years). On disposal, the related revaluation

reserve is transferred to retained earnings.

Equipment

Equipment is stated at cost less accumulated depreciation and any impairment losses. The cost of the assets is

depreciated on a straight line basis over their estimated useful lives, which are generally as follows: two to five

years for data processing equipment, and four to ten years for fixtures and fittings.

Disposals of property and equipment

The difference between the proceeds on disposal and net carrying value is recognised in the statement of profit or

loss under Other net income.

Right-of-use assets - ING Group as the lessee

A lessee is required to recognise a right-of-use asset representing its right to use the underlying leased asset and

a corresponding liability representing its obligation to make lease payments at the date at which the leased

asset is available for use by ING Group. Each lease payment is allocated between the repayment of the liability

and finance cost. The finance costs are charged to profit or loss over the lease period so as to produce a constant

periodic rate of interest on the remaining balance of the liability for each period. The right-of-use asset is

depreciated over the shorter of the asset’s useful life and the lease term on a straight-line basis.

Assets and liabilities arising from a lease are initially measured on a present value basis. Lease liabilities include

the net present value of the following lease payments:

§Fixed payments (including in-substance fixed payments), less any lease incentives receivable;

§Variable lease payments that are based on an index or a rate;

§Amounts expected to be payable by the lessee under residual value guarantees;

§The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and

§Payments of penalties for terminating the lease, if the lease term reflects the lessee exercising that option.

The lease payments are discounted using the interest rate implicit in the lease. If that rate cannot be readily

determined, the lessee’s incremental borrowing rate is used, being the rate that the lessee would have to pay to

borrow the funds necessary to obtain an asset of similar value in a similar economic environment with similar

terms and conditions.

Right-of-use assets are measured at cost comprising the amount of the initial measurement of the lease liability,

any lease payments made at or before the commencement date less any lease incentives received and any initial

direct costs and restoration costs.

The right-of-use asset is included in the statement of financial position line-item ‘Property and equipment’. The

lease liability is included in the statement of financial position line-item ‘Other liabilities’. Refer to Note 9 ‘Property

and equipment’ and to Note 16 ‘Other liabilities’.

Subsequent to initial recognition, the right-of-use asset amortises using a straight-line method to the income

statement over the life of the lease. The lease liability increases for the accrual of interest and decreases when

payments are made. Any remeasurement of the lease liability due to a lease modification or other reassessment

results in a corresponding adjustment to the carrying amount of the right-of-use asset.


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1.12 ING Group as lessor

When ING Group acts as a lessor, a distinction should be made between finance leases and operating leases. For

ING Group as a lessor, these are mainly finance leases and are therefore not included in 'Property and equipment'.

Instead, the present value of the lease payments is recognised as a receivable under Loans and advances to

customers or Loans and advances to banks. The difference between the gross receivable and the present value of

the receivable is unearned finance lease income. Lease income is recognised over the term of the lease using the

net investment method (before tax), which reflects a constant periodic rate of return.

1.13 Goodwill and other intangible assets

Impairment of goodwill and other non-financial assets

ING Group assesses at each reporting period whether there is an indication that a non-financial asset may be

impaired. Irrespective of whether there is an indication of impairment, intangible assets with an indefinite useful

life, including goodwill acquired in a business combination, and intangible assets not yet available for use, are

tested annually for impairment. Goodwill is allocated to groups of cash generating units (CGUs) for the purpose of

impairment testing. These groups of CGUs represent the lowest level at which goodwill is monitored for internal

management purposes. Goodwill is tested for impairment by comparing the carrying value of the group of CGUs to

the recoverable amount of that group of CGUs. Impairment of goodwill, if applicable, is included in the statement

of profit or loss in Other operating expenses and is not subsequently reversed.

Computer software

Computer software that has been purchased or generated internally for own use is stated at cost less amortisation

and any impairment losses. Amortisation is calculated on a straight-line basis over its useful life, which generally

does not exceed five years. Amortisation is included in Other operating expenses.

1.14 Taxation

Income tax on the result for the year consists of current and deferred tax. Income tax is recognised in the

statement of profit or loss but it is recognised directly in equity if the tax relates to items that are recognised

directly in equity.

Uncertain tax positions are assessed continually by ING Group and in case it is probable that there will be a cash

outflow, a current tax liability is recognised.

Deferred income tax

Deferred income tax is provided in full, using the liability method, for temporary differences arising between the

tax basis of assets and liabilities and their carrying amounts in the Consolidated statement of financial position.

Deferred income tax is determined using tax rates (and laws) that have been enacted or substantively enacted at

the balance sheet date and are expected to apply when the related deferred income tax asset is realised or the

deferred income tax liability is settled. Deferred tax assets and liabilities are not discounted.

Deferred tax assets are recognised when it is probable that future taxable profit will be available against which the

temporary differences can be utilised. Deferred income tax is provided for temporary differences arising from

investments in subsidiaries and associates, except where the timing of the reversal of the temporary difference is

controlled by ING Group and it is probable that the difference will not reverse in the foreseeable future. The tax

effects of income-tax losses available for carry forward are recognised as an asset where it is probable that future

taxable profits will be available, against which these losses can be utilised.

Fair value remeasurements of debt and equity instruments measured at FVOCI and cash flow hedges are

recognised directly in equity. Deferred tax related to this fair value remeasurement is also recognised directly in

equity and is subsequently recognised in the statement of profit or loss together with the deferred gain or loss.

1.15 Provisions, contingent liabilities and contingent assets

A provision is a present obligation arising from past events, the settlement of which is expected to result in an

outflow of resources embodying economic benefits. However, the timing or the amount is uncertain. Provisions are

discounted when the effect of the time value of money is significant using a pre-tax discount rate.

Reorganisation provisions include employee termination benefits when ING Group is demonstrably committed to

either terminate the employment of current employees according to a detailed formal plan without possibility of

withdrawal, or providing termination benefits as a result of an offer made to encourage voluntary redundancy.

A liability is recognised for a levy when the activity that triggers payment, as identified by the relevant legislation,

occurs. For a levy that is triggered upon reaching a minimum threshold, the liability is recognised only upon

reaching the specified minimum threshold.

A contingent liability is a possible obligation that arises from past events and whose existence will be confirmed

only by the occurrence or non-occurrence of one or more uncertain future events not wholly within the control of

ING Group, or a present obligation that arises from past events but is not recognised because it is either not

probable that an outflow of economic benefits will be required to settle the obligation or the amount of the

obligation cannot be measured reliably. Contingent liabilities are not recognised in the statement of financial

position, but are rather disclosed in the notes unless the possibility of the outflow of economic benefits is remote.

A contingent asset is a possible asset that arises from past events and whose existence will be confirmed only by

the occurrence or non-occurrence of one or more uncertain future events not wholly within the control of ING

Group. Contingent assets are recognised in the statement of financial position only when realisation of the income

that arises from such an asset is virtually certain. Contingent assets are disclosed in the notes when an inflow of

economic benefits is probable.


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	Significant judgements and critical accounting estimates and assumptions: The recognition and measurement of provisions is an inherently uncertain process, involving using judgement to determine when a present obligation exists and estimates regarding probability, amounts and timing of cash flows. ING Group may become involved in governmental, regulatory, arbitration and legal proceedings and investigations, and may be subject to third-party claims. With or without reference to the above, ING Group may also offer compensation to certain of its customers. Judgement is required to assess whether a present obligation exists and to estimate the probability of an unfavourable outcome and the amount of potential loss. The degree of uncertainty and the method of making the accounting estimate depends on the individual case, its nature and complexity. Such cases are usually one of a kind. For the assessment of related provisions, ING Group consults with internal and external legal experts. Even taking into consideration legal experts’ advice, the probability of an outflow of economic benefits can still be uncertain and the provision recognised can remain sensitive to the assumptions used. Reference is made to Note 15 'Provisions'. For proceedings where it is not possible to make a reliable estimate of the expected financial effect, that could result from the ultimate resolution of the proceedings, no provision is recognised, however disclosure is included in the financial statements, where relevant. Reference is made to Note 42 'Legal proceedings'. Critical accounting estimates and assumptions for the reorganisation provision are in estimating the amounts and timing of cash flows as the announced transformation initiatives are implemented over a period of several years. Reference is made to Note 15 'Provisions'.

1.16 Irrevocable Payment Commitments on contributions to SRF and DGS

ING makes contributions to the Single Resolution Fund (SRF) and Deposit Guarantee Schemes (DGS). The annual

contributions are paid in cash or, in some cases, partly using Irrevocable Payment Commitments (IPCs) that

become payable if and when called. Cash contributions are accounted for as levies as described in section 1.15

above, while IPCs are disclosed in Note 41 'Commitments'. Cash collateral posted on IPCs to the SRF is accounted

for as an interest bearing financial asset at amortised cost. Government bonds posted as collateral on IPCs to DGS

continue to be recognised as assets of ING as securities at amortised cost.

1.17 Other liabilities

Defined benefit plans

The net defined benefit asset or liability recognised in the statement of financial position in respect of defined

benefit pension plans is the fair value of the plan assets less the present value of the defined benefit obligation at

the balance sheet date.

Changes in plan assets include mainly:

§Return on plan assets are recognised as staff costs in the statement of profit or loss. It is determined using a

high quality corporate bond rate (identical to the discount rate used in determining the defined benefit

obligation) at the start of the reporting period; and

§Remeasurements which are recognised in Other comprehensive income.

The defined benefit obligation is calculated by internal and external independent qualified actuaries through

actuarial models and calculations using the projected unit credit method. This method considers expected future

payments required to settle the obligation resulting from employee service in the current and prior periods,

discounted using a high quality corporate bond rate. Inherent in these actuarial models are assumptions including

discount rates, rates of increase in future salary and benefit levels, mortality rates, consumer price index and the

expected level of indexation. The assumptions are based on available market data as well as management

expectations and are updated regularly.

Changes in the defined benefit obligation include mainly:

§Service cost which is recognised as staff costs in the statement of profit or loss;

§Interest expenses are recognised as staff costs in the Statement of profit or loss. It is determined using a high

quality corporate bond rate at the start of the period;

§Remeasurements which are recognised in Other comprehensive income (equity) and not recycled to the

Statement of profit or loss;

§Any past service cost relating to a plan amendment is recognised in profit or loss in the period of the plan

amendment; and

§Gains and losses on curtailments and settlements are recognised in the Statement of profit or loss when the

curtailment or settlement occurs.

The recognition of a net defined benefit asset in the Consolidated statement of financial position is limited to the

present value of any economic benefits available in the form of refunds from the plans or reductions in future

contributions to the plans.


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Defined contribution plans

For defined contribution plans, ING Group pays contributions to publicly or privately administered pension

insurance plans on a mandatory, contractual or voluntary basis. ING Group has no further payment obligations

once the contributions have been paid. The contributions are recognised as staff expenses in the profit or loss

when they are due. Prepaid contributions are recognised as an asset to the extent that a cash refund or a

reduction in the future payments is available.

Other post-employment obligations

Some group companies provide other post-employment benefits to former employees. The entitlement to these

benefits is usually conditional on the employee remaining in service up to retirement age and the completion of a

minimum service period. The expected costs of these benefits are accrued over the period of employment using an

accounting methodology similar to that for defined benefit pension plans.

1.18 Treasury shares

Treasury shares (own equity instruments bought back by ING Group or its subsidiaries) are deducted from Equity

(Other reserves). No gain or loss is recognised in the statement of profit or loss when purchasing, selling or

cancelling these shares. Treasury shares are not taken into account when calculating earnings per ordinary share

or dividend per ordinary share as they are not considered to be outstanding.

Treasury shares can be purchased by ING as part of a share buyback programme. If a share buyback is executed

by a broker and the agreement with the broker is irrevocable, ING has a contractual obligation to purchase its own

shares that is unavoidable once it signs the agreement with the broker. This is the moment when ING recognises a

financial liability measured at the present value of the redemption amount with a corresponding reduction in

equity (Retained earnings). During the share buyback programme, ING settles this liability for the actual purchase

price paid for the shares bought on a daily basis. Actual shares bought back and held by ING are presented as

Treasury shares within Other reserves in equity.

1.19 Income recognition

Interest

Interest income and expense are recognised in the statement of profit or loss using the effective interest method.

The effective interest method is a method of calculating the amortised cost of a financial asset or a financial

liability and of allocating the interest income or interest expense over the relevant period. The effective interest

rate is the rate that exactly discounts estimated future cash payments or receipts through the expected life of the

financial instrument or, when appropriate, a shorter period to the net carrying amount of the financial asset or

financial liability. When calculating the effective interest rate, ING Group estimates cash flows considering all

contractual terms of the financial instrument (for example, prepayment options) but does not consider future

credit losses.

The calculation includes all fees and points paid or received between parties to the contract that are an integral

part of the effective interest rate, transaction costs and all other premiums or discounts. Once a financial asset or

a group of similar financial assets has been written down as a result of an impairment loss, interest income is

recognised using the rate of interest used to discount the future cash flows for the purpose of measuring the

impairment loss.

Interest results on instruments classified at Amortised Cost, assets measured at FVOCI and derivatives in a formal

hedge accounting relationship are presented in ‘Interest income (expense) using effective interest rate method’.

Interest result on financial assets and liabilities voluntarily designated as at FVPL and derivatives in so-called

economic hedges and instruments designated at fair value are presented in ‘Other interest income (expense)’.

Interest result on all other financial assets and liabilities at FVTPL is recognised in ‘Valuation results and net trading

income’.

Fees and commissions

Fees and commissions are generally recognised as the service is provided. Loan commitment fees for loans that

are likely to be drawn down are deferred (together with related direct costs) and recognised as an adjustment to

the effective interest rate on the loan. Loan syndication fees are recognised as income when the performance

obligation has been satisfied based on the particular contract and ING Group has retained no part of the loan

package for itself or has retained a part at the same effective interest rate as the other participants. Commission

and fees arising from negotiating, or participating in the negotiation of, a transaction for a third party – such as

the arrangement of the acquisition of shares or other securities or the purchase or sale of businesses – are

recognised on completion of the underlying transaction. Portfolio and other management advisory and service

fees are recognised based on the applicable service contracts as the service is provided. Asset management fees

related to investment funds and investment contract fees are recognised on a pro-rata basis over the period the

service is provided. The same principle is applied for wealth management, financial planning and custody services

that are continuously provided over an extended period of time. Fees received and paid between banks for

payment services are classified as commission income and expenses.

Lease income

The proceeds from leasing out assets under operating leases are recognised on a straight-line basis over the life of

the lease agreement. Lease payments received in respect of finance leases when ING Group is the lessor are

divided into an interest component (recognised as interest income) and a repayment component based on a

pattern reflecting a constant periodic rate of return on the lessor’s net investment in the lease.

1.20 Expense recognition

Expenses are recognised in the statement of profit or loss as incurred, or when a decrease in future economic

benefits related to a decrease in an asset or an increase in a liability has arisen that can be measured reliably. Fee

and commission expenses generally result from contracts with ING service providers, who perform their service for


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ING Group’s customers. Costs are generally presented as ‘Commission expenses’ if they are specific, incremental,

directly attributable and identifiable to generate income.

Share-based payments

ING Group only engages in share-based payment transactions with its staff and directors. Share-based payment

expenses are recognised as a staff expense over the vesting period. A corresponding increase in equity is

recognised for equity-settled share-based payment transactions. A liability is recognised for cash-settled share-

based payment transactions. The fair value of equity-settled share-based payment transactions are measured at

the grant date, and the fair value of cash-settled share-based payment transactions are measured at each

balance sheet date. Rights granted will remain valid until the expiry date, even if the share based payment

scheme is discontinued. The rights are subject to certain conditions, including a pre-determined continuous period

of service.

1.21 Earnings per ordinary share

Earnings per ordinary share is calculated on the basis of the weighted average number of ordinary shares

outstanding. In calculating the weighted average number of ordinary shares outstanding:

§Own shares held by group companies are deducted from the total number of ordinary shares in issue;

§The computation is based on daily averages; and

§In case of exercised warrants, the exercise date is taken into consideration.

Diluted earnings per share data are computed as if all convertible instruments outstanding at year-end were

exercised at the beginning of the period. It is also assumed that ING Group uses the assumed proceeds thus

received to buy its own shares against the average market price in the financial year. The net increase in the

number of shares resulting from the exercise is added to the average number of shares used to calculate diluted

earnings per share.

1.22 Statement of cash flows

The statement of cash flows is prepared in accordance with the indirect method, distinguishing cash flows from

operating, investing and financing activities. In the net cash flow from operating activities, the result before tax is

adjusted for those items in the statement of profit or loss and changes in items per the statement of financial

position, which do not result in actual cash flows during the year.

For the purposes of the statement of cash flows, Cash and cash equivalents include deposits from banks and loans

and advances to banks that are on demand. Furthermore, it includes treasury bills and other eligible bills shorter

than three months. Investments qualify as a cash equivalent if they are readily convertible to a known amount of

cash and are subject to an insignificant risk of changes in value.

Cash flows arising from foreign currency transactions are translated into the functional currency using the

exchange rates at the date of the cash flows.

The net cash flow shown in respect of Loans and advances to customers relates only to transactions involving

actual payments or receipts. The Addition to loan loss provision, which is deducted from the item Loans and

advances to customers in the statement of financial position, has been adjusted accordingly from the result before

tax and is shown separately in the statement of cash flows.

The difference between the Net cash flow in accordance with the statement of cash flows and the change

between the opening and closing balance of Cash and cash equivalents in the statement of financial position is

due to exchange rate differences and is presented separately in the cash flow statement.

Liabilities arising from financing activities are debt securities, lease liabilities and subordinated loans.

1.23 Parent company financial statements

The condensed parent company financial statements of ING Groep N.V. are prepared using the recognition and

measurement principles as those applied in the Consolidated financial statements. Additionally, the investments in

Group companies are accounted for in the Parent company accounts according to the equity method.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-249

Notes to the Consolidated statement of financial position

2 Cash and balances with central banks


Cash and balances with central banks
in EUR million	2025	2024
Amounts held at central banks 1	51,133	68,708
Cash and bank balances	1,756	1,645
	52,889	70,353

1Amounts held at central banks include an amount of EUR -17 million (2024: EUR -14 million) of Loan loss provisions.

Amounts held at central banks reflect on-demand balances. The movement reflects ING’s active liquidity

management.

Reference is made to Note 39 'Transfer of financial assets, assets pledged and received as collateral' for restrictions

on amounts held at central banks.

3 Loans and advances to banks


Loans and advances to banks
	Netherlands		Rest of the world		Total
in EUR million	2025	2024	2025	2024	2025	2024
Loans and advances to banks1	12,362	14,344	8,841	7,426	21,204	21,770

1 Loans and advances to banks include EUR -18 million (2024: EUR -22 million) of Loan loss provisions.

Loans and advances include balances of reverse repurchase transactions. For more information, refer to Note 4

'Financial assets at fair value through profit or loss'. Furthermore, it includes on-demand and term loans, and cash

collateral transactions. Reference is made to Note 7 'Loans and advances to customers' for information on finance

lease receivables included in Loans and advances to banks.

As at 31 December 2025 and at 31 December 2024, all loans and advances to banks are non-subordinated.

4 Financial assets at fair value through profit or loss


Financial assets at fair value through profit or loss
in EUR million	2025	2024
Trading assets	55,730	72,897
Non-trading derivatives	1,657	2,463
Designated at fair value through profit or loss	3,448	5,740
Mandatorily measured at fair value through profit or loss	72,322	56,481
	133,157	137,580

(Reverse) repurchase transactions

Financial assets at fair value through profit or loss include securities lending and sales and repurchase transactions

with securities. At ING, these types of transactions are recognised in several lines in the statement of financial

position depending on business model assessment and counterparty. Netting is applicable to repurchase

agreements that are governed by an established Global Master Repurchase Agreement (GMRA) when ING Group

has the intention to settle net. This netting is restricted to transactions involving the same currency and maturity

date, and must occur within the same legal entity. Reference is made to Note 40 'Offsetting financial assets and

liabilities'.

Securities purchased under agreements to resell (reverse repos), securities borrowings and similar agreements are

not recognised in the consolidated statement of financial position as the counterparty continues to be exposed to

substantially all risks and rewards of the transferred security. Based on the business model assessment and

counterparty, the consideration paid to purchase securities is recognised as Loans and advances to customers,

Loans and advances to banks, financial assets mandatorily at FVPL or Trading assets.

Securities sold subject to repurchase agreements (repos), securities lending and similar agreements continue to be

recognised in the consolidated statement of financial position as ING Group continues to be exposed to

substantially all risks and rewards of the transferred financial asset. The counterparty liability is designated and

measured at FVPL if the asset is measured mandatorily at FVPL. Otherwise, the counterparty liability is included in

Deposits from banks, Customer deposits or Trading. Furthermore, for repurchase agreements, the gross amount of

assets must be considered together with the gross amount of related liabilities, which are presented separately on


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-250

the statement of financial position since IFRS does not always allow the netting of these positions in the statement

of financial position.

Reference is made to Note 39 'Transfer of financial assets, assets pledged and received as collateral' for

information on transferred assets which were not derecognised.

ING Group’s exposure to (reverse) repurchase transactions is included in the following lines in the statement of

financial position:


Exposure to (reverse) repurchase agreements
in EUR million	2025	2024
Reverse repurchase transactions
Loans and advances to banks	6,836	10,777
Loans and advances to customers	3,866	3,471
Trading assets, loans and receivables	1,574	12,033
Loans and receivables mandatorily measured at fair value through profit or loss	68,469	53,393
	80,746	79,675
Repurchase transactions
Deposits from banks	330	33
Customer deposits	182	1
Trading liabilities, funds on deposit	31	5,269
Funds entrusted designated and measured at fair value through profit or loss	46,211	38,420
	46,755	43,723

Trading assets


Trading assets by type
in EUR million	2025	2024
Equity securities	21,272	20,717
Debt securities	8,120	10,080
Derivatives	24,346	29,805
Loans and receivables	1,991	12,295
	55,730	72,897

Trading assets include assets that are closely related to servicing the needs of the clients of ING Group. ING offers

institutional clients, corporate clients, and governments products that are traded on the financial markets. A

significant part of the derivatives in the trading portfolio is related to servicing corporate clients in their risk

management to hedge, for example, currency or interest rate exposures. In addition, ING provides its customers

access to equity and debt markets for issuing their own equity or debt securities (securities underwriting).

Reference is made to Note 14 'Financial liabilities at fair value through profit or loss' for information on trading

liabilities.

Non-trading derivatives


Non-trading derivatives by type
in EUR million	2025	2024
Derivatives used in
- fair value hedges	578	617
- cash flow hedges	459	158
- hedges of net investments in foreign operations	68	82
Other non-trading derivatives	550	1,606
	1,657	2,463

Reference is made to Note 36 'Derivatives and hedge accounting' for information on derivatives designated in

hedge accounting.

Other non-trading derivatives mainly includes interest-rate swaps, foreign exchange swaps, and cross currency

swaps for which no hedge accounting is applied.

Designated at fair value through profit or loss


Designated at fair value through profit or loss by type
in EUR million	2025	2024
Debt securities	2,330	4,718
Loans and receivables	1,118	1,022
	3,448	5,740

‘Financial assets designated at fair value through profit or loss’ is partly economically hedged by credit derivatives.

The hedges do not meet the criteria for hedge accounting and the loans and debt securities are recorded at fair

value to avoid an accounting mismatch. The maximum credit exposure of the loans and receivables and debt

securities included in ‘Financial assets designated at fair value through profit or loss’ approximates its carrying

value and amounts to EUR 3,448 million (2024: EUR 5,740 million). In 2025, the change in fair value of these loans

and debt securities amounts to EUR -177 million (2024: EUR 5 million).


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-251

ING has mitigated the credit risk exposure on part of the portfolio. The cost at initial recognition of the financial

assets designated at fair value through profit or loss that are economically hedged by credit derivatives is EUR

2,454 million (2024: EUR 3,797 million). The cumulative change in fair value attributable to changes in credit risk

for the financial asset economically hedged is EUR 85 million (2024: EUR 173 million) and the change for the

current year is EUR -88 million (2024: EUR 24 million). The cumulative change in fair value attributable to changes

in credit risk for the financial assets non-economically hedged with credit derivatives is EUR 513 million (2024: EUR

489 million) and the change for the current year is EUR 23 million.

The notional value of the related credit derivatives is EUR 2,486 million (2024: EUR 3,807 million). The cumulative

change in fair value of the credit derivatives since the financial assets were first designated, amounts to EUR

-85 million (2024: EUR -214 million) and the change for the current year is EUR 128 million (2024: EUR -95 million).

The changes in fair value attributable to changes in credit risk have been calculated by determining the changes in

credit spread implicit in the fair value of loans and bonds issued by entities with similar credit characteristics.

Mandatorily at fair value through profit or loss


Mandatorily at fair value through profit or loss by type
in EUR million	2025	2024
Equity securities	310	228
Debt securities	769	789
Loans and receivables	71,243	55,464
	72,322	56,481

Equity securities are individually insignificant for ING Group. For total exposure to debt securities, reference is made

to Note 6 'Debt securities'. Loans and receivables include mainly reverse repurchase agreements.

5 Financial assets at fair value through other comprehensive income


Financial assets at fair value through other comprehensive income by type
in EUR million	2025	2024
Equity securities	2,607	2,562
Debt securities 1	50,817	42,219
Loans and advances 1	3,238	1,608
	56,662	46,389

1 Debt securities includes an amount of EUR -15 million (2024: EUR -12 million) and Loans and advances includes EUR -6 million (2024: EUR -7 million) of

Loan loss provisions.

Exposure to equity securities


Equity securities designated as at fair value through other comprehensive income
	Carrying value	Carrying value 1	Dividend income	Dividend income 1
in EUR million	2025	2024	2025	2024
Investment in Bank of Beijing	1,838	2,241	98	101
Investment in Van Lanschot Kempen	462	51	12	2
Other Investments	307	270	6	14
	2,607	2,562	116	117

1 The table has been updated to present the increased stake in Van Lanschot Kempen separately from other investments.

As at 31 December 2025 ING holds 13% (2024: 13%) of the shares of Bank of Beijing, a bank listed on the Shanghai

Stock Exchange. The stake in Bank of Beijing is part of the Corporate Line. As per regulatory requirements set by

the China Banking and Insurance Regulatory Commission, ING, as a shareholder holding more than 5% of the

shares, is required to supply additional capital when necessary. No request for additional capital was received in

2025 (2024: nil).

In 2025 ING increased its ownership in Van Lanschot Kempen by acquiring an additional 17.6% stake, raising its

total interest based on the issued share capital from 2.7% to 20.3%. Despite ING holding over 20% voting rights in

VLK (a presumption of significant influence in IFRS), this presumption is rebutted given that ING holds rights similar

to other ordinary shareholders where voting does not include financial and operating policy decisions and ING

does not have the rights or ability to obtain board representation. Therefore, the increased investment in VLK is

designated at fair value through other comprehensive income consistent with ING’s passive investment purpose.

The stake is part of the Corporate Line.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-252

Changes in fair value through other comprehensive income

The following table presents changes in financial assets at fair value through other comprehensive income:


Changes in fair value through other comprehensive income financial assets
	FVOCI equity securities		FVOCI debt instruments 1		Total
in EUR million	2025	2024	2025	2024	2025	2024
Opening balance as at 1 January	2,562	1,885	43,827	39,231	46,389	41,116
Additions	395	11	42,899	21,080	43,294	21,091
Amortisation			75	77	75	77
Transfers	10			1	10	1
Changes in unrealised revaluations 2	-156	605	322	-96	166	509
Impairments			-10	2	-10	2
Reversals of impairments			7	-7	7	-7
Disposals and redemptions	-7	-1	-33,124	-16,906	-33,131	-16,907
Exchange rate differences	-178	62	-1,088	443	-1,267	506
Other changes	-19		1,148		1,128
Closing balance	2,607	2,562	54,055	43,827	56,662	46,389

1Fair value through other comprehensive income debt instruments includes both debt securities and loans and advances.

2Changes in unrealised revaluations of FVOCI debt instruments include changes on hedged items which are recognised in the statement of profit or loss.

Reference is made to Note 19 'Equity' for details on the changes in the revaluation reserve.

FVOCI equity securities

Exchange rate differences of EUR -178 million (31 December 2024: EUR 62 million) are mainly related to the stake

in Bank of Beijing following the depreciation of CNY versus EUR. In 2025, changes in unrealised revaluations of

equity securities are mainly related to a revaluation of the stake in Bank of Beijing of EUR -225 million (31

December 2024: EUR 590 million) following a change in the share price.

FVOCI debt instruments

In 2025, changes in interest rates and portfolio composition resulted in changes in unrealised revaluations of debt

securities of EUR 322 million (31 December 2024: EUR -96 million).

Reference is made to Note 6 'Debt securities' for details on ING Group’s total exposure to debt securities.

6 Debt securities

ING Group’s exposure to debt securities is included in the following lines in the statement of financial position:


Exposure to debt securities
in EUR million	2025	2024
Debt securities at fair value through other comprehensive income	50,817	42,219
Debt securities at amortised cost	53,867	50,273
Total debt securities at fair value through other comprehensive income and amortised cost	104,684	92,493

Trading assets	8,120	10,080
Debt securities designated and measured at fair value through profit or loss	2,330	4,718
Debt securities mandatorily measured at fair value through profit or loss	769	789
Total debt securities at fair value through profit or loss	11,219	15,586
	115,903	108,078

ING Group’s total exposure to debt securities (excluding debt securities held in the trading portfolio) of EUR 107,783

million (31 December 2024: EUR 97,999 million) is specified as follows:


Debt securities by type of exposure
	Debt Securities at FVPL 1		Debt Securities at FVOCI		Debt Securities at AC		Total
in EUR million	2025	2024	2025	2024	2025	2024	2025	2024
Government bonds	288	289	32,578	24,757	25,297	22,734	58,163	47,780
Central bank bonds	376	444			2,541	2,900	2,917	3,344
Sub-sovereign, Supranationals and Agencies	413	1,027	13,788	11,513	16,744	15,445	30,945	27,985
Covered bonds			3,750	4,108	5,362	5,683	9,111	9,791
Corporate bonds	89	848	109	79	50	106	248	1,033
Financial institutions' bonds	1,176	2,141	28	980	96	139	1,300	3,261
ABS portfolio	757	757	578	794	3,790	3,281	5,125	4,832
	3,099	5,506	50,832	42,231	53,879	50,288	107,809	98,026
Loan loss provisions			-15	-12	-11	-15	-26	-27
Debt securities portfolio	3,099	5,506	50,817	42,219	53,867	50,273	107,783	97,999

1Debt securities at FVPL includes both debt securities designated - and mandatorily measured at fair value through profit or loss.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-253

7 Loans and advances to customers


Loans and advances to customers by type
	Netherlands		Rest of the world		Total
in EUR million	2025	2024	2025	2024	2025	2024
Loans and advances to public authorities	3,452	1,888	19,583	16,773	23,034	18,661
Residential mortgages	129,994	119,191	245,103	229,403	375,097	348,594
Other personal lending	5,033	5,007	34,690	31,789	39,723	36,797
Corporate Lending	68,792	66,921	226,981	218,473	295,773	285,393
	207,270	193,007	526,357	496,437	733,627	689,445

Loan loss provisions	-836	-811	-5,058	-5,023	-5,894	-5,833
	206,434	192,197	521,299	491,415	727,733	683,611

For details on credit quality and loan loss provisioning, refer to ‘Risk management – Credit risk’ – paragraphs ‘Credit

quality’ and 'Loan loss provisioning'.

As at 31 December 2025 EUR 727,498 million (2024: EUR 683,398 million) of loans and advances to customers are

non-subordinated.

Loans and advances to customers and, to a lesser extent, to banks include finance lease receivables which are

detailed as follows:


Finance lease receivables 1
in EUR million	2025	2024
Maturities of gross investment in finance lease receivables
- within 1 year	4,121	3,962
- between 1-2 years	3,040	2,961
- between 2-3 years	2,408	2,283
- between 3-4 years	1,563	1,577
- between 4-5 years	935	902
- more than 5 years	1,609	1,555
	13,677	13,240

Unearned future finance income on finance leases	-1,122	-1,145
Net investment in finance leases	12,554	12,095

Included in Loans and advances to banks	3	5
Included in Loans and advances to customers	12,551	12,091
	12,554	12,095

1The total loan loss provision for finance lease receivables is EUR 191 million (2024: EUR 193 million).

The finance lease receivables mainly relate to the financing of equipment and real estate for third parties where

ING is the lessor and are mainly part of corporate lending. Interest income in 2025 on finance lease receivables

amounts to EUR 513 million (2024: EUR 522 million).

8 Investment in associates and joint ventures


Investments in associates and joint ventures
	2025			2024
in EUR million	Interest held (%)	Fair value of listed investments	Balance sheet value	Interest held (%)	Fair value of listed investments	Balance sheet value
TMBThanachart Bank Public Company Limited	23%	1,212	1,307	23%	1,164	1,266
Other investments in associates and joint ventures			300			412
			1,607			1,679


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-254

TMBThanachart Bank Public Company Limited

ING Group has an 23% investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), a bank listed

on the stock exchange of Thailand. TTB is providing products and services to wholesale, small and medium

enterprise (SME), and retail customers. TTB is accounted for as an investment in associate based on the size of

ING's shareholding and representation on the Board. The investment in TTB is reflected in the Corporate Line.

A summary of the unaudited financial information of TTB as of the end of September 2025 based on the data

available at the time the consolidated financial statements were prepared is presented below. TTB’s statutory

reporting date is 31 December. For the year ending 31 December 2025, ING recognised the associate’s results

using TTB’s financial statements for the 12‑month period ending 30 September 2025.


Selected balance sheet information TMBThanachart Bank Public Company Limited
As at 30 September in EUR million	2025	2024
Loans to customers and accrued interest receivables, net	31,009	33,878
Interbank and money market items, net	5,856	7,152
Investments, net	5,917	4,680
Other	3,158	3,436
Total assets	45,940	49,147
Deposits	34,345	36,563
Interbank and money market items	2,663	2,633
Debts issued and borrowings	462	1,139
Other	1,942	2,218
Total liabilities	39,412	42,554
Equity	6,529	6,593


Selected profit or loss information TMBThanachart Bank Public Company Limited
For the 12 months ended 30 September
in EUR million	2025	2024
Total operating income	1,795	1,991
Total expenses	1,266	1,548
Profit for the period	555	586
Total other comprehensive income for the period	170	17

Other investments in associates and joint ventures

Included in Other investments in associates and joint ventures are mainly financial services and (non-) financial

technology funds or vehicles operating predominantly in Europe, and are individually not significant to ING Group.

Significant influence for associates in which the interest held is below 20%, is based on the combination of ING

Group’s financial interest and other arrangements, such as participation in the Board of Directors.

The associates and joint ventures of ING are subject to legal and regulatory restrictions regarding the amount of

dividends they can pay to ING. These restrictions are, for example, dependent on the laws in the country of

incorporation for declaring dividends or as a result of minimum capital requirements that are imposed by industry

regulators in the countries in which the associates and joint ventures operate.

In addition, the associates and joint ventures also consider other factors in determining the appropriate levels of

equity needed. These factors and limitations include, but are not limited to, the rating agency and regulatory

views, which can change over time.


Changes in Investments in associates and joint ventures
in EUR million	2025	2024
Opening balance as at 1 January	1,679	1,509
Additions	1	26
Transfers	-29	-7
Revaluations	35	0
Share of results	209	205
Dividends received	-160	-91
Disposals	-66	-16
Impairments	-9	-35
Exchange rate differences	-54	87
Closing balance	1,607	1,679

Share of results from associates and joint ventures of EUR 209 million (2024: EUR 205 million) as included in the

table above is mainly attributable to our share in the results of TTB of EUR 136 million (2024: EUR 123 million)

and a EUR 44 million gain from the sale of an associate in Belgium, while 2024 included EUR 77 million as our

share in the result of an associate in Belgium following a one-off profit.

Impairments and reversal thereof on the investment in TTB

Accumulated impairments on the investment in TTB of EUR 395 million (2024: EUR 395 million) were recognised in

previous years. There is no impairment trigger observed as per 31 December 2025. A Value in Use ('VIU') was


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-255

estimated following the prolonged increase of the quoted TTB share price over the original cost price of the

investment and the sustained improved broker consensus outlook. As the VIU did not significantly exceed the

carrying amount of the investment in TTB, no reversal of impairment was recognised.

Methodology

The recoverable amount is determined as the higher of the fair value less costs of disposal and VIU. Fair value less

costs of disposal is based on observable share price. The VIU calculation uses discounted cash flow projections

based on management’s best estimates. VIU is derived using a Dividend Discount Model (DDM) where distributable

equity, i.e. future earnings available to ordinary shareholders, is used as a proxy for future cash flows. The

valuation looks at expected cash flows into perpetuity resulting in two main components to the VIU calculation:

§The estimation of future earnings over a 5-year forecast period; and

§The terminal value being the extrapolation of earnings into perpetuity applying a long-term growth rate. The

earnings that are used for extrapolation represent the stable long-term financial results and position of TTB, i.e.

a steady state. The terminal value comprises the majority of the total VIU.

Key assumptions used in the VIU calculation as at 31 December 2025

The VIU is determined using a valuation model which is subject to multiple management assumptions. The key

assumptions, i.e. those to which the overall result is most sensitive to, are the following:

•Expected future earnings of TTB: Short- to medium-term expectations are based on forecasts derived from

broker consensus. Longer-term and steady-state expectations into perpetuity are derived using reasonable

and supportable assumptions capturing a combination of TTB specific and market data points; A capital

maintenance charge is applied, which is management’s forecast of the earnings that need to be withheld in

order for TTB to meet target regulatory requirements over the forecast period;

•Discount rate (cost of equity): 10.17% (2024: 10.96%), based on the capital asset pricing model (CAPM)

calculated for TTB using current market data and expert judgement; and

•Terminal growth rate: 2.41% (2024: 2.74%) consistent with current long term government bond yield in

Thailand as a proxy for a risk-free rate.

The model was evaluated for reasonably possible changes to key assumptions in the model. This reflects the

sensitivity of the VIU to each key assumption on its own and it is possible that more than one favourable and/or

unfavourable change may occur at the same time. The selected rates of reasonably possible changes to key

assumptions are based on external analysts’ forecasts and other relevant external data sources, which can change

period to period. The sensitivity of the VIU to each key assumption is as follows:

•A favourable change of 10% in the cash flows would result in an increase in VIU of EUR 89 million (2024: EUR

57 million), while an unfavourable change of -10% would result in a decrease in VIU of EUR -90 million (2024:

EUR -59 million);

•A favourable change of 1% in the discount rate would result in an increase in VIU of EUR 159 million (2024: EUR

95 million), while an unfavourable change of -1% would result in a decrease in VIU of EUR -122 million (2024:

EUR -75 million);

•A favourable change of 1% in the terminal growth rate would result in an increase in VIU of EUR 118 million

(2024: EUR 68 million), while an unfavourable change of -1% would result in a decrease in VIU of EUR -90

million (2024: EUR -53 million).

9 Property and equipment


Property and equipment by type
in EUR million	2025	2024
Property in own use	863	758
Equipment:
- Data processing equipment	197	218
- Other equipment	447	426
Right- of- use assets:
- ROU property	837	895
- ROU cars	123	124
- ROU other leases	12	13
	2,478	2,434


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-256


Changes in property and equipment
	Property in own use		Equipment		Right-of-use assets		Total
in EUR million	2025	2024	2025	2024	2025	2024	2025	2024
Opening balance as at 1 January	758	616	643	705	1,033	1,078	2,434	2,399
Additions	147	92	203	240	160	141	510	473
Transfers	-15	83	11	-78		-4	-3	1
Depreciation	-11	-11	-194	-204	-237	-242	-442	-457
Impairments1	-8	-9	-6	-10	-3	-4	-16	-23
Reversals of impairments 1	6	5					7	5
Remeasurements	15	5			40	75	56	80
Disposals	-28	-36	-11	-14	-10	-18	-48	-68
Exchange rate differences	-3	13	-3	5	-12	8	-18	25
Closing balance	863	758	644	643	972	1,033	2,478	2,434

Cost price	994	871	2,827	3,027	1,982	1,933	5,803	5,831
Accumulated depreciation	-299	-298	-2,176	-2,376	-1,237	-1,098	-3,712	-3,772
Accumulated impairments	-95	-97	-7	-8	-31	-31	-134	-136
Accumulated revaluation surplus	264	282					264	282
Accumulated remeasurement					258	229	258	229
Net carrying value	863	758	644	643	972	1,033	2,478	2,434

1Impairments and reversals of impairments of property and equipment are presented as Other operating expenses in the statement of Profit or Loss.

ING considers valuations from third-party experts in determining the fair values of property in own use. The vast

majority of the land and buildings were appraised during 2025. Property in own use purchase costs amounted to

EUR 994 million (2024: EUR 871 million). Cost or the purchase price less accumulated depreciation and

impairments would have been EUR 599 million (2024: EUR 476 million) had property in own use been valued at

cost instead of at fair value.

10 Intangible assets


Changes in intangible assets
	Goodwill		Software		Other		Total
in EUR million	2025	2024	2025	2024	2025	2024	2025	2024
Opening balance as at 1 January	476	469	855	727	3	2	1,334	1,198
Additions		6	35	43		1	35	50
Capitalised expenses			380	324			380	324
Amortisation			-223	-215			-223	-216
Impairments 1			-7	-12			-7	-12
Exchange rate differences	1	1	-10	8			-9	9
Disposals			-2	-9			-2	-9
Other changes			2	-10	1		2	-10
Closing balance	477	476	1,030	855	3	3	1,510	1,334

Gross carrying amount	477	476	3,281	2,986	9	8	3,767	3,471
Accumulated amortisation			-2,197	-2,079	-4	-4	-2,201	-2,084
Accumulated impairments			-53	-52	-1	-2	-55	-53
Net carrying value	477	476	1,030	855	3	3	1,510	1,334

1 Impairments of intangible assets are presented within Other operating expenses in the statement of Profit or Loss.

Goodwill

Goodwill is allocated to groups of cash generating units (CGUs) as follows:


Goodwill allocation to group of CGUs
in EUR million	Method used for recoverable amount	Discount rate		Terminal growth rate		Goodwill
Group of CGUs		2025	2024	2025	2024	2025	2024
Retail Netherlands	Value in use	7.20%	7.81%	2.00%	2.00%	30	30
Retail Germany	Value in use	7.20%	7.77%	2.20%	2.00%	356	356
Retail Poland	Value in use	8.76%	9.30%	2.50%	2.50%	77	76
Retail Romania	Value in use	10.86%	11.45%	2.60%	3.00%	14	15
						477	476


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-257

Impairment testing

Goodwill is tested for impairment annually in the fourth quarter by comparing the recoverable amount of each

goodwill-carrying CGU with its carrying amount. The key assumptions used in the calculation of the recoverable

amounts are included in the table above. Furthermore, ING Group tests goodwill whenever a triggering event is

identified. In 2025, no triggering events were identified.

At the annual impairment test in the fourth quarter, the recoverable amount exceeds the carrying value of the

CGUs as at 31 December 2025 and therefore no impairment is required (31 December 2024: nil).

Methodology

The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use (VIU).

The VIU calculation is based on a Dividend Discount model using three-year management-approved plans,

updated for expected changes in the macroeconomic environment. When estimating the VIU of a CGU, local

conditions and requirements determine the capital requirements, discount rates, and terminal growth rates. These

local conditions and requirements determine the ability to upstream excess capital and profits to ING Group. The

discount rate calculation includes other inputs such as equity market premium, country risk premium, and long-

term inflation which are based on market sources and management’s judgement. The long-term growth rate is

based on the long-term inflation rate obtained from market sources. The impacts of climate risk are included to

the extent that they are observable in discount rates and assets prices.

Sensitivity of key assumptions

Key assumptions in the goodwill impairment test model are the projected locally available cash flows (based on

local capital requirements and projected profits), discount rates (cost of equity), and long-term growth rates.

The recoverable amounts of the CGUs are sensitive to the above key assumptions. A decrease in the available cash

flows of 10%, an increase in the discount rate of 1 percent point or a reduction of the future growth rate to zero

are considered reasonably possible changes in key assumptions. If the aforementioned changes occur to one of

the above key assumptions holding the other key assumptions constant, goodwill of the remaining CGUs will

continue to be recoverable.

Software

Software includes internally developed software amounting to EUR 956 million (2024: EUR 768 million). Software

capitalisation amounts increased in 2025 following the significant IT-platform investments in our Retail business.

Software is reviewed for indicators of impairment. Irrespective of whether there is an indication of impairment,

software under development is tested annually for impairment.

11 Other assets


Other assets by type
in EUR million	2025	2024
Assets held for sale	164	0
Net defined benefit assets	528	568
Investment properties	27	19
Property development and obtained from foreclosures	17	18
Prepayments	829	413
Accrued assets	480	499
Amounts to be settled	4,076	3,550
Other	1,853	1,879
	7,975	6,945

Disclosures in respect of Net defined benefit assets are provided in Note 33 'Pensions and other post-employment

benefits'.

Amounts to be settled include primarily transactions not settled at the balance sheet date. The nature of these

transactions is short term and they are expected to settle shortly after the closing date of the balance sheet. Other

relates to various receivables in the normal course of business, including short-term receivables from mortgages

issued to notary accounts pending transfer to customers and other amounts receivable from customers.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-258

12 Deposits from banks


Deposits from banks by type
	Netherlands		Rest of the world		Total
in EUR million	2025	2024	2025	2024	2025	2024
Non-interest bearing	2	5	115	166	117	171
Interest bearing	6,438	5,845	11,962	10,707	18,400	16,553
	6,440	5,850	12,077	10,873	18,517	16,723

Deposits from banks includes non-subordinated deposits and, to a lesser extent, repurchase transactions. For more

information on reverse repurchase transactions, refer to Note 4 'Financial assets at fair value through profit or loss'.

13 Customer deposits


Customer deposits
in EUR million	2025	2024
Current accounts / Overnight deposits	238,940	227,827
Savings accounts	382,066	354,560
Time deposits	98,599	107,695
Other	1,768	1,579
	721,373	691,661

Current accounts / Overnight deposits, Savings accounts and Time deposits include balances with individuals,

respectively EUR 113,586 million (2024: EUR 107,068 million), EUR 347,234 million (2024: EUR 324,135 million)

and EUR 50,033 million (2024: EUR 56,599 million).


Customer deposits by type
	Netherlands		Rest of the world		Total
in EUR million	2025	2024	2025	2024	2025	2024
Non-interest bearing	3	26	30,036	27,142	30,039	27,168
Interest bearing 1	246,230	237,395	445,104	427,098	691,334	664,493
	246,233	237,421	475,140	454,240	721,373	691,661

1 Interest bearing includes current accounts which are not remunerated. However, ING holds the contractual right to revise the rates.

14 Financial liabilities at fair value through profit or loss


Financial liabilities at fair value through profit or loss
in EUR million	2025	2024
Trading liabilities	23,427	35,255
Non-trading derivatives	1,338	2,101
Designated at fair value through profit or loss	55,768	49,543
	80,532	86,900

Trading liabilities


Trading liabilities by type
in EUR million	2025	2024
Equity securities	682	467
Debt securities	1,872	3,185
Funds on deposit	191	5,437
Derivatives	20,681	26,166
	23,427	35,255

Non-trading derivatives


Non-trading derivatives by type
in EUR million	2025	2024
Derivatives used in:
- fair value hedges	54	79
- cash flow hedges	254	573
- hedges of net investments in foreign operations	74	117
Other non-trading derivatives	957	1,332
	1,338	2,101

Reference is made to Note 36 'Derivatives and hedge accounting' for information on derivatives used for hedge

accounting.

Other non-trading derivatives mainly include interest-rate swaps, foreign-exchange swaps and cross-currency

swaps for which no hedge accounting is applied.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-259

Designated at fair value through profit or loss


Designated at fair value through profit or loss by type
in EUR million	2025	2024
Debt securities	8,707	9,844
Funds entrusted	46,930	39,577
Subordinated liabilities	131	122
	55,768	49,543

As at 31 December 2025, the change in the fair value of financial liabilities designated at fair value through profit

or loss attributable to changes in credit risk is EUR 57 million on a cumulative basis (2024: EUR 17 million). This

change has been determined as the amount of change in fair value of the financial liability that is not attributable

to changes in market conditions that gave rise to market risk (i.e. mainly interest-rate risk based on yield curves).

The amount that ING Group is contractually required to pay at maturity to the holders of financial liabilities

designated at fair value through profit or loss excluding repurchase agreements (part of funds entrusted) is EUR

9,574 million (2024: EUR 11,376 million).

Funds entrusted include mainly repurchase agreements. For more information on repurchase transactions, refer

to Note 4 'Financial assets at fair value through profit or loss'.

15 Provisions


Provisions by type
in EUR million	2025	2024
Reorganisation provisions	333	201
Litigation provisions	362	288
Other provisions	105	139
	800	628
Loan loss provisions for guarantees and loan commitments	141	146
	941	774

For details and changes on loan loss provisioning for guarantees and loan commitments, refer to ‘Risk

management – Credit risk’ paragraph 'Loan loss provisioning'.


Changes in provisions
	Reorganisation		Litigation		Other provisions		Total
in EUR million	2025	2024	2025	2024	2025	2024	2025	2024
Opening balance as at 1 January	201	231	288	193	139	355	628	779
Additions 1	295	146	128	116	35	26	457	288
Releases 1	-6	-4	-9	-15	-13	-46	-28	-64
Utilised	-146	-163	-45	-31	-58	-196	-248	-390
Exchange rate differences	-5		1	1	-1	-1	-5
Other changes	-5	-10	-2	25	2	1	-4	16
Closing balance	333	201	362	288	105	139	800	628

1Additions to provisions and unused amounts released are presented in Note 26 'Other operating expenses' in the Statement of Profit

or Loss.

As at 31 December 2025, amounts expected to be settled within 12 months in provisions amount to EUR

694 million (2024: EUR 574 million). The amounts included are based on best estimates with regard to amounts

and timing of cash flows required to settle the obligation.

Reorganisation provisions

Reorganisation initiatives are implemented over a period of several years and the estimate of the reorganisation

provisions is inherently uncertain.

Litigation provisions

Furthermore, we refer to Note 42 'Legal proceedings' for any contingent liabilities in respect of legal proceedings.

Other provisions

In 2024, the utilisations in the Other provisions mainly relate to the provision for the compensation of Dutch retail

customers for past interest charges that did not sufficiently track market rates.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-260

16 Other liabilities


Other liabilities by type
In EUR million	2025	2024
Net defined benefit liability	141	152
Other post-employment benefits	42	38
Other staff-related liabilities	798	784
Other taxation and social security contributions	837	899
Rents received in advance	15	14
Costs payable	2,021	1,764
Amounts to be settled	4,188	4,290
Lease liabilities	1,050	1,116
Other	2,898	3,311
	11,989	12,369

Disclosures in respect of Net defined benefit liabilities are provided in Note 33 'Pensions and other post-

employment benefits'. Other staff-related liabilities comprise provisions for vacation leave, jubilee, disability and

illness, as well as liabilities for variable compensations.

Lease liabilities relate to right-of-use assets. Disclosures regarding right-of-use assets are provided in Note 9

'Property and equipment'. The total cash outflow for leases in 2025 was EUR 282 million (2024: EUR 290 million).

Amounts to be settled include primarily transactions not settled at the balance sheet date. The nature of these

transactions is short term and have settled after the closing date of the balance sheet. The line Other relates

mainly to amounts payable to suppliers. It also includes the remaining EUR 732 million (2024: EUR 1,275 million)

obligation related with share buyback programme.

17 Debt securities in issue

Debt securities in issue relate to debentures and other issued debt securities with either fixed interest rates or

interest rates based on floating interest rate levels, such as certificates of deposit and accepted bills issued by ING

Group, except for subordinated items. Debt securities in issue do not include debt securities presented as Financial

liabilities at fair value through profit or loss. ING Group does not have debt securities that are issued on terms other

than those available in the normal course of business.


Debt securities in issue – maturities
In EUR million	2025	2024
Fixed rate debt securities
Within 1 year	34,021	27,333
More than 1 year but less than 2 years	10,392	13,085
More than 2 years but less than 3 years	13,898	10,857
More than 3 years but less than 4 years	12,624	13,300
More than 4 years but less than 5 years	13,093	12,201
More than 5 years	28,731	30,640
Total fixed rate debt securities	112,760	107,416

Floating rate debt securities
Within 1 year	28,774	26,262
More than 1 year but less than 2 years	1,761	2,821
More than 2 years but less than 3 years	830	1,939
More than 3 years but less than 4 years	1,688	117
More than 4 years but less than 5 years	913	902
More than 5 years	4,506	2,910
Total floating rate debt securities	38,472	34,951

Total debt securities	151,231	142,367

Reference is made to the Consolidated statement of cash flows for more information on issuances, redemptions

and non-cash movements.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-261

18 Subordinated loans


Subordinated loans
In EUR million	2025	2024
Subordinated loans	18,100	17,878

Subordinated loans are bonds issued by ING Groep N.V. and its subsidiaries to raise Tier 1 and Tier 2 (CRR-eligible)

capital. Under IFRS these securities are classified as liabilities, and for regulatory purposes they are considered as

capital.

In 2025 ING Groep N.V. issued EUR 1.25 billion 4.13% Fixed Rate Subordinated Green Tier 2 Notes in May, EUR

1.25 billion 3.88% Fixed Rate Subordinated Tier 2 Notes in August and USD 1.50 billion 7.00% Perpetual AT1

Contingent Convertible Capital Securities in September.

In 2025 ING Groep N.V. redeemed EUR 750 million 2.00% Fixed Subordinated Tier 2 notes in March, USD 1.25

billion 6.50% Perpetual AT1 Contingent Convertible Capital Securities in April and EUR 1 billion 1.00% Fixed

Subordinated Tier 2 notes in November.

Reference is made to the Consolidated statement of cash flows for further information on issuances and

redemptions.

19 Equity


Total equity
In EUR million	2025	2024	2023
Share capital and share premium
- Share capital	30	31	35
- Share premium	17,116	17,116	17,116
	17,147	17,148	17,151

Other reserves
- Revaluation reserve: Equity securities at FVOCI	1,444	1,816	1,152
- Revaluation reserve: Debt instruments at FVOCI	-41	-479	-280
- Revaluation reserve: Cash flow hedge	-1,096	-1,693	-2,058
- Revaluation reserve: Credit liability	-49	-15	31
- Revaluation reserve: Property in own use	156	161	178
- Net defined benefit asset/liability remeasurement reserve	-345	-333	-317
- Currency translation reserve	-2,774	-1,986	-2,527
- Share of associates and joint ventures and other reserves	2,031	2,607	3,047
- Treasury shares	-2,404	-765	-1,994
	-3,080	-687	-2,767

Retained earnings	40,016	36,243	40,299

Shareholders’ equity (parent)	54,083	52,703	54,684
Non-controlling interests	1,255	995	944
Total equity	55,339	53,698	55,628

Adjustments for hyperinflation

ING applies IAS 29 ‘Hyperinflation’ on its investment in Türkiye since 2022. The IAS 29 indexation impact on equity

was EUR 34 million (2024: EUR 50 million; 2023: EUR 54 million) of which EUR 123 million (2024: EUR 202 million;

2023: EUR 284 million) in the currency translation reserve, EUR 0 million (2024: EUR 4 million; 2023: EUR 3 million)

in revaluation reserves and EUR -89 million (2024: EUR -156 million; 2023: EUR -234 million) in profit or loss.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-262

Share capital and share premium


Share capital
				Ordinary shares (par value EUR 0.01)
	Number x 1,000			In EUR million
	2025	2024	2023	2025	2024	2023
Authorised share capital	9,142,000	9,142,000	9,142,000	91	91	91
Unissued share capital	6,120,457	5,994,609	5,643,806	61	60	56
Issued share capital	3,021,543	3,147,391	3,498,194	30	31	35


Changes in issued share capital
	Ordinary shares (par value EUR 0.01)
	Number x 1,000	In EUR million
Issued share capital as at 31 December 2022	3,726,539	37
Issue of shares	5
Cancellation of shares	-228,350	-2
Issued share capital as at 31 December 2023	3,498,194	35
Cancellation of shares	-350,803	-4
Issued share capital as at 31 December 2024	3,147,391	31
Cancellation of shares	-125,848	-1
Issued share capital as at 31 December 2025	3,021,543	30

In 2022, shares were issued in order to fund obligations arising from share-based employee incentive

programmes. As from 2023 these shares are repurchased from the market. The cancellation of shares relates to

the shares purchased under the share buyback programme which was completed in October 2025. For further

information, reference is made to 'Ordinary shares held by ING Group (treasury shares)'.

As at 31 December 2025 ING Groep N.V. has issued USD 9,000 million (2024: USD 8,750 million; 2023: USD 7,750

million) Perpetual Additional Tier 1 Contingent Convertible Capital Securities which can, in accordance with their

terms and conditions, convert by operation of law into ordinary shares if the conditions (when the Group CET1

ratio has fallen below 7.00%) to such a conversion are fulfilled. As a result of this conversion, the issued share

capital can increase by up to 1,014 million (2024: 982 million; 2023: 864 million) ordinary shares. Reference is

made to Note 18 'Subordinated loans'.

Ordinary shares

All ordinary shares are registered. No share certificates have been issued. The par value of ordinary shares is EUR

0.01. The authorised ordinary share capital of ING Groep N.V. currently consists of 9,142 million ordinary shares. As

at 31 December 2025, 3,022 million ordinary shares were issued and fully paid.

Ordinary shares held by ING Group (Treasury shares)

As at 31 December 2025, 119.1 million ordinary shares (2024: 51.1 million; 2023: 154.6 million) of ING Groep N.V.

with a par value of EUR 0.01 are held by ING Groep N.V. or its subsidiaries.

Share premium

No changes in 2025, 2024 and 2023.

Revaluation reserves


Changes in revaluation reserve: Equity securities and Debt instruments at FVOCI
	Equity securities at FVOCI			Debt instruments at FVOCI
	Equity securities at FVOCI			Debt instruments at FVOCI
In EUR million	2025	2024	2023	2025	2024	2023
Opening balance	1,816	1,152	1,187	-479	-280	-341
Unrealised revaluations	-366	664	-35	459	-261	53
Realised gains/losses transferred to the statement of profit or loss				-21	62	9
Realised revaluations transferred to retained earnings	-6		1
Closing balance	1,444	1,816	1,152	-41	-479	-280

Equity securities at FVOCI

In 2025, the unrealised revaluation of EUR -366 million (2024: EUR 664 million; 2023: EUR -35 million) includes

revaluation of shares in Bank of Beijing for EUR -403 million (2024: EUR 652 million; 2023: EUR -24 million).


Changes in cash flow hedge and credit liability reserve
	Cash flow hedge			Credit liability
	Cash flow hedge			Credit liability
In EUR million	2025	2024	2023	2025	2024	2023
Opening balance	-1,693	-2,058	-3,055	-15	31	70
Changes in credit liability reserve				-34	-46	-39
Unrealised revaluations	597	365	997
Closing balance	-1,096	-1,693	-2,058	-49	-15	31


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-263

Cash flow hedge

The increase in the cash flow hedge reserve, primarily related to floating rate lending with interest rate swaps, in

2025 (EUR 597 million) reflects the impact of changes in interest rates, pull-to-par effect and amortisation of de-

designated hedges. Reference is made to Note 36 'Derivatives and hedge accounting'.


Changes in Property in own use reserve
In EUR million	2025	2024	2023
Opening balance	161	178	176
Unrealised revaluations	7	3	10
Realised revaluations transferred to retained earnings	-12	-20	-8
Closing balance	156	161	178

Net defined benefit asset/liability remeasurement reserve

Reference is made to Note 33 'Pensions and other post-employment benefits'.

Currency translation reserve


Changes in currency translation reserve
In EUR million	2025	2024	2023
Opening balance	-1,986	-2,527	-2,395
Unrealised revaluations	637	-222	183
Realised gains/losses transferred to the statement of profit or loss		1
Exchange rate differences	-1,425	763	-316
Closing balance	-2,774	-1,986	-2,527

Unrealised revaluations relates to changes in the value of hedging instruments that are designated as net

investment hedges. The hedging strategy is to protect the CET1 ratio against adverse impact from exchange rate

fluctuations. The net decrease of unrealised revaluations and Exchange rate differences of EUR -789 million is

related to several currencies including USD (EUR -664 million), TRY (EUR -21 million including EUR 123 million IAS

29 indexation effect), GBP (EUR -64 million), PLN (EUR 29 million), UAH (EUR -16 million), AUD (EUR -69 million),

RUB (EUR 87 million), THB (EUR -19 million), RON (EUR -13 million) and other currencies (EUR -39 million).

Share of associates and joint ventures and other reserves


Changes in share of associates, joint ventures and other reserves
In EUR million	2025	2024	2023
Opening balance	2,607	3,047	3,603
Result for the year	14	125	336
Transfer to/from retained earnings	-590	-565	-892
Closing balance	2,031	2,607	3,047

The Share of associates, joint ventures and other reserves includes non-distributable profits from associates and

joint ventures of EUR 962 million (2024: EUR 940 million; 2023: EUR 815 million). Other reserves includes a

statutory reserve of EUR 108 million (2024: EUR 897 million; 2023: EUR 1,602 million) related to the former

Stichting Regio Bank and the former Stichting Vakbondsspaarbank SPN and a legal reserve of EUR 956 million

(2024: EUR 768 million; 2023: EUR 628 million) related to internally developed software. The transfer to retained

earnings of EUR -590 million includes the release of the Regio bank and Vakbondsspaarbank SPN reserve of EUR

-802 million (2024: EUR -830 million; 2023: EUR -998 million) against regulatory expenses which are recognised in

the statement of profit or loss.

Treasury shares


Changes in treasury shares
	In EUR million			Number x 1,000
	2025	2024	2023	2025	2024	2023
Opening balance	-765	-1,994	-1,205	51,117	154,571	107,395
Purchased/sold for trading purposes	6	2	-7	-480	-211	464
Purchased under staff share plans	-64	-43	-42	3,674	3,319	3,156
Distributed under staff share plans	60	43	41	-3,460	-3,343	-3,106
Purchased under Share buyback programme	-3,641	-3,774	-3,482	194,102	247,584	275,013
Cancelled under Share buyback programme	2,000	5,000	2,701	-125,848	-350,803	-228,350
Closing balance	-2,404	-765	-1,994	119,105	51,117	154,571

In 2025 ING Group initiated three share buyback programmes and completed one from 2024:

§EUR 2,000 million, commencing on 31 October 2024 and completed by 30 April 2025. A total of 126 million

shares have been repurchased at an average effective price of EUR 15.89 per share. The shares have been

cancelled in July 2025;

§EUR 70 million, commencing on 3 March 2025 and completed by 4 March 2025. A total of 4 million shares have

been repurchased at an average price of EUR 17.44 per share and for a total consideration of EUR 64 million.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-264

The purpose of the share repurchase programme was to meet obligations under the share-based

compensation plans;

§EUR 2,000 million, commencing on 2 May 2025 and completed by 27 October 2025. A total of 101 million

shares have been repurchased at an average effective price of EUR 19.76 per share. The shares have been

cancelled in January 2026;

§EUR 1,100 million, commencing on 30 October 2025 and expected to be completed before 27 April 2026. As per

31 December 2025 a total of 18 million shares have been repurchased at an average price of EUR 22.62 per

share and for a total consideration of EUR 397 million. ING has the intention to cancel these shares in June

2026.

Retained earnings


Changes in retained earnings
In EUR million	2025	2024	2023
Opening balance	36,243	40,299	41,538
Impact on opening balance1			-45
Transfer to/from other reserves	616	585	899
Result for the year	8,310	5,209	3,804
Dividend and other distributions	-3,691	-4,124	-2,668
Employee share plans	-8	1	-7
Share buybacks and other changes	-1,453	-5,728	-3,222
Closing balance	40,016	36,243	40,299

1In 2023, changes in policy following the adoption of IFRS 17 and change in policy for non-financial guarantees.

Dividend and other distributions

In 2025, a cash dividend of EUR 3,191 million (2024: EUR 3,626 million; 2023: EUR 2,668 million) and in January

2026 an additional cash distribution of EUR 500 million (2024: EUR 498 million; 2023: EUR 0 million) were paid to

the shareholders of ING Group. For further information, reference is made to Note 29 'Dividend per ordinary share'.

Share buybacks and other changes

Share buybacks and other changes includes an amount of EUR -1,458 million (2024: EUR -5,723 million; 2023: EUR

-3,217 million), which corresponds to the purchase and cancellation of treasury shares purchased under the share

buyback programmes.

Ordinary shares - Restrictions with respect to dividend and repayment of capital

The following equity components cannot be freely distributed: Revaluation reserves, Net defined benefit asset/

liability remeasurement reserve, Currency translation reserve, Share of associates and joint ventures reserve and

Other reserves including the reserve related to the former Stichting Regio Bank and the former Stichting

Vakbondsspaarbank SPN.

ING Groep N.V. is subject to legal restrictions regarding the amount of dividends it can pay to the holders of its

ordinary shares. Pursuant to the Dutch Civil Code, dividends can only be paid up to an amount equal to the excess

of the company’s own funds over the sum of the paid-up capital and reserves required by law.

Moreover, ING Groep N.V.’s ability to pay dividends is dependent on the dividend payment ability of its subsidiaries,

associates and joint ventures. ING Groep N.V. is legally required to create a non-distributable reserve insofar as

profits of its subsidiaries, associates and joint ventures are subject to dividend payment restrictions which apply to

those subsidiaries, associates and joint ventures themselves.

Non-distributable reserves, determined in accordance with the financial reporting requirements included in Part 9

of Book 2 of the Dutch Civil Code, from ING Group’s subsidiaries, associates and joint ventures are as follows:


Non-distributable reserves
In EUR million	2025	2024	2023
ING Bank	6,225	5,672	6,727
Other	0	0	0
Non-distributable reserves	6,225	5,672	6,727

In addition to the legal and regulatory restrictions on distributing dividends from subsidiaries, associates and joint

ventures to ING Groep N.V. there are various other considerations and limitations that are taken into account in

determining the appropriate levels of equity in the Group’s subsidiaries, associates and joint ventures. These

considerations and limitations include, but are not restricted to, minimum capital requirements that are imposed

by industry regulators in the countries in which the subsidiaries, associates and joint ventures operate, or other

limitations which may exist in certain countries and may or may not be temporary in nature. It is not possible to

disclose a reliable quantification of these limitations. Without prejudice to the authority of the Executive Board to

allocate profits to reserves and to the fact that the ordinary shares are the most junior securities issued by ING

Groep N.V., no specific dividend payment restrictions with respect to ordinary shares exist.

Furthermore, ING Groep N.V. is subject to legal restrictions with respect to repayment of capital to holders of

ordinary shares. Pursuant to the Dutch Civil Code, capital may only be repaid if none of ING Groep N.V.’s creditors

opposes such a repayment within two months following the announcement of a resolution to that effect.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-265

Cumulative preference shares (not issued)

Pursuant to the Articles of Association of ING Groep N.V. the authorised cumulative preference share capital

consists of 4.6 billion cumulative preference shares, of which none have been issued. The par value of these

cumulative preference shares is EUR 0.01. A right to acquire cumulative preference shares has been granted to

Stichting Continuïteit ING (ING Continuity Foundation).

The cumulative preference shares rank before the ordinary shares in entitlement to dividend and to distributions

upon liquidation of ING Groep N.V.

The dividend on the cumulative preference shares will be equal to a percentage, calculated on the amount

compulsorily paid up or yet to be paid up. This percentage shall be equal to the average of the euro short-term

rate (€STR) as calculated by the European Central Bank during the financial year for which the distribution is made;

this percentage being weighted on the basis of the number of days for which it applies, and increased by 2.585

percentage points.

If, and to the extent that, the profit available for distribution is not sufficient to pay the dividend referred to above

in full, the shortfall will be made up from the reserves insofar as possible. If, and to the extent that, the dividend

distribution cannot be made from the reserves, the profits earned in subsequent years shall first be used to make

up the shortfall before any distribution may be made on shares of any other category.

ING Groep N.V.’s Articles of Association make provision for the cancellation of cumulative preference shares. Upon

cancellation of cumulative preference shares and upon liquidation of ING Groep N.V., the amount paid up on the

cumulative preference shares will be repaid together with the accrued dividend as well as any dividend shortfall in

preceding years, insofar as this shortfall has not yet been made up. No specific dividend payment restrictions with

respect to the cumulative preference shares exist.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-266

Notes to the Consolidated statement of profit or loss

20 Net interest income


Net interest income
in EUR million	2025	2024	2023		2025	2024	2023
Interest income on loans1	30,961	34,146	32,021	Interest expense on deposits2	12,843	15,105	11,940
Interest income on debt securities at amortised cost	1,333	1,204	877	Interest expense on debt securities in issue	5,105	5,254	4,014
Interest income on financial assets at fair value through OCI	1,790	1,481	1,078	Interest expense on subordinated loans	813	753	708
Interest income on non-trading derivatives (hedge accounting)	9,676	12,644	10,682	Interest expense on non-trading derivatives (hedge accounting)	10,957	13,767	11,849
Total interest income using effective interest rate method	43,760	49,474	44,658	Total interest expense using effective interest rate method	29,718	34,878	28,510

Interest income on financial assets at fair value through profit or loss	5,401	6,343	4,934	Interest expense on financial liabilities at fair value through profit or loss	4,419	5,479	4,410
Interest income on non-trading derivatives (no hedge accounting)	2,044	3,168	2,637	Interest expense on non-trading derivatives (no hedge accounting)	2,059	3,308	3,131
Interest income other	123	173	171	Interest expense on lease liabilities	27	27	28
Total other interest income	7,568	9,685	7,741	Interest expense other	148	178	157
				Total other interest expense	6,653	8,993	7,726

Total interest income	51,327	59,159	52,399	Total interest expense	36,371	43,871	36,237

				Net interest income	14,957	15,288	16,162

1Includes interest income on loans to customers and banks, cash balances as well as negative interest on liabilities. Negative interest on liabilities amounted to EUR 11 million (2024: EUR 7 million; 2023: EUR 19 million).

2Includes interest paid on deposits from customers and banks, and negative interest on assets. Negative interest on assets amounted to EUR 12 million (2024: EUR 1 million; 2023: nil).

Net interest income was affected by reversing the hedge accounting impacts that are applied under EU ‘IAS 39

carve-out’ with an impact of EUR 276 million (2024: EUR 265 million; 2023: EUR 187 million). The net decrease,

without the IAS 39 carve out impact, is EUR 342 million.

For 2024 Interest expense on deposits includes interest paid under the TLTRO III programme of EUR 59 million

(2023: EUR 557 million). The funding under this programme was fully repaid during the first quarter of 2024.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-267

21 Net fee and commission income


Net fee and commission income
in EUR million	2025	2024	2023
Fee and commission income
Payment Services	2,478	2,219	2,062
Securities business	922	734	584
Insurance and other broking	650	594	529
Portfolio management	796	699	625
Lending business	727	650	602
Financial guarantees and other commitments	461	454	459
Other fee and commission income	264	255	248
Total fee and commission income	6,297	5,604	5,109

Fee and commission expenses
Payment Services	858	756	704
Securities business	170	147	128
Distribution of products	457	475	480
Other fee and commission expenses	210	218	202
Total fee and commission expenses	1,696	1,596	1,514

Net fee and commission income	4,602	4,008	3,595

Payment services fees are earned for providing services for deposit accounts and cards, cash management and

transaction processing including interchange. Securities fees and commissions are fees for securities brokerage

and securities underwriting. Portfolio management fees include fees earned for asset management activities,

fiduciary and related activities in which ING holds or invests assets on behalf of its customers. Fees and

commissions from lending (syndication) business include income earned for lending advisory, origination,

underwriting and loan commitments which are not part of the effective interest rate. Financial guarantees and

other commitments fees and commissions are earned from bank guarantees, letters of credit and other trade

finance related products, factoring and leasing. Fees paid for distribution of products are all fees paid for the

distribution of ING’s products and services through external providers.

Reference is made to Note 30 'Segments', which includes net fee and commission income, as reported to the

Executive Board and the Management Board Banking, disaggregated by segment.

22 Valuation results and net trading income


Valuation results and net trading income
in EUR million	2025	2024	2023
Securities trading results	4,801	996	873
Derivatives trading results	-3,053	207	116
Other trading results	263	336	273
Change in fair value of derivatives relating to
– fair value hedges	1,111	1,016	1,606
– cash flow hedges (ineffective portion)	10	35	48
– other non-trading derivatives	1,550	140	-4,071
Change in fair value of assets and liabilities (hedged items)	-1,078	-1,043	-1,679
Valuation results on assets and liabilities designated at FVPL (excluding trading)	8	32	-128
Foreign exchange transactions results	2,175	-105	1,230
	5,789	1,614	-1,732

In general, the fair value movements are influenced by changes in the market conditions, such as stock prices,

credit spreads, interest rates and currency exchange rates. In 2025, the interest rate volatility resulted in a

positive EU IAS39 carve out adjustment of EUR 2,367 million (2024: EUR -1,793 million; 2023: EUR -4,642 million).

Net trading income relates to trading assets and trading liabilities which include assets and liabilities that are

classified under IFRS as Trading but are closely related to servicing the needs of the clients of ING. ING offers

products that are traded on the financial markets to institutional clients, corporate clients, and governments. ING’s

trading books are managed based on internal limits and comprise a mix of products whose results may neutralise

one another. A significant part of the derivatives in the trading portfolio are related to servicing corporate clients in

their risk management to hedge for example currency or interest rate exposures. From a risk perspective, the

gross amount of trading assets must be considered together with the gross amount of trading liabilities, which are

presented separately on the statement of financial position. However, IFRS does not always allow the netting of

these positions in the statement of financial position. Reference is made to Note 4 'Financial assets at fair value

through profit or loss' and Note 14 'Financial liabilities at fair value through profit or loss' for information on trading

assets and trading liabilities respectively.

Securities trading results include the results of market making in instruments such as government securities,

equity securities, corporate debt securities, and money-market instruments. The majority of the risks involved in

security and currency trading are economically hedged with derivatives. The securities trading results are partly

offset by results on these derivatives. Derivatives trading results include the results of derivatives such as interest


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-268

rate swaps, options, futures, and forward contracts. Trading gains and losses relating to trading securities still held

as at 31 December 2025 amount to EUR 1,219 million (2024: EUR 20 million; 2023: EUR 160 million).

Other trading results include the results of trading loans and funds entrusted.

Foreign-exchange transactions results include gains and losses from spot, options, futures, and translated foreign

currency assets and liabilities. The result on currency trading is included in foreign exchange transactions results.

Valuation results and net trading income include the fair value movements on derivatives (used for both hedge

accounting and economically hedging exposures) as well as the changes in the fair value of assets and liabilities

included in hedging relationships as hedged items. In 2025, fluctuations in interest rate had a significant impact on

the fair value changes of both the derivatives and the hedged items designated in fair value hedges. Reference is

made to Note 36 'Derivatives and hedge accounting' for information on derivatives used for hedge accounting.

Furthermore, derivatives trading results are also impacted by fair value movements arising from changes in credit

spreads (CVA and DVA), bid offer spreads, model risk and incremental cost of funding on derivatives (FVA and

CollVA). Refer to Note 35 'Fair value of assets and liabilities' for information on these valuation adjustments.

23 Investment income


Investment income
in EUR million	2025	2024	2023
Dividend income	116	117	105
Realised gains/losses on disposal of debt instruments measured at FVOCI	28	-104	-11
Other investment income	-15
	129	13	95

Dividend income mainly consists of dividend received from ING’s equity stake in Bank of Beijing.

24 Other net income


Other net income
in EUR million	2025	2024	2023
Net monetary loss reflecting IAS 29 hyperinflation impact	-84	-159	-244
Income related to a prior insolvency of a financial institution in the Netherlands	16	53
Sale of the remaining NNHB mortgages		21
Other	70	82	97
	3	-3	-147

The net monetary loss, reflecting the IAS 29 hyperinflation impact, is fully related to the indexation of ING Türkiye's

statement of financial position and statement of profit or loss with an offsetting effect in the currency translation

reserve.

25 Staff expenses


Staff expenses
in EUR million	2025	2024	2023
Salaries	5,277	4,906	4,559
Pension costs and other staff-related benefit costs	488	455	418
Social security costs	752	690	635
Share-based compensation arrangements	52	45	31
External employees	662	720	776
Education	56	49	50
Other staff costs	313	319	256
	7,600	7,184	6,725

Share-based compensation arrangements include EUR 52 million (2024: EUR 45 million; 2023: EUR 31 million)

relating to equity-settled share-based payment arrangements.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-269


Number of employees
	Netherlands			Rest of the world			Total
	2025	2024	2023	2025	2024	2023	2025	2024	2023
Total average number of internal employees at full time equivalent basis	15,280	14,821	14,449	47,490	46,301	44,985	62,770	61,121	59,434

Remuneration of senior management, Executive Board and Supervisory Board

Reference is made to Note 45 'Related parties'.

Share plans

ING grants various types of share awards, namely deferred and upfront shares, which form part of the variable

remuneration offering via the Long-term Sustainable Performance Plan (LSPP). The entitlement to the LSPP share

awards is granted conditionally. If the participant remains in employment for an uninterrupted period between the

grant date and the vesting date, the entitlement becomes unconditional, with the exception of the upfront shares

which are immediately vested upon grant. Upfront and deferred shares awarded to the Executive Board and

Management Board members of ING Group as well as identified staff, have a retention obligation that must be

adhered to upon vesting, typically a minimum retention of 12 months applies for staff and up to 60 months for

Board. ING has the authority to apply a holdback to awarded but unvested shares and a clawback to vested

shares.

The share awards granted in 2025 relate to the performance year 2024. In 2025, 48,224 share awards (2024:

59,490; 2023: 52,693) were granted to the members of the Executive Board of ING Groep N.V., and 97,248 share

awards (2024: 121,504; 2023: 172,103) were granted to the Management Board Banking. To senior management

and other employees 3,876,388 share awards (2024: 4,248,400; 2023: 3,244,951) were granted.

The shares granted under the Share Based Compensation Plans create obligations for ING Group that require

funding. Starting in 2023, shares are purchased from the market to fund the obligations arising out of the awards

granted under the share plans.


Changes in share awards
	Share awards (in numbers)			Weighted average grant date fair values (in euros)
	2025	2024	2023	2025	2024	2023
Opening balance as at 1 January	4,855,542	3,897,800	3,699,555	10.88	8.81	7.97
Granted	4,021,860	4,429,394	3,469,747	17.57	13.75	9.71
Vested	-3,448,317	-3,343,429	-3,113,115	14.67	12.29	8.83
Forfeited	-138,970	-128,223	-158,387	13.99	10.73	8.54
Closing balance	5,290,115	4,855,542	3,897,800	13.44	10.88	8.81

As at 31 December 2025, there were 5,290,115 share awards outstanding (2024: 4,855,542; 2023: 3,897,800).

These all are related to equity-settled share-based payment arrangements, as cash-settled share-based payment

arrangements were terminated in 2023.

The fair value of share awards granted is recognised as an expense under Staff expenses and is allocated over the

vesting period of the share awards. The fair value calculation takes into account the current share prices, expected

volatilities and the dividend yield of ING shares.

As at 31 December 2025, total unrecognised compensation costs related to share awards amount to EUR 33

million (2024: EUR 25 million; 2023: EUR 15 million). These costs are expected to be recognised over a weighted

average period of 2.0 years (2024: 2.0 years; 2023: 2.0 years).


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-270

26 Other operating expenses


Other operating expenses
in EUR million	2025	2024 1	2023 1
Promotional and clients acquisition costs	443	441	369
IT related expenses (excluding outsourcing and subcontracting)	768	694	653
Outsourcing and subcontracting	697	664	579
Facilities	271	277	289
Market data services	153	136	120
Advisory fees	298	321	299
Audit and supervisory fees	142	142	123
Indirect taxes	208	235	107
Regulatory costs	866	882	1,042
Depreciation and impairment of property and equipment 9	451	475	493
Amortisation and impairment of intangible assets 10	230	228	218
Additions and releases of provisions 15	322	219	243
Other	134	223	303
	4,984	4,937	4,839

1ING changed the presentation of Other operating expenses as of 2025. The comparative figures for 2024 and 2023 have been updated accordingly. The

reclassifications do not affect the total amount of Other operating expenses.

Reference is made to Note 9 'Property and equipment' for (reversals of) impairments of property and equipment

and Note 10 'Intangible assets' for (reversals of) impairments of intangible assets.

For more information on addition to (unused amounts reversed of) provision for reorganisations refer to Note 15

'Provisions' and for more information on addition to (unused amounts reversed of) other provisions refer to Note

15 'Provisions' and Note 42 'Legal proceedings'.

Regulatory costs

Regulatory costs represent contributions to the Deposit Guarantee Schemes (DGS), the Single Resolution Fund

(SRF), local bank taxes and local resolution funds. Included in Regulatory costs for 2025, are contributions to DGS of

EUR 167 million (2024: EUR 230 million; 2023: EUR 320 million) mainly related to Belgium, Poland, Germany and

the Netherlands and contributions to the SRF and local resolution funds of EUR 41 million (2024: EUR 35 million;

2023: EUR 251 million). In 2025 local bank taxes increased by EUR 41 million from EUR 617 million in 2024 to EUR

657 million (2023: EUR 472 million).

27 Audit fees

Total audit and non-audit services include the following fees for services provided by the Group’s auditor.


Fees of Group’s auditor
in EUR million	2025	2024	2023
Audit fees	32	33	29
Audit related fees	4	4	1
Total1	36	37	30

1The Group’s auditor did not provide any non-audit services.

Fees as disclosed in the table above relate to the network of the Group’s auditors and are the total fees charged for

the period excluding VAT.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-271

28 Earnings per ordinary share


Earnings per ordinary share
				Weighted average number
				of ordinary shares outstanding
	Amount			during the period			Per ordinary share
	(in EUR million)			(in millions)			(in EUR)
	2025	2024	2023	2025	2024	2023	2025	2024	2023
Basic earnings	8,324	5,334	4,140	2,989.7	3,228.7	3,562.9	2.78	1.65	1.16
Basic earnings from continuing operations	8,324	5,334	4,140				2.78	1.65	1.16

Effect of dilutive instruments:
Share plans				0.0	0.0	2.4
				0.0	0.0	2.4

Diluted earnings	8,324	5,334	4,140	2,989.7	3,228.7	3,565.3	2.78	1.65	1.16
Diluted earnings from continuing operations	8,324	5,334	4,140				2.78	1.65	1.16

Earnings per ordinary share is calculated on the basis of the weighted average number of ordinary shares

outstanding. In calculating the weighted average number of ordinary shares outstanding, own shares held by group

companies (including share buyback programmes) are deducted from the total number of ordinary shares in issue.

Dilutive instruments

Diluted earnings per share is calculated as if the share plans outstanding at the end of the period had been

exercised at the beginning of the period and assuming that the cash received from dilutive instruments (if any) is

used to buy own shares against the average market price during the period. The net increase in the number of

shares resulting from exercising share plans is added to the average number of shares used for the calculation of

diluted earnings per share.

29 Dividend per ordinary share


Dividends to shareholders of the parent
	Per ordinary share (in EUR)	Total (in EUR million)
Dividends on ordinary shares:
In respect of 2023
- Interim dividend, paid August 2023	0.350	1,260
- Final dividend, paid May 2024	0.756	2,497
Total dividend in respect of 2023	1.106	3,757
In respect of 2024
- Interim dividend, paid August 2024	0.350	1,129
- Final dividend, paid May 2025	0.710	2,152
Total dividend in respect of 2024	1.060	3,281
In respect of 2025
- Interim dividend, paid August 2025	0.350	1,039
- Final dividend declared	0.736	2,125
Total dividend for the period ending 31 December 2025	1.086	3,164

On 22 April 2025, the Annual General Meeting of shareholders ratified the total dividend of EUR 1.06 per ordinary

share of which EUR 0.35 per share was paid as an interim cash dividend during August 2024. The final dividend of

EUR 0.71 per ordinary share was paid entirely in cash on 2 May 2025.

In October 2025 an additional cash distribution of EUR 0.172 per share was declared to shareholders of ING Group

and EUR 500 million was paid in January 2026 (2024: EUR 498 million, EUR 0.161 per share 2023: nil).

The Board has proposed to pay a final cash dividend over 2025 of EUR 0.736 per share. This is subject to approval

by shareholders at the Annual General Meeting in April 2026.

ING Groep N.V. is required to withhold tax of 15% on dividends paid. Reference is made to Note 19 'Equity' for more

information on share buyback programmes and other distributions.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-272

Segment reporting

30 Segments

ING Group’s segments are based on the internal reporting structure by lines of business.

The Executive Board of ING Group and the Management Board Banking (together the Chief Operating Decision

Maker or CODM) set the performance targets, and approve and monitor the budgets prepared by the business

lines. Business lines formulate strategic, commercial, and financial plans in conformity with the strategy and

performance targets set by the CODM.

Recognition and measurement of segment results are in line with the accounting policies as described in Note 1

'Basis of preparation and material accounting policy information'. The results for the period for each reportable

segment are after intercompany and intersegment eliminations and are those reviewed by the CODM to assess

performance of the segments. Corporate expenses are allocated to business lines based on time spent by head

office personnel, the relative number of staff, or on the basis of income, expenses and/or assets of the segment.

Interest income per segment is reported as net interest income because management relies primarily on net

(rather than gross) interest revenue to assess the performance of the segments.

The following table specifies the segments by line of business and the main sources of income of each of the

segments:


Specification of the main sources of income of each of the segments by line of business
Segments by line of business	Main source of income
Retail Netherlands	Income from products and services provided to private individuals, business banking clients and private banking clients in the Netherlands. The main products and services offered are daily banking, lending, savings, investments and insurance.
Retail Belgium	Income from products and services provided to private individuals, business banking clients and private banking clients in Belgium and Luxembourg. The main products and services offered are similar to those in the Netherlands.

Retail Germany	Income from products and services provided to private individuals, business banking clients and private banking clients in Germany. The main products and services offered are similar to those in the Netherlands.

Retail Other	Income from products and services provided to private individuals, business banking clients and private banking clients in the other retail countries. The main products and services offered are similar to those in the Netherlands.

Wholesale Banking	Income from wholesale banking activities, of which the main products are lending, payments & cash management, working capital solutions, trade finance, financial markets, corporate finance and treasury.


Specification of geographical split of the segments
Geographical split of the segments	Main countries
The Netherlands
Belgium	Including Luxembourg
Germany
Other Challengers	Australia, Italy, Spain and Portugal
Growth Markets	Poland, Romania and Türkiye
Wholesale Banking Rest of World	Other countries in Europe & Middle East, Americas, Asia
Other	Corporate Line


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-273

ING Group monitors and evaluates the performance of ING Group at a consolidated level and by segment. The

Executive Board and the Management Board Banking consider this to be relevant to an understanding of the

Group’s financial performance, because it allows investors to understand the primary method used by

management to evaluate the Group’s operating performance and make decisions about allocating resources.

In addition, ING Group believes that the presentation of results in accordance with IFRS-EU helps investors compare

its segment performance on a meaningful basis by highlighting result before tax attributable to ongoing

operations and the profitability of the segment businesses. IFRS-EU result is derived by including the impact of the

IFRS-EU ‘IAS 39 carve out’ adjustment.

The IFRS-EU ‘IAS 39 carve-out’ adjustment relates to fair value portfolio hedge accounting strategies for the

mortgage and savings portfolios in the Benelux, Germany, France, Spain, Italy and Romania that are not eligible

under IFRS-IASB. As no hedge accounting is applied to these mortgage and savings portfolios under IFRS-IASB, the

fair value changes of the derivatives are not offset by fair value changes of the hedge items (mortgages and

savings).

The segment reporting in the annual report on Form 20-F has been prepared in accordance with International

Financial Reporting Standards as issued by the EU (IFRS-EU) and reconciled to International Financial Reporting

Standards as issued by the International Accounting Standards Board (IFRS-IASB) for consistency with the other

financial information contained in this report. The difference between the accounting standards is reflected in the

Wholesale Banking segment, and in the geographical split of the segments in the Netherlands, Belgium, Germany,

Other Challengers, Growth Markets and Wholesale Banking Rest of World.

Reference is made to Note 1 'Basis of preparation and material accounting policy information' for a reconciliation

between IFRS-EU and IFRS-IASB. Corporate expenses are allocated to business lines based on time spent by head

office personnel, the relative number of staff, or on the basis of income, expenses and/or assets of the segment.

ING Group reconciles the total segment results to the total result using Corporate Line. The Corporate Line includes

capital management activities, as ING Group applies a system of capital charging for its banking operations in

order to create a comparable basis for the results of business units globally, irrespective of the business units’ book

equity and the currency they operate in.

Corporate Line also includes certain other income and expenses that are not allocated to the banking businesses,

such as our investments in Bank of Beijing and TMBThanachart Bank (Asian stakes) as well as our stake in Van

Lanschot Kempen (which in 2025 was increased to 20.3%). Furthermore, as from 2022, results in the Corporate

Line have been impacted by the application of hyperinflation accounting in the consolidation of our subsidiary in

Türkiye (IAS 29).

Total income within the Corporate Line increased 28% to EUR 484 million, up from EUR 378 million in the previous

year. This growth was driven by higher income from foreign currency ratio hedging (up EUR 70 million year-on-

year), increased results from our financial stakes (EUR 49 million, including a favourable revaluation of the

derivative related to the forward purchase of a stake in Van Lanschot Kempen), and a diminished impact from IAS

29 (reflecting lower inflation in Türkiye). In both years, results also included a receivable related to the prior

insolvency of a financial institution in the Netherlands: EUR 16 million in 2025 and EUR 53 million in 2024.

Operating expenses for the Corporate Line decreased to EUR 512 million, compared with EUR 533 million in 2024.

The 2025 figure comprised a hyperinflation impact of EUR 12 million and EUR 73 million in restructuring costs. In

2024, expenses included a EUR 35 million hyperinflation impact, EUR 25 million in restructuring costs, a EUR 22

million one-off CLA-related payment to staff in the Netherlands, and a EUR 21 million litigation provision. Expenses

excluding the aforementioned items declined year-on-year due to a higher VAT refund.

The information presented in this note is in line with the information presented to the Executive Board of ING

Group and Management Board Banking.

This note does not provide information on the types of products and services from which each reportable segment

derives its revenues, as this is not reported internally.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-274


Reconciliation between IFRS-IASB and IFRS-EU income, expense and net result
12 month period	2025					2024					2023
in EUR million	Income	Expenses	Taxation	Non-controlling interests	Net result 1	Income	Expenses	Taxation	Non-controlling interests	Net result1	Income	Expenses	Taxation	Non-controlling interests	Net result1
Net result IFRS-IASB attributable to equity holder of the parent	25,678	13,887	3,192	275	8,324	21,087	13,315	2,181	258	5,334	18,121	12,084	1,662	235	4,140

Remove impact of:
Adjustment of the EU 'IAS 39 carve out' 2	-2,643		-647		-1,996	1,528		470		1,058	4,455		1,308		3,147
Net result ING Group IFRS-EU 3	23,035	13,887	2,545	275	6,327	22,615	13,315	2,650	258	6,392	22,575	12,084	2,970	235	7,287

1Net result in the table above reflects the net result attributable to shareholders of the parent.

2ING prepares the Form 20-F in accordance with IFRS-IASB. This information is prepared by reversing the hedge accounting impacts that applied under the EU 'carve-out' version of IAS 39. For the underlying result, the impact of the carve-out is re-instated as this is the measure at which management monitors the

business.

3IFRS-EU figures include the impact of applying the EU 'IAS 39 carve-out'.


ING Group Total
12 month period	2025			2024			2023
in EUR million	ING Bank	Other	Total ING Group	ING Bank	Other	Total ING Group	ING Bank	Other	Total ING Group
Income
Net interest income	14,542	139	14,681	14,749	275	15,023	15,809	166	15,976
Net fee and commission income	4,597	5	4,602	4,002	6	4,008	3,586	9	3,595
Total investment and other income	3,752		3,752	3,584		3,584	3,006	-1	3,005
– of which share of result from associates and joint ventures	200		200	170		170	144		144
– of which revaluations and trading income	3,422		3,421	3,407	1	3,407	2,910		2,910
Total income	22,891	144	23,035	22,334	281	22,615	22,401	174	22,575

Expenditure
Operating expenses	12,576	7	12,583	12,116	5	12,121	11,563	1	11,564
– of which Regulatory costs	866		866	882		882	1,042		1,042
Addition to loan loss provisions	1,304		1,304	1,194		1,194	520		520
Total expenses	13,879	7	13,887	13,310	5	13,315	12,083	1	12,084

Result before taxation	9,012	136	9,148	9,025	275	9,300	10,318	173	10,492
Taxation	2,510	35	2,545	2,580	71	2,650	2,926	44	2,970
Non-controlling interests	275		275	258		258	235		235
Net result IFRS-EU	6,226	101	6,327	6,187	205	6,392	7,157	129	7,287
Adjustment of the EU 'IAS 39 carve out'	1,996		1,996	-1,058		-1,058	-3,147		-3,147
Net result IFRS-IASB	8,223	101	8,324	5,130	205	5,334	4,010	129	4,140


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-275


Segments
12 month period	2025							2024							2023
in EUR million	Retail Nether- lands	Retail Belgium	Retail Germany	Retail Other	Wholesale Banking	Corporate Line	Total	Retail Nether- lands	Retail Belgium	Retail Germany	Retail Other	Wholesale Banking	Corporate Line	Total	Retail Nether- lands	Retail Belgium	Retail Germany	Retail Other 1	Wholesale Banking	Corporate Line	Total
in EUR million	Retail Nether- lands	Retail Belgium	Retail Germany	Retail Other	Wholesale Banking	Corporate Line	Total	Retail Nether- lands	Retail Belgium	Retail Germany	Retail Other	Wholesale Banking	Corporate Line	Total	Retail Nether- lands	Retail Belgium	Retail Germany	Retail Other 1	Wholesale Banking	Corporate Line	Total
Income
Net interest income	3,115	1,786	2,457	3,892	2,997	434	14,681	3,027	1,959	2,647	3,817	3,259	315	15,023	3,096	2,063	2,862	3,437	4,028	489	15,976
Net fee and commission income	1,128	692	632	717	1,433	1	4,602	1,049	603	433	609	1,317	-3	4,008	959	502	357	519	1,259	-1	3,595
Total investment and other income	726	197	-98	299	2,579	49	3,752	835	189	-173	263	2,405	66	3,584	945	117	-67	277	1,771	-38	3,005
– of which share of result from associates and joint ventures	-8	119		11	-56	133	200		81		8	-36	118	170				7	31	107	144
– of which revaluations and trading income	689	118	-112	257	2,571	-102	3,421	810	81	-160	253	2,478	-55	3,407	898	61	-57	264	1,730	13	2,910
Total income	4,968	2,674	2,991	4,908	7,009	484	23,035	4,910	2,751	2,906	4,688	6,981	378	22,615	5,001	2,683	3,152	4,233	7,057	450	22,575

Expenditure
Operating expenses	2,089	1,878	1,362	2,905	3,837	512	12,583	2,124	1,811	1,303	2,792	3,558	533	12,121	2,135	1,852	1,243	2,479	3,313	542	11,564
– of which Regulatory costs	67	261	32	287	219		866	114	206	88	261	212	1	882	212	211	96	252	271		1,042
Addition to loan loss provisions	107	153	171	323	549	1	1,304	-8	134	149	291	627	1	1,194	5	169	119	313	-92	5	520
Total expenses	2,196	2,031	1,533	3,228	4,386	513	13,887	2,117	1,944	1,452	3,083	4,185	534	13,315	2,140	2,022	1,362	2,792	3,222	547	12,084

Result before taxation	2,773	644	1,457	1,680	2,624	-30	9,148	2,793	807	1,455	1,605	2,796	-156	9,300	2,861	661	1,790	1,441	3,836	-97	10,492
Taxation	733	178	472	398	673	92	2,545	723	210	505	381	693	138	2,650	740	182	631	359	900	158	2,970
Non-controlling interests	0	0	2	225	48	0	275	0	0	1	221	35	0	258	0	0	0	174	61	0	235
Net result IFRS-EU 1	2,040	466	983	1,058	1,902	-121	6,327	2,070	597	949	1,002	2,068	-294	6,392	2,121	479	1,159	908	2,875	-255	7,287
Adjustment of the EU 'IAS 39 carve out'					1,996		1,996					-1,058		-1,058					-3,147		-3,147
Net result IFRS-IASB 1	2,040	466	983	1,058	3,899	-121	8,324	2,070	597	949	1,002	1,010	-294	5,334	2,121	479	1,159	908	-272	-255	4,140

1Net result in the table above reflects the net result attributable to shareholders of the parent.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-276


Geographical split of the segments
12 month period	2025								2024								2023
in EUR million Income	Nether- lands	Belgium	Ger- many	Other Challen gers	Growth markets	Wholesale Banking Rest of World	Other	Total	Nether- lands	Belgium	Ger- many	Other Challen gers	Growth markets	Wholesale Banking Rest of World	Other	Total	Nether- lands	Belgium	Ger- many	Other Challen gers	Growth markets	Wholesale Banking Rest of World	Other	Total
Net interest income	2,925	2,277	2,936	2,099	2,526	1,487	431	14,681	3,063	2,478	3,182	2,131	2,409	1,448	312	15,023	3,773	2,712	3,375	2,121	1,961	1,548	486	15,976
Net fee and commission income	1,387	948	698	397	513	660	-1	4,602	1,329	832	484	337	445	585	-3	4,008	1,239	715	400	285	384	573	-1	3,595
Total investment and other income	2,079	198	-112	37	455	1,040	56	3,752	1,889	207	-188	27	408	1,167	74	3,584	1,627	145	-81	21	487	829	-25	3,005
– of which share of result from associates and joint ventures	1	54			11		133	200	-45	87			8		120	170	31				7		107	144
– of which revaluations and trading income	2,072	137	-147	3	409	1,074	-127	3,421	1,916	119	-191	2	403	1,217	-58	3,407	1,568	95	-83	4	479	841	6	2,910
Total income	6,392	3,422	3,522	2,533	3,493	3,186	486	23,035	6,282	3,517	3,478	2,495	3,262	3,200	382	22,615	6,639	3,573	3,694	2,427	2,833	2,950	460	22,575

Expenditure
Operating expenses	3,067	2,260	1,587	1,468	1,922	1,766	514	12,583	3,026	2,170	1,512	1,454	1,759	1,669	531	12,121	3,065	2,195	1,437	1,320	1,495	1,509	544	11,564
– of which Regulatory costs	112	285	33	36	320	80		866	159	228	90	61	260	83	1	882	296	243	103	92	207	101		1,042
Addition to loan loss provisions	168	298	259	134	239	205	1	1,304	42	148	222	188	214	378	1	1,194	-111	139	35	166	189	96	5	520
Total expenses	3,235	2,558	1,846	1,602	2,161	1,970	515	13,887	3,068	2,319	1,734	1,642	1,973	2,047	532	13,315	2,954	2,334	1,472	1,486	1,683	1,605	549	12,084

Result before taxation	3,157	865	1,676	931	1,333	1,216	-29	9,148	3,213	1,198	1,744	853	1,289	1,153	-149	9,300	3,685	1,239	2,222	941	1,149	1,345	-89	10,492
Retail Banking	2,773	644	1,457	593	1,087			6,554	2,793	807	1,455	534	1,071			6,660	2,861	661	1,790	649	792			6,753
Wholesale Banking	384	221	219	338	246	1,216		2,624	420	391	289	319	218	1,153	7	2,796	824	577	432	292	357	1,345	8	3,836
Corporate Line							-30	-30							-156	-156							-97	-97
Result before taxation	3,157	865	1,676	931	1,333	1,216	-29	9,148	3,213	1,198	1,744	853	1,289	1,153	-149	9,300	3,685	1,239	2,222	941	1,149	1,345	-89	10,492
Taxation	833	236	543	292	263	287	92	2,545	847	308	563	272	256	267	137	2,650	909	349	723	282	225	335	148	2,970
Non-controlling interests			2		273			275			1		256			258					234			235
Net result IFRS-EU 1	2,324	629	1,131	639	796	929	-121	6,327	2,367	889	1,179	581	777	886	-286	6,392	2,776	889	1,499	659	690	1,011	-237	7,287
Adjustment of the EU 'IAS 39 carve out'	931	603	465	15	1	-18		1,996	225	-398	-860	-5		-20		-1,058	-277	-1,012	-1,825	-9		-23		-3,147
Net result IFRS-IASB 1	3,255	1,231	1,596	654	797	911	-121	8,324	2,591	492	319	576	777	865	-286	5,334	2,499	-123	-326	649	690	988	-237	4,140

1Net result in the table above reflects the net result attributable to shareholders of the parent.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-277

31 Information on geographical areas

ING Group’s business lines operate in different geographical areas: the Netherlands, Belgium, Germany, Rest of

Europe and Rest of the World. The geographical analyses are based on the location of the office from which the

transactions are originated and do not include countries where ING only has representation offices. The

Netherlands is ING Group’s country of domicile.

In order to increase ING Group’s tax transparency, additional financial information on a per country basis has been

included in this disclosure: Tax paid represents all income tax paid to and/or received from tax authorities in the

current year, irrespective of the fiscal year to which these payments or refunds relate. Total assets by country do

not include intercompany balances and reconcile to the total assets in the consolidated statement of financial

position of ING Group.

ING Group is subject to top-up tax (Global Anti-Base Erosion Model Rules (Pillar Two)) in relation to its operations in

countries where the effective tax rate falls below 15%. This includes Switzerland, Ireland and Bulgaria as a result of

their lower nominal tax rates, as well as Singapore, where special local tax rates for certain types of income reduce

the effective tax rate.

ING Group has applied a temporary mandatory relief from deferred tax accounting for the impacts of the top-up

tax and accounts for it as a current tax when it is incurred. The total top-up tax that is expected to be paid by ING

Group per jurisdiction over 2025 amounts to EUR 5.8 million (2024: EUR 9.5 million).


Overview Top up tax to be paid per jurisdiction (EUR million)
Country	2025	2024
Singapore	3.0	6.5
Ireland	2.2	2.1
Bulgaria	0.3	0.6
Switzerland	0.3	0.3
	5.8	9.5


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-278

The table below provides additional information, for the years 2025, 2024 and 2023 respectively, on names of

principal subsidiaries and branches, the nature of main activities and the average number of employees on a full-

time equivalent basis by country/tax jurisdiction.


Additional information by country
Geographical area	Country/Tax jurisdiction	Name of principal subsidiary	Main (banking) activity	Average number of employees at full time equivalent basis			Total income			Total assets			Result before tax			Taxation			Tax paid
				2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023
Netherlands	Netherlands	ING Bank N.V.	Wholesale / Retail	15,280	14,821	14,449	6,832	5,201	5,171	305,860	301,955	294,485	2,833	1,408	1,445	833	519	461	413	589	601
Belgium	Belgium	ING België N.V.	Wholesale / Retail	5,828	5,994	6,392	3,890	2,767	1,917	137,372	136,765	128,391	1,666	759	-119	440	198	7	245	272	169
	Luxembourg	ING Luxembourg S.A.	Wholesale / Retail	865	887	939	432	469	587	14,150	13,961	14,435	141	192	328	34	48	84	113	116	40
Germany	Germany	ING DiBa A.G.	Wholesale / Retail	5,673	5,460	5,499	4,320	2,582	1,244	185,220	174,500	171,899	2,474	853	-221	710	280	-55	549	663	904
Rest of Europe	Poland 1	ING Bank Slaski S.A	Wholesale / Retail	11,130	11,575	11,677	2,798	2,620	2,350	61,344	56,090	52,134	1,411	1,313	1,236	310	280	286	241	231	136
	Spain	Branch of ING Bank N.V.	Wholesale / Retail	1,748	1,692	1,576	1,230	1,224	1,156	38,580	35,917	33,092	575	549	533	189	174	125	170	185	114
	Italy	Branch of ING Bank N.V.	Wholesale / Retail	1,335	1,235	1,190	522	513	433	20,309	16,444	14,832	116	119	128	41	38	54	13	16	19
	Romania 1	Branch of ING Bank N.V.	Wholesale / Retail	4,514	4,282	3,971	779	749	690	14,151	12,937	11,496	365	401	396	63	67	61	69	76	55
	Türkiye	ING Bank A.S.	Wholesale / Retail	2,574	2,795	2,973	208	142	14	4,958	4,897	4,770	-73	-110	-232	3	18	-20	11	5	29
	UK	Branch of ING Bank N.V.	Wholesale	762	741	722	782	811	758	63,746	59,615	50,572	385	249	510	88	52	131	55	70	101
	Switzerland	Branch of ING Bank N.V.	Wholesale	305	300	292	214	228	248	9,641	9,086	8,501	90	104	137	14	16	19	14	29	52
	France 2	Branch of ING Bank N.V.	Wholesale	209	194	194	220	214	221	7,876	7,928	8,458	90	-23	91	30	-3	25	7	9	7
	Ireland	Branch of ING Bank N.V.	Wholesale	147	119	82	107	135	83	4,048	3,593	3,907	100	102	71	15	15	9	12	12	8
	Czech Republic	Branch of ING Bank N.V.	Wholesale	124	122	134	75	77	76	3,561	3,382	3,191	27	37	33	6	8	6	8	4	10
	Hungary	Branch of ING Bank N.V.	Wholesale	131	128	127	54	63	85	2,183	2,179	1,893	-2	6	35	3	3	7	2	9	9
	Russia	ING Bank (Eurasia) Z.A.O.	Wholesale	239	236	259	186	139	136	1,086	764	925	157	99	151	38	19	31	35	21	20
	Slovakia 1	Branch of ING Bank N.V.	Wholesale	1,605	1,489	1,347	19	22	20	686	612	618	3	8	11	1	3	2	2	4	2
	Portugal	Branch of ING Bank N.V.	Wholesale	12	11	10	23	23	17	714	815	620	16	18	12	4	4	3	6	4	2
	Ukraine	PJSC ING Bank Ukraine	Wholesale	94	92	91	38	45	53	567	651	590	24	29	44	6	14	22	10	25	7
	Bulgaria	Branch of ING Bank N.V.	Wholesale	64	64	61	25	27	23	611	570	530	6	13	11	1	2	1	3	2	1
	Austria	Branch of ING Bank N.V.	Wholesale	23	20	17	12	10	9	845	394	383	-1	-2	-4	0	0	-1	0	0	1

1Includes significant number of FTEs in relation to global services provided.

2Public subsidies received, as defined in article 89 of the CRD IV, amounts to EUR 0.0 million (2024: EUR 0.1 million; 2023: EUR 0.2 million).


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-279


Additional information by country (continued)
Geographical area	Country/Tax jurisdiction	Name of principal subsidiary	Main (banking) activity	Average number of employees at full-time equivalent basis			Total income			Total assets			Result before tax			Taxation			Tax paid
				2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023	2025	2024	2023
Rest of the World	Australia	ING Bank (Australia) Ltd.	Wholesale / Retail	2,050	1,994	1,820	971	994	1,033	55,976	53,895	52,734	485	460	572	150	142	174	174	195	185
Rest of the World	USA	ING Financial Holdings Corp.	Wholesale	714	659	603	1,262	1,277	1,124	61,483	65,197	66,143	598	759	654	160	195	185	161	175	183
	Singapore	Branch of ING Bank N.V.	Wholesale	590	572	576	403	474	354	38,414	34,593	26,816	206	333	172	30	44	24	44	24	13
	Japan	Branch of ING Bank N.V.	Wholesale	40	32	32	43	42	40	7,401	9,570	14,267	16	25	17	8	5	7	5	4	10
	South Korea	Branch of ING Bank N.V.	Wholesale	89	86	86	84	86	92	8,343	8,050	6,167	34	32	39	8	7	9	-6	7	24
	Hong Kong	Branch of ING Bank N.V.	Wholesale	100	100	104	70	76	101	3,469	3,512	4,378	18	24	-18	3	4	-2	0	0	0
	Taiwan	Branch of ING Bank N.V.	Wholesale	38	37	37	34	27	39	6,054	3,507	2,597	16	4	0	6	1	1	1	3	0
	China	Branch of ING Bank N.V.	Wholesale	80	78	78	25	29	18	1,129	1,935	998	-8	-5	-12	-3	-1	2	2	0	-9
	Philippines 1	Branch of ING Bank N.V.	Wholesale	6,392	5,290	4,079	16	16	10	496	477	403	17	14	1	2	3	2	3	3	2
	United Arab Emirates	Branch of ING Bank N.V.	Wholesale	14	12	11	0	0	-2	1	1	1	0	0	-3	0	0	0	0	0	0
	Sri Lanka	Branch of ING Hubs B.V.	Global services	1	5	4	0	0	0	2	0	0	0	0	0	0	0	0	0	0	0
	Brazil	ING ADMINISTRAÇÃO LTDA.	In run-off / liquidation	0	0	2	4	4	18	55	63	73	3	3	17	1	25	0	1	1	4
	Mexico	ING Consulting, S.A. de C.V.	In run-off / liquidation	0	0	0	0	0	0	0	0	0	0	0	0	0	0	0		0	0
	Canada	Payvision Canada Services Ltd.	Dissolved in 2023		0	0		0	0		0	0		0	0		0	0		0	0
Total				62,770	61,121	59,434	25,678	21,087	18,121	1,060,329	1,023,856	980,299	11,791	7,772	6,037	3,192	2,181	1,662	2,366	2,754	2,700

1Includes significant number of FTEs in relation to global services provided.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-280

2025

The higher tax charge of 29% in the Netherlands (compared to the statutory rate of 25.8%) was mainly caused by

the non-deductible Dutch bank tax (EUR 256 million) and other non-deductible expenses.

Since the Russian invasion of Ukraine, ING has a policy in place to take on no new business with Russian clients. In

2025, we have further scaled down operations and continued actions to separate the business from ING’s

networks and systems, which resulted in additional workload for the local operation. On 28 January 2025, an

agreement was announced on the sale of our business in Russia to Global Development JSC. As of the date of this

report, and as announced in September 2025, the buyer has not received all necessary approvals yet. We continue

to work towards completing the transaction and our exit from the Russian market. As reported earlier, on

completion of the divestment we expect a negative P&L impact of around EUR 0.8 billion post tax and a negligible

impact on our CET1 ratio. The local income and result on a standalone basis over 2025 are driven by the high local

interest rate as most of the assets are deposited at the Russian central bank, supported by the appreciation of the

rouble against the euro. Under local law and banking regulations, ING Russia must accept rouble inflows and

deposits from existing clients. We are in discussion with regulators on the conflicting regulatory requirements in

various jurisdictions with respect to the activities of ING Bank (Eurasia) JSC. For further information, reference is

made to Note 32 'Potential sale of ING Bank (Eurasia) JSC'.

2024

The higher tax charge of 37% in the Netherlands (compared to the statutory rate of 25.8%) was mainly caused by

the non-deductible Dutch bank tax (EUR 246 million) and other non-deductible expenses.

The positive tax charge reported for ING Türkiye with respect to its loss was mainly caused by the non-deductibility

for tax purposes of the accounting loss based on hyperinflation accounting.

The high tax charge in Brazil was caused by tax corrections for prior periods in connection with the run-off of our

Brazilian operations.

2023

The higher tax charge of 32% in the Netherlands (compared to the statutory rate of 25.8%) was mainly caused by

the non-deductible Dutch bank tax (EUR 189 million) and other non-deductible expenses.

The lower tax charge in Spain was caused by a tax refund (EUR 43 million) regarding previous years.

ING continued reducing Russian-related exposure during 2023, the local results on a standalone basis were

positively impacted by releases of loan loss provisions following improved macroeconomic indicators and decrease

in exposures following sales and repayments.

The lower negative tax charge reported for ING Türkiye with respect to its loss was mainly caused by the non

deductibility for tax purposes of the accounting loss based on hyperinflation accounting.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-281

Additional notes to the consolidated financial statements

32 Potential sale of ING Bank (Eurasia) JSC

On 28 January 2025, ING announced the proposed sale of ING Bank (Eurasia) JSC to Global Development JSC.

Completion of the transaction is subject to various regulatory approvals. This transaction will effectively end ING’s

activities in the Russian market. Under the terms of the agreement, Global Development JSC will acquire all shares

of ING Bank (Eurasia) JSC, taking over all Russian onshore activities and staff. Global Development JSC intends to

continue to serve customers in Russia under a new brand. As of the date of this report and as announced in

September 2025, the buyer has not received all necessary approvals yet. We continue working towards

completing the transaction and our exit from the Russian market. In the meantime, we are in discussion with

regulators on the conflicting regulatory requirements in various jurisdictions with respect to the activities of ING

Bank (Eurasia) JSC.

ING has taken on no new business with Russian companies, has scaled down operations and has taken actions to

separate the business from ING’s networks and systems. Until sales completion ING Group continues to direct the

relevant activities of ING Eurasia and, therefore, continues to control and to consolidate it.

Based on 31 December 2025 position, ING estimates a negative impact to the Result on disposal of Group

companies of EUR 0.8 billion post tax. This includes an estimated book loss of EUR 0.5 billion, representing the

expected difference between the sale price and the book value of the business. It also includes an estimated

negative impact of EUR 0.3 billion from recycling the currency translation adjustment net of the Net Investment

hedge reserve through P&L. These estimates are subject to change, depending on the position at the closing date.

Given the prevailing uncertainties around substantive regulatory approvals as at 31 December 2025, no book loss

was recognised in 2025 and assets and liabilities of the disposal group were not classified as held for sale.

Furthermore, recycling of the currency translation reserve and the net investment hedge reserve through P&L will

only occur upon deal closing when ownership and control over ING Eurasia is transferred. Such recycling of the

reserves will have no impact on total equity and, hence, ING’s CET1 ratio.

33 Pensions and other post-employment benefits

Most group companies sponsor defined contribution pension plans. The assets of all ING Group’s defined

contribution plans are held in independently administered funds. Contributions, including the defined contribution

plan in the Netherlands, are principally determined as a percentage of remuneration. These plans do not give rise

to provisions in the statement of financial position, other than relating to short-term timing differences included in

other assets and in other liabilities.

ING Group maintains defined benefit retirement plans in some countries. These plans provide benefits that are

related to the remuneration and service of employees upon retirement. The benefits in some of these plans are

subject to various forms of indexation. The indexation is, in some cases, at the discretion of management; in other

cases it is dependent upon the sufficiency of plan assets.

Annual contributions are paid to the funds at a rate necessary to adequately finance the accrued liabilities of the

plans calculated in accordance with local legal requirements. Plans in all countries are designed to comply with

applicable local regulations governing investments and funding levels.

ING Group provides other post-employment benefits to certain former employees. These post-employment

benefits are primarily discounts on ING products.

Defined contribution plans

ING, as part of the labour agreements with its employees, sponsors a number of defined contribution plans. ING’s

obligation is limited to contributions which are agreed in advance and also includes employee contributions. The

most significant plans are in the Netherlands and Belgium. The employer's contribution is recognised as an

expense which amounted in 2025 to EUR 460 million (2024: EUR 423 million and 2023: EUR 391 million).

Transition Plan on the New Dutch Pension Plan Legislation

In 2024, ING and unions agreed on a transition plan for a new pension plan, based on the new Dutch pension

legislation. This new plan will replace the current pension plan and will remain to be classified as a Defined

Contribution Plan and will continue to be executed by the ING CDC Pension fund.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-282

Defined benefit retirement plans

Statement of financial position - Net defined benefit asset/liability


Plan assets and defined benefit obligation per country
	Plan assets		Defined benefit obligation		Funded Status
in EUR million	2025	2024	2025	2024	2025	2024
The Netherlands	302	325	381	415	-79	-90
United States	226	250	224	235	1	15
United Kingdom	1,129	1,206	706	751	423	455
Belgium	514	513	441	450	72	63
Other countries	327	341	358	368	-31	-26
Funded status (Net defined benefit asset/liability)	2,497	2,636	2,110	2,219	387	416

Presented as:
- Other assets					528	568
- Other liabilities					-141	-152
					387	416

The most recent (actuarial) valuations of the plan assets and the present value of the defined benefit obligation

were carried out as at 31 December 2025. The present value of the defined benefit obligation, and the related

current service cost and past service cost, were determined using the projected unit credit method.

Changes in the fair value of plan assets for the period were as follows:


Changes in fair value of plan assets
in EUR million	2025	2024
Opening balance as at 1 January	2,636	2,678
Interest income	108	106
Remeasurements: Return on plan assets excluding amounts included in interest income	-37	-118
Employer's contribution	13	23
Participants contributions	4	4
Benefits paid	-121	-128
Effect of curtailment or settlement	-12	-8
Exchange rate differences	-93	79
Closing balance	2,497	2,636

Actual return on the plan assets	70	-12

As at 31 December 2025, the defined benefit plans did not hold any direct investments in ING Groep N.V. (2024:

nil). During 2025 and 2024, there were no purchases or sales of assets between ING and the pension funds.

ING does not manage the pension funds and thus receives no compensation for fund management. The pension

funds have not engaged ING in any swap or derivative transactions to manage the risk of the pension funds.

No plan assets are expected to be returned to ING Group during 2026.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-283

Changes in the present value of the defined benefit obligation and other post-employment benefits for the period

were as follows:


Changes in defined benefit obligation and other post-employment benefits
	Defined benefit obligation		Other post-employment benefits
in EUR million	2025	2024	2025	2024
Opening balance as at 1 January	2,219	2,288	38	30
Current service cost	28	28	1	1
Interest cost	86	87	3	3
Remeasurements: Actuarial gains and losses arising from changes in demographic assumptions	6	-3
Remeasurements: Actuarial gains and losses arising from changes in financial assumptions	-32	-94	6	5
Participants’ contributions	4	3
Benefits paid	-127	-132	-1	-1
Past service cost	1	1
Effect of curtailment or settlement	-12	-9
Exchange rate differences and other changes	-65	51	-5	1
Closing balance	2,110	2,219	42	38

Amounts recognised directly in Other comprehensive income were as follows:


Changes in the net defined benefit assets/liability remeasurement reserve
in EUR million	2025	2024
Opening balance as at 1 January	-333	-317

Remeasurement of plan assets	-37	-118
Actuarial gains and losses arising from changes in demographic assumptions	-6	3
Actuarial gains and losses arising from changes in financial assumptions	32	94
Taxation and Exchange rate differences	0	5
Total Other comprehensive income movement for the year	-12	-16

Closing balance	-345	-333

In 2025, the EUR -37 million (2024: EUR -118 million) of remeasurements of plan assets, that is recognised as a

loss in other comprehensive income, is driven by yield changes on investments.

The EUR 32 million (2024: EUR 94 million) of actuarial gains arising from changes in financial assumptions in the

calculation of the defined benefit obligation is mainly due to changes in discount rates.

The accumulated amount of remeasurements recognised directly in Other comprehensive income is EUR

-433 million (EUR -345 million after tax) as at 31 December 2025 (2024: EUR -447 million; EUR -333 million after

tax).

Amounts recognised in the statement of profit or loss related to pension and other staff-related benefits are as

follows:


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-284


Pension and other staff-related benefit costs
	Net defined benefit asset/liability			Other post- employment benefits			Total
in EUR million	2025	2024	2023	2025	2024	2023	2025	2024	2023
Current service cost	28	28	27	1	1	1	29	29	28
Past service cost	1	1	1				1	1	1
Net Interest cost	-21	-19	-23	3	3	2	-19	-16	-21
Effect of curtailment or settlement		-1						-1
Defined benefit plans	7	9	5	3	4	3	11	13	8

Defined contribution plans							460	423	391
Pension and other post-employment benefits							471	435	399
Other staff-related benefits							16	20	19
Pension and other staff-related benefits							488	455	418

Determination of the net defined benefit asset/liability

The net defined benefit asset/liability is reviewed and adjusted annually. The assumptions used in the

determination of the net defined benefit asset/liability and the Other post-employment benefits include discount

rates, mortality rates, expected rates of salary increases (excluding promotion increases), and indexation. The

rates used for salary developments, interest discount factors, and other adjustments reflect country-specific

conditions.

The key assumption in the determination of the net defined benefit asset/liability is the discount rate. The discount

rate is the weighted average of the discount rates that are applied in different regions where ING Group has

defined benefit pension plans (weighted by the defined benefit obligation). The discount rate is based on a

methodology that uses market yields on high quality corporate bonds of the specific regions with durations

matching the pension liabilities as key input. Market yields of high quality corporate bonds reflect the yield on

corporate bonds with an AA rating for durations where such yields are available. An extrapolation is applied in

order to determine the yield to the longer durations for which no AA-rated corporate bonds are available. As a

result of the limited availability of long-duration AA-rated corporate bonds, extrapolation is an important element

of the determination of the discount rate. The weighted average discount rate applied for net defined benefit

asset/liability for 2025 was 4.2% (2024: 4.4%) based on the pension plan in the Netherlands, Germany, Belgium,

the United States of America, and the United Kingdom. The average discount rate applied for Other post-

employment benefits in 2025 was 5.4% (2024: 5.7%).

Sensitivity analysis of key assumptions

ING performs sensitivity analyses on the most significant assumptions: discount rates, mortality, expected rate of

salary increase, and indexation. The sensitivity analysis has been carried out under the assumption that the

changes occurred at the end of the reporting period.

The sensitivity analysis calculates the financial impact on the defined benefit obligation of an increase or decrease

of the weighted averages of each significant actuarial assumption with all other assumptions held constant. In

practice, this is unlikely to occur, and some changes of the assumptions may be correlated. Changes to mortality,

expected rate of salary increase, and indexation would have no material impact on the defined benefit obligation.

The most significant impact would be from a change in the discount rate. An increase or decrease in the discount

rate of 1.0% creates an impact on the defined benefit obligation of EUR 200 million (increase) and EUR 228 million

(decrease), respectively.

Expected cash flows

ING Group’s subsidiaries should fund the cost of the entitlements expected to be earned on a yearly basis. For

2026, the expected contributions to defined benefit pension plans are EUR 48 million.

The benefit payments for defined benefit and other post-employment benefits expected to be made by the plan

between 2026-2030 are estimated to be between EUR 159 million and EUR 174 million per year. From 2030 to

2034, the total payments made by the plan are expected to be EUR 790 million.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-285

34 Taxation

Statement of financial position – Deferred tax

Deferred taxes are recognised on all temporary differences under the liability method using tax rates applicable in

the jurisdictions in which ING Group is subject to taxation.


Changes in deferred tax
in EUR million 2025	Net liability (-) Net asset (+) opening balance	Change through equity	Change through net result	Exchange rate differences	Changes in the composition of the group and other changes	Net liability (-) Net asset (+) ending balance
Financial assets at FVOCI	126	-155	5	2		-22
Financial assets and liabilities at FVPL	-1,008		-694	-13		-1,715
Depreciation	-22		18	6		2
Cash flow hedges	363	-43		2		322
Pension and post- employment benefits	-32	4	-1	1		-28
Other provisions	62		-1			61
Loans and advances	427	1	-42	-9		376
Unused tax losses carried forward	85		-47	-4		35
Other	-208	57	21	-8		-139
Total	-208	-137	-739	-23		-1,108
Presented in the statement of financial position as:
– Deferred tax liabilities	-1,209					-1,896
– Deferred tax assets	1,001					788
	-208					-1,108

The above table shows netted deferred tax amounts related to right-of-use assets and lease liabilities included in

the row ‘Other’, and includes a deferred tax amount for right-of-use assets of EUR 164 million (2024: EUR 178

million and 2023: EUR 195 million) and a deferred tax amount for lease liabilities of EUR 181 million (2024: EUR 197

million and 2023: EUR 217 million).

The changes in Deferred tax on financial assets and liabilities at FVPL in 2025 amounting to EUR -694 million (2024:

EUR 441 million) is mainly driven by interest yield developments related to derivatives that are under IFRS-EU used

in portfolio based hedging strategies for retail mortgages and savings. These portfolio hedging strategies are not

allowed under IFRS-IASB and is referred to as the EU IAS39 carve out adjustment for which we refer to Note 1.2.2

Reconciliation between IFRS-EU and IFRS-IASB.

The deferred tax on cash flow hedges relate to floating rate lending with interest rate swaps. Due to interest rate

developments in 2025 there was a positive revaluation of the cash flow hedge through other comprehensive

income. This resulted in a decline in the deferred tax asset by EUR 43 million compared to the decline in deferred

tax assets in 2024 by EUR 138 million due to the decline in the interest yield curve. The deferred tax asset in cash

flow hedges decreased from EUR 363 million in 2024 to EUR 322 million in 2025.

The deferred tax on Loans and advances changes through net result in 2025 EUR -42 million (2024: EUR -49

million) relates mainly to differences in valuation between accounting (carrying) value and tax value caused by for

example collectively assessed expected credit losses and fee amortisation in Germany.

The deferred tax changes through equity - Other in 2025 of EUR 57 million (2024: EUR -41 million) is due to FX

developments following the USD depreciation and the application of IAS 29 Hyperinflation in Türkiye.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-286


Changes in deferred tax
in EUR million 2024	Net liability (-) Net asset (+) opening balance	Change through equity	Change through net result	Exchange rate differences	Changes in the composition of the group and other changes	Net liability (-) Net asset (+) ending balance
Financial assets at FVOCI	64	70	-8			126
Financial assets and liabilities at FVPL	-1,461		441	12		-1,008
Depreciation	-13		-9			-22
Cash flow hedges	502	-138		-1		363
Pension and post-employment benefits	-33	6	1	-5	-1	-32
Other provisions	48		12	1	1	62
Loans and advances	475		-49			427
Unused tax losses carried forward	209		-128	3		85
Other	-154	-41	-9	-5	1	-208
Total	-362	-103	251	6		-208
Presented in the statement of financial position as:
– deferred tax liabilities	-1,447					-1,209
– deferred tax assets	1,085					1,001
	-362					-208


Deferred tax in connection with unused tax losses carried forward
in EUR million	2025	2024
Total unused tax losses carried forward	860	1,345
Unused tax losses carried forward not recognised as a deferred tax asset	640	951
Unused tax losses carried forward recognised as a deferred tax asset	220	394

Average tax rate	15.7%	21.6%
Deferred tax asset	35	85


Total unused tax losses carried forward analysed by expiry terms
	No deferred tax asset recognised		Deferred tax asset recognised
in EUR million	2025	2024	2025	2024
Within 1 year
More than 1 year but less than 5 years	55	135	152	14
More than 5 years but less than 10 years		9	30	66
More than 10 years but less than 20 years
Unlimited	585	808	38	313
	640	951	220	394

Deferred tax assets are recognised for temporary deductible differences, for tax losses carried forward and unused

tax credits only to the extent that realisation of the related tax benefit is probable.


Breakdown of certain net deferred tax asset positions by jurisdiction
in EUR million	2025	2024
Australia	14	1
Czech Republic	1
China	8	9
Hong Kong		5
Singapore	2
Taiwan		10
Türkiye	30	40
United States of America		1
	55	66

The table above includes a breakdown of certain net deferred tax asset positions by jurisdiction for which the

utilisation of the deferred tax asset is dependent on future taxable profits in excess of the profits arising from the

reversal of existing taxable temporary differences whilst the related entities have incurred losses in either the

current or the preceding year.

At 31 December 2025 and 2024, ING Group had no significant temporary differences associated with the parent

company’s investments in subsidiaries and associates as any economic benefit from those investments will not be

taxable at parent company-level.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-287

Statement of profit or loss – Taxation


Taxation by type
	Netherlands			Rest of the world			Total
in EUR million	2025	2024	2023	2025	2024	2023	2025	2024	2023
Current taxation	510	454	601	1,943	1,977	2,121	2,453	2,432	2,722
Deferred taxation	323	65	-141	417	-315	-918	739	-251	-1,059
	833	519	460	2,359	1,662	1,202	3,192	2,181	1,662


Reconciliation of the weighted average statutory income tax rate to ING Group’s effective income tax rate
in EUR million	2025	2024	2023
Result before tax from continuing operations	11,791	7,772	6,037
Weighted average statutory tax rate	25.0%	24.0%	22.7%
Weighted average statutory tax amount	2,949	1,864	1,371

Permanent differences affecting current tax
Participation exemption	-69	-87	-43
Other income not subject to tax	-123	-64	-68
Expenses not deductible for tax purposes	476	424	398
Current tax from previously unrecognised amounts	0	-1	1
State and local taxes	56	77	99
Adjustments to prior periods	-92	-34	-72
Differences affecting deferred tax
Impact on deferred tax from change in tax rates	-6	-1	2
Deferred tax benefit from previously unrecognised amounts	0	-1	-30
Write-off/reversal of deferred tax assets	1	4	4
Effective tax amount	3,192	2,181	1,662

Effective tax rate	27.1%	28.1%	27.5%

The effective tax rate of 27.1% in 2025 is higher than the weighted average statutory tax rate. This is mainly

caused by the impact in 2025 of the following non-deductible items for income tax purposes: interest expenses

based on Dutch thin capitalisation rules for banks, bank taxes, and other non-deductible expenses in various

countries. State and local taxes mainly relate to taxes in the United States of America.

The effective tax rate of 28.1% in 2024 was higher than the weighted average statutory tax rate. This is mainly

caused by the impact in 2024 of the following non-deductible items for income tax purposes: hyperinflation

accounting loss in Türkiye, interest expenses, and bank- and local taxes in various countries. State and local taxes

mainly relate to Base Erosion and anti-Abuse Tax (BEAT) in the United States of America and top-up Tax based on

Global Anti-Base Erosion Model Rules (Pillar Two).

The effective tax rate of 27.5% in 2023 was higher than the weighted average statutory tax rate. This is mainly

caused by the impact in 2023 of the following non-deductible items for income tax purposes: hyperinflation

accounting loss in Türkiye, interest expenses, and bank- and local taxes in various countries. Adjustments to prior

periods mainly relate to a tax refund in Spain.

Equity - Other comprehensive income


Income tax related to components of other comprehensive income
in EUR million	2025	2024	2023
Unrealised revaluations of financial assets at fair value through other comprehensive income and other revaluations IFRS-EU	-162	99	-7
Realised gains/losses transferred to the statement of profit or loss (reclassifications from equity to profit or loss)	7	-29	-3
Changes in cash flow hedge reserve	-43	-138	-251
Remeasurement of the net defined benefit asset/liability	4	6	31
Changes in fair value of own credit risk of financial liabilities at fair value through profit or loss	6	5	2
Exchange rate differences and other	51	-46	19
Total income tax related to components of other comprehensive income	-137	-103	-209


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-288

35 Fair value of assets and liabilities

a) Valuation methods

The estimated fair values represent the price that would be received to sell an asset or paid to transfer a liability in

an orderly transaction between market participants at the measurement date. It is a market-based measurement,

which is based on assumptions that market participants would use and takes into account the characteristics of

the asset or liability that market participants would take into account when pricing the asset or liability.

Fair values of financial assets and liabilities are based on quoted prices in active market where available. When

such quoted prices are not available, the fair value is determined by using valuation techniques.

b) Valuation control framework

The valuation control framework covers the product approval process (PARP), pricing, market data assessment and

independent price verification (IPV), valuation adjustments, model use, fair value hierarchy and day one profit or

loss. Valuation processes are governed by the Global Valuation and Impairment Committee (GV&IC) and its

delegate, based on the valuation and valuation adjustment models approved by Trading and Counterparty Risk

Committee (TCRC), with outcomes monitored under the valuation Risk Appetite Statement established by Group

Financial Risk Committee (GFRC) and TCRC.

The Global Valuation and Impairment Committee is responsible for the oversight and the approval of the outcome

of impairments (other than loan loss provisions) and valuation processes. It oversees the quality and coherence of

valuation methodologies and performance. The Group Financial Risk Committee (GFRC) is the highest committee

next to Management Board Banking (MBB) to discuss and approve global policies, methodologies and risk appetite

related to Financial Risk. The Trading and Counterparty Risk Committee (TCRC) is responsible for the approval of all

valuation models used for the Fair valuation (IFRS) and Prudent Valuation (CRR) of positions measured at fair value.

The Local Parameter Committee discusses the valuation results and monitors the performance of the valuation

activities carried out on local or regional level. The Global Financial Markets Parameter Committee reviews the

consolidated valuation outcome and resulting P&L for Financial Market products, targeting a globally consistent

treatment across Financial Markets. The Banking Book Parameter Committee (BBPC) discusses the valuation topics

for non-Financial Market and non-Group Treasury Wholesale Banking portfolios. The Market Data Committee is

responsible for the approval of the market data used in valuation.

c) Valuation adjustments

Valuation adjustments are an integral part of the fair value. They are the adjustments to the output from a

valuation technique in order to appropriately determine a fair value in accordance with IFRS13. ING considers

various fair value adjustments including Bid-Offer adjustments, Model Risk adjustments, Bilateral Valuation

Adjustments (BVA, consisting of Credit Valuation Adjustments or CVA, and Debit valuation Adjustments or DVA),

Collateral Valuation Adjustment (CollVA) and Funding Valuation Adjustment (FVA).

For financial instruments where the fair value at initial recognition is based on one or more significant

unobservable inputs, a difference between the transaction price and the fair value resulting from the internal

valuation process can occur. Such difference is referred to as Day One Profit or Day One Loss (hereafter: DOP).

ING defers material DOP of instruments with significant unobservable valuation inputs, which are the financial

instruments classified as Level 3 and financial instruments with material unobservable inputs into CVA which are

not necessarily classified as Level 3. The DOP is amortised over the life of the instrument, or until the significant

unobservable inputs become observable, or until the significant unobservable inputs become non-significant. The

adjustments in fair value and the DOP reserve are disclosed in the below table.

Deferred Day One Profit or Loss Reserve

The table below summarises the movement in the aggregate DOP not recognised when financial instruments were

initially recognised, because of the use of valuation techniques for which not all the inputs were market observable

data.


Deferred day one profit or loss reserve
in EUR million	2025	2024
Opening balance at 1 January	-94	-90
DOP deferred on new transactions during the period	-37	-62
DOP recognised in the statement of profit or loss during the period:
–of which release	13	27
–of which amortisation and exchange differences	27	32
Closing balance at 31 December	-91	-94


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-289

The following table presents the adjustments in fair value for financial assets and liabilities.


Adjustments in fair value on financial assets and liabilities
in EUR million	2025	2024
Deferred Day One Profit or Loss	-91	-94
Own Credit Adjustments	-57	-17
Bid/Offer	-130	-130
Model Risk	-48	-33
CVA	-88	-123
DVA	43	50
CollVA	-11	-3
FVA	-82	-64
Other Valuation Adjustments	3	2
Total Valuation Adjustments	-462	-412

Own Credit Adjustment

Own issued debt and structured notes that are designated at fair value through profit or loss are adjusted for ING’s

own credit risk by means of DVA.

Bid-Offer Adjustment

For positions priced based upon mid-market input parameters, Bid-Offer adjustments are required in order to

reflect the valuation of that position based on bid price or offer price. In practice this adjustment accounts for the

difference in valuation from ‘mid to bid’ and ‘mid to offer’ for long and short exposures respectively. In principle,

assets are valued at the bid prices and liabilities are valued at the offer price. For certain assets or liabilities, where

a market-quoted price is not available, the price used is the fair value that is most representative within the bid-

offer spread.

Model Risk Adjustment

Financial instruments that are valued using a valuation model can be subject to model risk. Model risk is the risk of

possible financial loss resulting from a pricing model or model-based parameter deficiencies and/or uncertainties.

Bilateral Valuation Adjustments (Credit and Debit Valuation Adjustments)

Bilateral Valuation Adjustment is the valuation adjustment reflecting the counterparty credit risk of derivative

contracts. It has a bilateral nature, where both the counterparty’s credit risk (i.e. Credit Valuation Adjustment or

CVA) and ING’s own credit risk (Debit Valuation Adjustment or DVA) are taken into account:

§CVA is the fair value adjustment applicable to derivative instruments to account for the possibility that the

counterparty defaults (i.e. it is the market value of the counterparty’s credit risk).

§DVA is the fair value adjustment applicable to derivative instruments to account for the possibility that ING

defaults (i.e. it is the market value of ING’s credit risk).

The calculation of CVA and DVA on derivatives is based on their expected exposures, and the counterparties’ and

ING’s risk of default, taking into account the collateral agreements as well as netting agreements. The

counterparties’ risk of default is measured by probability of default and expected loss given default, which is based

on market information including credit default swap (CDS) spreads. Where counterparty CDS spreads are not

available, relevant proxy spreads are used. Additionally, wrong-way risk (which occurs when the probability of

default by the counterparty increases or decreases when ING’s exposure to the counterparty increases

(decreases)) and right-way risk (which occurs when the probability of default by the counterparty increases

(decreases) when ING’s exposure to the counterparty decreases (increases)) are included in the adjustment.

Collateral Valuation Adjustment (CollVA)

Collateral Valuation Adjustment is a fair valuation adjustment applied on derivative instruments to capture specific

features of CSA (Credit Support Annex) with a counterparty that the regular OIS discounting framework does not

capture. Non-standard CSA features may include deviations in relation to the currencies in which ING posts or

receives collateral, deviations in the remuneration rate on collateral which may pay lower or higher rate than the

overnight rate or even no interest at all; other deviations can be posting securities rather than cash as collateral.

Funding Valuation Adjustment (FVA)

Funding Valuation Adjustment (FVA) is a fair valuation adjustment applied on derivative instruments to address

the asymmetry in funding costs or funding benefits between collateralised and uncollateralised derivative

portfolios. This adjustment is based on the expected exposure profiles of the uncollateralised or partially

collateralised OTC derivatives and market-based funding spreads.

Other Valuation Adjustments

This pertains to other valuation adjustments that are immaterial to ING. Most of the balance consists of the Market

Price Uncertainty (MPU) adjustment in fair value, which accounts for the price uncertainty risk inherent in the

valuation inputs to fair value.

d) Fair value hierarchy

ING Group has categorised its financial instruments that are either measured in the statement of financial position

at fair value or of which the fair value is disclosed, into a three level hierarchy based on the observability of the

valuation inputs. Highest priority is retained to unadjusted quoted prices in active markets for identical assets or

liabilities and the lowest priority to valuation techniques supported by unobservable inputs.

Transfers into and transfers out of fair value hierarchy levels are made on a quarterly basis at the end of the

reporting period.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-290

Level 1 – (Unadjusted) quoted prices in active markets

This category includes financial instruments whose fair value is determined directly by reference to (unadjusted)

quoted prices in an active market. A financial instrument is regarded as quoted in an active market if quoted prices

are readily and regularly available from an exchange, dealer markets, brokered markets, or principal to principal

markets. Those prices represent actual and regularly occurring market transactions with sufficient frequency and

volume to provide pricing information on an ongoing basis. Transfers out of Level 1 into Level 2 or Level 3 occur

when ING Group establishes that markets are no longer active and therefore (unadjusted) quoted prices no longer

provide reliable pricing information.

Level 2 – Valuation technique supported by observable inputs

This category includes financial instruments whose fair value is based on market observable inputs, either directly

or indirectly, other than quoted prices included within Level 1. The fair value for financial instruments in this

category can be determined by reference to quoted prices for similar instruments in active markets, quoted prices

for identical or similar instruments in markets that are not active, inputs other than quoted prices that are

observable or market-corroborated inputs. ING analyses how the prices are derived and determines whether the

prices are liquid tradable prices or model-based consensus prices taking various data as inputs.

For financial instruments that do not have a reference price available, fair value is determined using a valuation

technique (e.g., a model), where inputs in the model are taken from an active market or are observable, such as

interest rates and yield curves observable at commonly quoted intervals, implied volatilities, and credit spreads.

Instruments where inputs are unobservable are classified in this category, provided that the impact of those

unobservable inputs on the overall valuation is insignificant. The notion of significant is particularly relevant for the

distinction between Level 2 and Level 3 assets and liabilities, as the significance assessment of the valuation input

on the entire fair value measurement will determine whether the instrument should be classified as Level 2 or

Level 3. Expert judgement is required on the significance assessment approach.

Level 3 – Valuation technique supported by unobservable inputs

This category includes financial instruments whose fair value is determined using a valuation technique for which

a significant part of the overall valuation is driven by unobservable valuation inputs. Where valuation inputs are

unobservable, the Group must use the best information available to value the instruments. This may require

internally derived inputs taking into account market participants' assumptions that are reasonably available,

including assumptions on the risk inherent in a particular valuation technique used to measure fair value and the

risk inherent in the inputs to the valuation technique. Unobservable inputs may include, among others, volatility,

correlation, spreads to discount rates, default rates, recovery rates, prepayment rates, and certain credit spreads.

Financial instruments at fair value

The fair values of the financial instruments were determined as follows:


Methods applied in determining fair values of financial assets and liabilities (carried at fair value)
	Level 1		Level 2		Level 3		Total
in EUR million	2025	2024	2025	2024	2025	2024	2025	2024
Financial Assets
Financial assets at fair value through profit or loss
- Equity securities	21,392	20,789	4	15	187	141	21,583	20,945
- Debt securities	6,492	7,485	2,793	4,596	1,934	3,505	11,219	15,586
- Derivatives	52	1	25,178	31,792	773	475	26,003	32,268
- Loans and receivables	0	0	65,811	62,168	8,542	6,614	74,352	68,782
	27,937	28,275	93,785	98,571	11,435	10,734	133,157	137,580
Financial assets at fair value through other comprehensive income
- Equity securities	2,301	2,292	0	0	307	270	2,607	2,562
- Debt securities	49,529	39,859	1,288	2,360	0	0	50,817	42,219
- Loans and receivables	0	0	3,238	1,608	0	0	3,238	1,608
	51,829	42,151	4,526	3,967	307	270	56,662	46,389
Financial liabilities
Financial liabilities at fair value through profit or loss
– Debt securities	1,540	1,455	7,284	8,445	15	67	8,839	9,966
– Deposits	0	0	47,120	45,014	0	0	47,120	45,014
– Trading securities	2,534	3,631	11	12	9	10	2,554	3,653
– Derivatives	152	45	21,090	27,528	777	694	22,019	28,267
	4,226	5,131	75,505	80,998	802	770	80,532	86,900

The following methods and assumptions were used by ING Group to estimate the fair value of the financial

instruments:

Equity securities

Instrument description: Equity securities include stocks and shares, corporate investments and private equity

investments.

Valuation: If available, the fair values of publicly traded equity securities and private equity securities are based on

quoted market prices. In the absence of active markets, fair values are estimated by analysing the investee’s

financial position, result, risk profile, prospect, price, earnings comparisons and revenue multiples. Additionally,

reference is made to valuations of peer entities where quoted prices in active markets are available. For equity


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-291

securities, best market practice will be applied using the most relevant valuation method. All non-listed equity

investments, including investments in private equity funds, are subject to a standard review framework which

ensures that valuations reflect the fair values.

Fair value hierarchy: The majority of equity securities are publicly traded, and quoted prices are readily and

regularly available. Hence, these securities are classified as Level 1. Equity securities which are not traded in active

markets mainly include corporate investments, fund investments and other equity securities and are classified as

Level 3.

Debt securities

Instrument description: Debt securities include government bonds, financial institutions bonds and Asset-backed

securities (ABS).

Valuation: Where available, fair values for debt securities are generally based on quoted market prices. Quoted

market prices are obtained from an exchange market, dealer, broker, industry group, pricing service, or regulatory

service. The quoted prices from non-exchange sources are reviewed on their tradability of market prices. If quoted

prices in an active market are not available, fair value is based on an analysis of available market inputs, which

include consensus prices obtained from one or more pricing services. Furthermore, fair values are determined by

valuation techniques discounting expected future cash flows using market interest rate curves, referenced credit

spreads, maturity of the investment, and estimated prepayment rates where applicable.

Fair value hierarchy: Government bonds and financial institution bonds are generally traded in active markets.

Where quoted prices are readily and regularly available, they are classified as Level 1. The remaining positions are

classified as Level 2 or Level 3 depending on the trading activity and observability of prices. Asset backed securities

for which no active market is available and a wide discrepancy in quoted prices exists, are classified as Level 3.

Derivatives

Instrument description: Derivative contracts can either be exchange-traded or over the counter (OTC). Derivatives

include interest rate derivatives, FX derivatives, credit derivatives, equity derivatives and commodity derivatives.

Valuation: The fair value of exchange-traded derivatives is determined using quoted market prices in an active

market and are classified as Level 1 of the fair value hierarchy. For instruments that are not actively traded, fair

values are estimated based on valuation techniques. OTC derivatives and derivatives trading in an inactive market

are valued using valuation techniques. The valuation techniques and inputs depend on the type of derivatives and

the nature of the underlying instruments. The principal techniques used to value these instruments are based on,

among others, discounted cash flows, option pricing models and Monte Carlo simulations. These valuation models

calculate the present value of expected future cash flows, based on ‘no-arbitrage’ principles. The models are

commonly used in the financial industry and inputs to the validation models are determined from observable

market data where possible. Certain inputs may not be observable in the market, but can be determined from

observable prices via valuation model calibration procedures. These inputs include prices available from

exchanges, dealers, brokers or providers of pricing, yield curves, credit spreads, default rates, recovery rates,

dividend rates, volatility of underlying interest rates, equity prices, and foreign currency exchange rates and

reference is made to quoted prices, recently executed trades, independent market quotes and consensus data,

where available. For uncollateralised OTC derivatives, ING applies Credit Valuation Adjustment to correctly reflect

the counterparty credit risk in the valuation and Debit Valuation Adjustments to reflect the credit risk of ING for its

counterparty. In addition, for these derivatives ING applies Funding Valuation Adjustment. See sections CVA/DVA

and FVA in section c) Valuation Adjustments for more details regarding the calculation.

Fair value hierarchy: The majority of the derivatives are priced using observable inputs and are classified as Level

2. Derivatives for which the input cannot be implied from observable market data are classified as Level 3.

Loans and receivables

Instrument description: Loans and receivables are non-derivative financial assets with fixed or determinable

payments that are not quoted in an active market. Loans and receivables carried at fair value include trading

loans, being securities lending and similar agreement comparable to collateralised lending, syndicated loans, loans

expected to be sold and receivables with regards to reverse repurchase transactions.

Valuation: The fair value of loans and receivables is generally estimated by discounting expected future cash flows

using a discount rate that reflects credit risk, liquidity, and other current market conditions. The fair value of

mortgage loans is estimated by taking into account prepayment behaviour.

Fair value hierarchy: Loans and receivables are predominantly classified as Level 2. Loans and receivables for

which current market information about similar assets to use as observable, corroborated data for all significant

inputs into a valuation model is not available, are classified as Level 3.

Financial liabilities at fair value through profit and loss

Instrument description: Financial liabilities at fair value through profit and loss include debt securities and debt

instruments, primarily comprised of structured notes, which are held at fair value under the fair value option.

Besides that, they include derivative contracts and repurchase agreements.

Valuation: The fair values of securities in the trading portfolio and other liabilities at fair value through profit or loss

are based on quoted market prices, where available. For those securities not actively traded, fair values are

estimated based on internal discounted cash flow valuation techniques using interest rates and credit spreads that

apply to similar instruments.

Fair value hierarchy: The majority of the derivatives and debt instruments are classified as Level 2. Derivatives and

debt instruments for which the input cannot be derived from observable market data are classified as Level 3.

e) Transfers between Level 1 and 2

As a consequence of change in observable inputs, ING recorded for financial assets measured at fair value through

profit or loss a EUR 0.3 billion (2024: nil) transfer from Level 1 to Level 2 and a EUR 0.4 billion (2024: EUR 0.8 billion)

transfer from Level 2 to Level 1 within debt securities. For financial liabilities measured at fair value through profit

or loss, EUR 0.2 billion (2024: nil) of trading securities were transferred from Level 2 to Level 1. No other significant

transfers between Level 1 and Level 2 were recorded during the 2025 reporting period (2024: nil).


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-292

f) Level 3: Valuation techniques and inputs used

Financial assets and liabilities in Level 3 include both assets and liabilities for which the fair value was determined

using (i) valuation techniques that incorporate unobservable inputs as well as (ii) quoted prices which have been

adjusted to reflect that the market was not actively trading at or around the balance sheet date. Unobservable

inputs are inputs which are based on ING’s own assumptions about the factors that market participants would use

in pricing an asset or liability, developed based on the best information available in the circumstances.

Unobservable inputs may include volatility, correlation, spreads to discount rates, default rates and recovery rates,

prepayment rates, and certain credit spreads. Valuation techniques that incorporate unobservable inputs are

sensitive to the inputs used.

Of the total amount of financial assets classified as Level 3 as at 31 December 2025 of EUR 11.7 billion (2024: EUR

11.0 billion), an amount of EUR 10.1 billion (86.2%) (2024: EUR 9.6 billion, being 87.2%) is based on unadjusted

quoted prices in inactive markets. As ING does not generally adjust quoted prices using its own inputs, there is no

significant sensitivity to ING’s own unobservable inputs.

Furthermore, Level 3 financial assets include EUR 0.1 billion (2024: EUR 0.1 billion) which relates to financial assets

that are part of structures that are designed to be fully neutral in terms of market risk. Such structures include

various financial assets and liabilities for which the overall sensitivity to market risk is insignificant. Whereas the

fair value of individual components of these structures may be determined using different techniques and the fair

value of each of the components of these structures may be sensitive to unobservable inputs, the overall

sensitivity is by design not significant.

The remaining EUR 1.5 billion (2024: EUR 1.3 billion) of the fair value classified in Level 3 financial assets is

established using valuation techniques that incorporate certain inputs that are unobservable.

Of the total amount of financial liabilities classified as Level 3 as at 31 December 2025 of EUR 0.8 billion (2024: EUR

0.8 billion), an amount of EUR 0.6 billion (72.7%) (2024: EUR 0.6 billion, being 75.7%) is based on unadjusted quoted

prices in inactive markets. As ING does not generally adjust quoted prices using its own inputs, there is no

significant sensitivity to ING’s own unobservable inputs.

Furthermore, Level 3 financial liabilities include EUR 0.1 billion (2024: EUR 0.1 billion) which relates to financial

liabilities that are part of structures that are designed to be fully neutral in terms of market risk. As explained

above, the fair value of each of the components of these structures may be sensitive to unobservable inputs, but

the overall sensitivity is by design not significant.

The remaining EUR 0.1 billion (2024: EUR 0.1 billion) of the fair value classified in Level 3 financial liabilities is

established using valuation techniques that incorporates certain inputs that are unobservable.

The table below provides a summary of the valuation techniques, key unobservable inputs and the lower and

upper range of such unobservable inputs, by type of Level 3 asset/liability. The lower and upper range mentioned

in the overview represent the lowest and highest variance of the respective valuation input as actually used in the

valuation of the different financial instruments. Amounts and percentages stated are unweighted. The range can

vary from period to period subject to market movements and change in Level 3 position. Lower and upper bounds

reflect the variability of Level 3 positions and their underlying valuation inputs in the portfolio, but do not

adequately reflect their level of valuation uncertainty. For valuation uncertainty assessment, reference is made to

section Sensitivity analysis of unobservable inputs (Level 3).


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Valuation techniques and range of unobservable inputs (Level 3)
	Assets		Liabilities		Valuation techniques	Significant unobservable inputs	Lower range		Upper range
In EUR million	2025	2024	2025	2024			2025	2024	2025	2024
At fair value through profit or loss
Debt securities	1,934	3,504	9	10	Price based	Price (%)	0%	0%	103%	120%
						Price (price per share)	201	327	412	520
					Present value techniques	Price (%)	n.a.	95.85%	n.a.	100%
Equity securities	187	141			Price based	Price (price per share)	0	0	5,475	5,475
Loans and advances	1,978	1,565	0	0	Price based	Price (%)	0%	0%	109%	107%
					Present value techniques	Credit spread (bps)	120	576	709	629
						Prepayment rate (%)	2%	2%	2%	100%
(Reverse) repos	6,563	5,050			Present value techniques	Interest rate (%)	n.a.	2%	n.a.	2%
Structured notes			15	67	Price based	Price (%)	96%	93%	103%	104%
					Option pricing model	Equity volatility (%)	18%	n.a.	22%	n.a.
						Equity/Equity correlation	0.7	0.7	0.8	0.7
						Equity/FX correlation	-0.6	n.a.	0.2	n.a.
						Dividend yield (%)	0.4%	n.a.	1.9%	n.a.
					Present value techniques	Prepayment rate (%)	n.a.	99.59%	n.a.	100.09%
Derivatives
– Rates	628	413	670	389	Option pricing model	Interest rate volatility (bps)	45	n.a.	91	n.a.
					Present value techniques	Reset spread (%)	1%	2%	1%	2%
– FX	2	6	4	8	Option pricing model	Implied volatility (%)	1.7%	2%	42%	15%
– Credit	134	39	48	241	Present value techniques	Credit spread (bps)	10	0	88	91
					Price based	Price (%)	0%	0%	100%	100%
– Equity	7	10	46	47	Option pricing model	Equity volatility (%)	13%	7%	75%	81%
						Equity/Equity correlation	0.0	0.0	1.0	1.0
						Equity/FX correlation	-0.7	-0.6	0.5	0.6
						Dividend yield (%)	0%	0%	51%	33%
– Other	2	6	10	9	Option pricing model	Commodity volatility (%)	20%	13.1%	76%	61%
						Com/FX correlation	-0.25	-0.40	-0.25	-0.25
					Price based	Price (commodity)	66	68	66	68
At fair value through other comprehensive income
– Equity	307	270			Present value techniques	Credit spread (bps)	5.15	5.67	5.15	5.76
						Interest rate (%)	2.5%	1.5%	2.5%	3.5%
						Payout ratio (%)	70%	70%	90%	90%
					Price based	Price (%)	n.a.	122%	n.a.	122%
						Price (price per share)	126	n.a	126	n.a
Total	11,742	11,005	802	770

1The abbreviation n.a. stands for not applicable or not available.


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Price

For securities where market prices are not available, fair value is measured by comparison with observable pricing

data from similar instruments. Prices of 0% are distressed to the point that no recovery is expected, while prices

significantly in excess of 100% or par are expected to pay a yield above current market rates.

Credit spreads

Credit spread is the premium above a benchmark interest rate required by the market participant to accept a

lower credit quality. Higher credit spreads indicate lower credit quality and a lower value of an asset.

Volatility

Volatility is a measure for variation of the price of a financial instrument or other valuation input over time.

Volatility is one of the key inputs in option pricing models. Typically, the higher the volatility, the higher value of

the option. Volatility varies by the underlying reference (equity, commodity, foreign currency and interest rates),

by strike, and maturity of the option. The minimum level of volatility is 0% and there is no theoretical maximum.

Correlation

Correlation is a measure of dependence between two underlying references which is relevant for valuing

derivatives and other instruments having more than one underlying reference. High positive correlation (close to 1)

indicates a strong positive (statistical) relationship, where underliers move, everything else equal, into the same

direction. The same holds for a high negative correlation.

Interest rate

An interest rate is the amount of interest due per period, as a proportion of the amount lent, deposited, or

borrowed.

Reset spread

Reset spreads are key inputs to mortgage-linked prepayment swaps valuation. Reset spread is the future spread at

which mortgages will re-price at interest rate reset dates.

Dividend yield

Dividend yield is an important input for equity option pricing models showing how much dividends a company is

expected to pay out each year relative to its share price. Dividend yields are generally expressed as an annualised

percentage of share price.

Payout ratio

Dividend payout ratio is an input that shows the percentage of dividends a company is expected to pay out each

year relative to its net income.

Prepayment rate

Prepayment rate is a key input to mortgage and loan valuation. Prepayment rate is the estimated rate at which

mortgage borrowers will repay their mortgages early, e.g. 5% per year. Prepayment rate and reset spread are key

inputs to mortgage-linked prepayment swaps valuation.


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Level 3: Changes during the period


Changes in Level 3 Financial assets
	Trading assets		Non-trading derivatives		Financial assets mandatorily at FVPL		Financial assets designated at FVPL		Financial assets at FVOCI		Total
	Trading assets		Non-trading derivatives		Financial assets mandatorily at FVPL		Financial assets designated at FVPL		Financial assets at FVOCI		Total
In EUR million	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024
Opening balance as at 1 January	824	848	68	286	5,721	3,499	4,121	3,547	270	938	11,005	9,118
Realised gain/loss recognised in the statement of profit or loss during the period 1	247	-175	63	-38	211	294	-798	-54			-278	28
Revaluation recognised in other comprehensive income during the period 2									8	-3	8	-3
Purchase of assets	953	486	0	198	5,177	4,424	1,208	1,600	182	154	7,520	6,862
Sale of assets	-109	-111	0	-257	-1,765	-1,605	-1,160	-10	-163	-418	-3,197	-2,402
Maturity/settlement	-128	-140	0	-7	-166	-294	-763	-988	0	-20	-1,057	-1,449
Reclassifications	0	0	-1	0	18	0	0	0	10	0	28	0
Transfers into Level 3	316	370	0	0	824	615	0	30	0	0	1,139	1,014
Transfers out of Level 3	-974	-454	-9	-114	-2,389	-1,214	0	-3	0	-384	-3,372	-2,169
Exchange rate differences	-14	0	0	0	-6	5	-33	-2	0	9	-53	12
Changes in the composition of the group and other changes	0	0	0	0	0	-1	0	0	0	-5	0	-6
Closing balance	1,114	824	121	68	7,625	5,721	2,576	4,121	307	270	11,742	11,005

1Net gains/losses were recorded as ‘Valuation results and net trading income’ in the statement of profit or loss. The total amounts includes EUR 280 million (2024: EUR -41 million) of unrealised gains and losses recognised in the statement of profit or loss.

2Revaluation recognised in other comprehensive income is included on the line ‘Net change in fair value of debt instruments at fair value through other comprehensive income’.

In 2025, transfers out of Level 3 within trading assets relate mainly to securities, as their valuations were no longer

significantly influenced by unobservable inputs. In 2024, transfers out of Level 3 in trading assets primarily

involved derivative instruments, as their valuations were no longer significantly impacted by unobservable inputs.

In 2025 and 2024, the transfer into Level 3 trading assets consisted of cross currency swap trades, which were

transferred to Level 3 as a result of the valuation being significantly impacted by unobservable inputs. In 2024, the

transfer out of Level 3 in non-trading derivatives primarily involved derivative instruments, as their valuations were

no longer significantly impacted by unobservable inputs.

In 2025 and 2024, transfers into and out of Level 3 of financial assets mandatorily at fair value mainly relate to

(long- term) reverse repurchase transactions for which the valuation being significantly impacted by unobservable

inputs and no longer significantly impacted by unobservable inputs, respectively.

In 2024, the transfer out of Level 3 of financial assets at FVOCI relates to Hold-to-Collect and Sell portfolio

transferred to Level 2 resulting from change in methodology.


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Changes in Level 3 Financial liabilities
	Trading liabilities		Non-trading derivatives		Financial liabilities designated as at fair value through profit or loss		Total
	Trading liabilities		Non-trading derivatives				Total
in EUR million	2025	2024	2025	2024	2025	2024	2025	2024
Opening balance as at 1 January	637	382	67	301	67	47	770	729
Realised gain/loss recognised in the statement of profit or loss during the period1	81	-104	82	-98	-6	-5	157	-206
Additions	205	55	3	190	11	29	219	274
Redemptions	-74	-12	0	-209	0	0	-74	-222
Maturity/settlement	-160	-15	0	-7	-64	-4	-225	-26
Transfers into Level 3	19	364	0	0	19	34	38	399
Transfers out of Level 3	-72	-33	0	-111	-12	-34	-84	-179
Exchange rate differences	-1	0	0	0	0	0	-1	0
Closing balance	636	637	151	67	15	67	802	770

1Net gains/losses were recorded as ‘Valuation results and net trading income’ in the statement of profit or loss. The total amount includes EUR 158

million (2024: EUR -206 million) of unrealised gains and losses recognised in the statement of profit or loss.

In 2025, the transfers out of Level 3 mainly consisted of trading liabilities related to securities transferred out of

Level 3 as a result of the valuation being no longer impacted by significantly unobservable inputs.

In 2024, the transfers into Level 3 mainly consisted of trading liabilities attributed to cross currency swap trades

transferred into Level 3 as a result of the valuation being significantly impacted by unobservable inputs. The

transfers out of Level 3 for non-trading derivatives are driven by interest rate swap trades, which were reclassified

out of Level 3 as their valuations were no longer influenced by significantly unobservable inputs.

g) Recognition of unrealised gains and losses in Level 3

Amounts recognised in the statement of profit or loss relating to unrealised gains and losses during the year that

relate to Level 3 assets and liabilities are included in the line item ‘Valuation results and net trading income’ in the

statement of profit or loss.

h) Level 3: Sensitivity analysis of unobservable inputs

Where the fair value of a financial instrument is determined using inputs which are unobservable and which have

a more than insignificant impact on the fair value of the instrument, the actual value of those inputs at the

balance date may be drawn from a range of reasonably possible alternatives. In line with market practice, the

upper and lower bounds of the range of alternative input values reflect a level of valuation certainty. The actual

levels chosen for the unobservable inputs in preparing the financial statements are consistent with the valuation

methodology used for fair valued financial instruments.

In practice, valuation uncertainty is measured and managed per exposure to individual valuation inputs (i.e. risk

factors) at portfolio-level across different product categories. Where the disclosure looks at individual Level 3

inputs, the actual valuation adjustments may also reflect the benefits of portfolio offsets.

This disclosure does not attempt to indicate or predict future fair value movement. The numbers in isolation give

limited information as in most cases these Level 3 assets and liabilities should be seen in combination with other

instruments (for example as a hedge) that are classified as Level 2.

The valuation uncertainty in the table below is broken down by related risk class rather than by product. The

possible impact of a change of unobservable inputs in the fair value of financial instruments where unobservable

inputs are significant to the valuation is as follows:


Sensitivity analysis of Level 3 instruments
	Positive fair value movements from using reasonable possible alternatives		Negative fair value movements from using reasonable possible alternatives
in EUR million	2025	2024	2025	2024
Equity (equity derivatives, structured notes)	20	21	-12	-20
Interest rates (Rates derivatives, FX derivatives)	1	5	0	0
Credit (Debt securities, Loans, structured notes, credit derivatives)	12	2	-14	-27
Loans and advances	0	0	0	0
	33	28	-26	-47

i) Financial instruments not measured at fair value

The following table presents the estimated fair values of the financial instruments not measured at fair value in

the statement of financial position.


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Methods applied in determining fair values of financial assets and liabilities (carried at amortised cost)
	Carrying Amount		Carrying amount presented as fair value1		Level 1		Level 2		Level 3		Total fair value
in EUR million	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024
Financial Assets
Loans and advances to banks	21,204	21,770	3,053	3,195			14,722	15,614	3,366	2,957	21,141	21,766
Loans and advances to customers	727,733	683,611	18,231	18,291			12,782	18,626	678,392	630,493	709,405	667,410
Securities at amortised cost	53,867	50,273			47,722	42,871	2,381	2,908	2,692	2,523	52,796	48,303
	802,804	755,655	21,284	21,486	47,723	42,871	29,885	37,149	684,450	635,973	783,342	737,479

Financial liabilities
Deposits from banks	18,517	16,723	5,401	4,348			9,162	8,208	3,745	3,943	18,308	16,499
Customer deposits	721,373	691,661	620,999	582,387			82,665	61,916	17,433	46,984	721,097	691,287
Debt securities in issue	151,231	142,367			84,506	79,254	64,028	61,651	3,857	2,000	152,391	142,905
Subordinated loans	18,100	17,878			18,368	17,968	354	389			18,722	18,357
	909,221	868,630	626,401	586,735	102,874	97,221	156,208	132,164	25,035	52,927	910,519	869,048

1In accordance with IFRS and for the purpose of this disclosure, the carrying amount of financial instruments with an immediate on demand feature is presented as fair value.

The aggregation of the fair values presented above does not represent, and should not be construed as

representing, the underlying value of ING Group. These fair values were calculated for disclosure purposes only.

The carrying amount of financial instruments presented in the above table includes, when applicable, the fair value

hedge adjustment.

Loans and advances to banks

For short-term receivables from banks, carrying amounts represent a reasonable estimate of the fair value. The

fair value of long-term receivables from banks is estimated by discounting expected future cash flows using a

discount rate based on specific available market data, such as interest rates and appropriate spreads, that reflects

current credit risk or quoted bonds.

Loans and advances to customers

For short-term loans, carrying amounts represent a reasonable estimate of the fair value. The fair value of long-

term loans is estimated by discounting expected future cash flows using a discount rate that reflects current credit

risk, current interest rates, and other current market conditions where applicable. The fair value of mortgage loans

is estimated by taking into account prepayment behaviour. Loans with similar characteristics are aggregated for

calculation purposes.

Securities at amortised cost

Where available, fair values for debt securities are generally based on quoted market prices. Quoted market prices

are obtained from an exchange market, dealer, broker, industry group, pricing service, or regulatory service. The

quoted prices from non-exchange sources are reviewed on their tradability of market prices. If quoted prices in an

active market are not available, fair value is based on an analysis of available market inputs, which include

consensus prices obtained from one or more pricing services. Furthermore, fair values are determined by valuation

techniques discounting expected future cash flows using market interest rate curves, referenced credit spreads,

maturity of the investment, and estimated prepayment rates where applicable.

Deposits from banks

For short-term payables to banks, carrying amounts represent a reasonable estimate of the fair value. The fair

value of long-term payables to banks is estimated by discounting expected future cash flows using a discount rate

based on available market interest rates and appropriate spreads that reflect ING’s own credit risk.

Customer deposits

There is an embedded value in our on-demand deposits. However, for the purpose of this disclosure, and in

accordance with IFRS, the fair value of deposits with an immediate on demand feature approximates the carrying

amount.


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The fair value of deposits with fixed contractual terms has been estimated based on discounting future cash flows

using the interest rates currently applicable to deposits of similar maturities.

Debt securities in issue

The fair value of debt securities in issue is generally based on quoted market prices, or if not available, on

estimated prices by discounting expected future cash flows using a current market interest rate and credit spreads

applicable to the yield, credit quality and maturity.

Subordinated loans

The fair value of publicly traded subordinated loans are based on quoted market prices when available. Where no

quoted market prices are available, fair value of the subordinated loans is estimated using discounted cash flows

based on interest rates and credit spreads that apply to similar instruments.

36 Derivatives and hedge accounting

Use of derivatives

ING uses derivatives for economic hedging purposes to manage its asset and liability portfolios and structural risk

positions. The primary objective of ING’s hedging activities is to manage the risks which arise from structural

imbalances in the duration and other profiles of its assets and liabilities. The objective of economic hedging is to

enter into positions with an opposite risk profile to an identified risk exposure to reduce that exposure. The main

risks which are being hedged are interest rate risk and foreign currency exchange rate risk. These risks are

primarily hedged with interest rate swaps, cross currency swaps and foreign exchange forwards/swaps.

ING uses credit derivatives to manage its economic exposure to credit risk, including total return swaps and credit

default swaps, to sell or buy protection for credit risk exposures in the loan, investment, and trading portfolios.

Hedge accounting is not applied in relation to these credit derivatives.

Hedge accounting

Derivatives that qualify for hedge accounting under IFRS are classified and accounted for in accordance with the

nature of the instrument hedged and the type of IFRS hedge accounting model that is applicable. The three

models applicable under IFRS are: fair value hedge accounting, cash flow hedge accounting, and hedge accounting

of a net investment in a foreign operation. How and to what extent these models are applied are described under

the relevant headings below. The company’s detailed accounting policies for these three hedge models are set out

in paragraph 1.5 ‘Financial instruments’ of Note 1 ‘Basis of preparation and material accounting policy

information’.

The benchmark rate reform

Reference is made to note 'Risk management / The impact of the benchmark rate reform' for information on how

ING is managing the transition to alternative benchmark rates and ING’s progress in completing the transition with

respect to derivatives in hedge accounting relationships.

Fair value hedge accounting

ING’s fair value hedges principally consist of interest rate swaps that are used to protect against changes in the fair

value of fixed-rate instruments due to movements in market interest rates. ING’s approach to managing market

risk, including interest rate risk, is discussed in ‘Risk management –Market risk’. ING’s exposure to interest rate risk

is disclosed in paragraph ‘Interest rate risk in banking book’.

ING Group designates specific non-contractual risk components of hedged items. This is usually determined by

designating benchmark interest rates such as EURIBOR, SOFR, SONIA or TONAR, among others, because the fair

value of a fixed-rate instrument varies directly in response to changes in its benchmark interest rate.

By using derivative financial instruments to hedge exposures to changes in interest rates, ING also exposes itself to

credit risk of the derivative counterparty, which is not offset by the hedged item. ING minimises counterparty

credit risk in derivative instruments by clearing most of the derivatives through Central Clearing Counterparties. In

addition, ING only enters into transactions with high-quality counterparties and requires posting collateral.

ING Group applies fair value hedge accounting on micro level in which one hedged item is hedged with one or

multiple hedging instruments. Micro fair value hedge accounting is mainly applied on issued debt securities and

purchased debt instruments for hedging interest rate risk.

Before fair value hedge accounting is applied, ING determines whether an economic relationship between the

hedged item and the hedging instrument exists based on an evaluation of the quantitative characteristics of these

items and the hedged risk that is supported by quantitative analysis. ING considers whether the critical terms of

the hedged item and hedging instrument closely align when assessing the presence of an economic relationship.

ING evaluates whether the fair value of the hedged item and the hedging instrument respond similarly to similar

risks. In addition, ING is mainly using regression analysis to assess whether the hedging instrument is expected to

be and has been highly effective in offsetting changes in the fair value of the hedged item.


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ING uses the following derivative financial instruments in a fair value hedge accounting relationship:


Gross carrying value of derivatives designated under fair value hedge accounting
	Assets	Liabilities	Assets	Liabilities
in EUR million	2025	2025	2024	2024
As at 31 December
Hedging instrument on interest rate risk
– Interest rate swaps	2,831	4,294	3,080	5,673
– Other interest derivatives	213	13	207	23
Hedging instrument on FX rate risk
– Cross currency swaps			12	3

The derivatives used for fair value hedge accounting are included in the statement of financial position line-item

‘Financial assets at fair value through profit or loss – Non-trading derivatives’ for EUR 578 million (2024: EUR 617

million) respectively ‘Financial liabilities at fair value through profit or loss – Non-trading derivatives’ EUR 54 million

(2024: EUR 79 million). The difference between the gross carrying value as presented in the table and the net

carrying value as presented in the statement of financial position is due to offsetting with other derivatives and

collaterals paid or received.

For our main currencies the average fixed rate for interest rate swaps used in fair value hedge accounting are

2.16% (2024: 2.08%) for EUR and 4.43% (2024: 4.22%) for USD.

The following table shows the net notional amount of derivatives designated in fair value hedging, split into the

maturity of the instruments. The net notional amounts presented in the table are a combination of payer (-) and

receiver (+) swaps.


Maturity derivatives designated in fair value hedging
in EUR million	Less than 1 month	1 to 3 months	3 to 12 months	1 to 2 years	2 to 3 years	3 to 4 years	4 to 5 years	>5 years	Total
As at 31 December 2025
Hedging instrument on interest rate risk
– Interest rate swaps	1,994	4,453	7,778	6,726	12,149	8,484	4,694	-6,999	39,279
– Other interest derivatives	-3	-31	-211	-348	-457	-297	-274	-1,157	-2,780
As at 31 December 2024
Hedging instrument on interest rate risk
- Interest rate swaps	43	1,224	7,341	14,134	6,313	12,050	7,688	1,564	50,358
– Other interest derivatives	-4	-47	-218	-317	-389	-347	-287	-932	-2,540
Hedging instrument on FX rate risk
– Cross currency swaps	-142	-60	-98						-299

Gains and losses on derivatives designated under fair value hedge accounting are recognised in the statement of

profit or loss. The effective portion of the fair value change on the hedged item is also recognised in the statement

of profit or loss in 'Valuation results and net trading income'. As a result, only the net accounting ineffectiveness

has an impact on the net result.


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Hedged items included in a fair value hedging relationship
	Carrying amount of the hedged items		Accumulated amount of fair value hedge adjustment on the hedged item included in the carrying amount of the hedged item		Change in fair value of the hedged item for measuring ineffectiveness for the period	Change in fair value hedging instruments for the period	Hedge ineffectiveness recognised in the statement of profit or loss gain (+) / loss (-)
in EUR million	Assets	Liabilities	Assets	Liabilities
As at 31 December 2025
Interest rate risk and FX rate risk
– Debt securities at fair value through other comprehensive income	44,165		n/a		-480
– Loans at FVOCI			n/a
– Loans and advances to customers	830		-2		19
– Debt instruments at amortised cost	20,695		-438		-284
– Debt securities in issue		85,843		-2,127	-45
– Subordinated loans		16,794		-327	-287
– Customer deposits and other funds on deposit		26		-1
– Discontinued hedges			33	-1
Total	65,690	102,663	-407	-2,456	-1,078	1,111	34
As at 31 December 2024
Interest rate risk and FX rate risk
– Debt securities at fair value through other comprehensive income	35,119		n/a		269
– Loans at FVOCI			n/a
– Loans and advances to customers	1,149		-6		-35
– Debt instruments at amortised cost	13,802		-179		49
– Debt securities in issue		83,669		-2,234	-1,139
– Subordinated loans		17,131		-665	-188
– Customer deposits and other funds on deposit		28		-1	1
– Discontinued hedges			58	-5
Total	50,070	100,827	-126	-2,906	-1,043	1,016	-27


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-301

During 2025, the interest rate movements significantly affected the fair value changes of both the derivatives and

the hedged items designated in fair value hedges. However, no material hedging relationship was discontinued as

a result of the interest rate movements in 2025. Refer to Note 22 ‘Valuation results and net trading income'. In

addition, the net increase in hedged items is due to higher volumes in debt securities designated in hedge

accounting.

The main sources of ineffectiveness are:

§differences in maturities of the hedged item(s) and hedging instrument(s);

§different interest rate curves applied to discount the hedged item(s) and hedging instrument(s);

§differences in timing of cash flows of the hedged item(s) and hedging instrument(s).

There were no other sources of significant ineffectiveness in these hedging relationships.

Cash flow hedge accounting

ING applies cash flow hedge accounting on a micro and macro level. ING’s cash flow hedges mainly consist of

interest rate swaps and cross-currency swaps that are used to protect against the exposure to variability in future

cash flows on non-trading assets and liabilities that bear interest at variable rates or are expected to be refunded

or reinvested in the future. The amounts and timing of future cash flows, representing both principal and interest

flows, are projected for each portfolio of financial assets and liabilities, based on contractual terms and other

variables including estimates of prepayments. These projected cash flows form the basis for identifying the

notional amount subject to interest rate risk or foreign currency exchange rate risk that is designated under cash

flow hedge accounting.

ING’s approach to manage market risk, including interest rate risk and foreign currency exchange rate risk, is

discussed in ‘Risk management – Market risk’. ING determines the amount of the exposures to which it applies

hedge accounting by assessing the potential impact of changes in interest rates and foreign currency exchange

rates on the future cash flows from its floating-rate assets and liabilities. This assessment is performed using

analytical techniques.

As noted above for fair value hedges, by using derivative financial instruments to hedge exposures to changes in

interest rates and foreign currency exchange rates, ING exposes itself to credit risk of the derivative counterparty,

which is not offset by the hedged items. This exposure is managed similarly to that for fair value hedges.

Gains and losses on the effective portions of derivatives designated under cash flow hedge accounting are

recognised in Other Comprehensive Income. Interest cash flows on these derivatives are recognised in the

statement of profit or loss in ‘Net interest income’ consistent with the manner in which the forecasted cash flows

affect the net result. The gains and losses on ineffective portions of such derivatives are recognised immediately in

the statement of profit or loss in ‘Valuation results and net trading income’.

ING determines an economic relationship between the cash flows of the hedged item and the hedging instrument

based on an evaluation of the quantitative characteristics of these items and the hedged risk that is supported by

quantitative analysis. ING considers whether the critical terms of the hedged item and hedging instrument closely

align when assessing the presence of an economic relationship. ING evaluates whether the cash flows of the

hedged item and the hedging instrument respond similarly to the hedged risk, such as the benchmark interest

rate of foreign currency. In addition, a regression analysis is performed to assess whether the hedging instrument

is expected to be and has been highly effective in offsetting changes in the fair value of the hedged item.

ING uses the following derivative financial instruments in a cash flow hedge accounting relationship:


Gross carrying value of derivatives used for cash flow hedge accounting
	Assets	Liabilities	Assets	Liabilities
in EUR million	2025	2025	2024	2024
As at 31 December
Hedging instrument on interest rate risk
– Interest rate swaps	9,414	10,066	10,635	12,814
Hedging instrument on FX rate risk
– Cross currency swaps	1,042	139	472	339
Hedging instrument on combined interest and FX rate risk
– Cross currency interest rate swaps	63			10

The derivatives used for cash flow hedge accounting are included in the statement of financial position line-item

‘Financial assets at fair value through profit or loss – Non-trading derivatives’ EUR 459 million (2024: EUR 158

million) respectively ‘Financial liabilities at fair value through profit or loss – Non-trading derivatives’ EUR 254

million (2024: EUR 573 million). The difference between the gross carrying value as presented in the table and the

net carrying value as presented in the statement of financial position is due to offsetting with other derivatives and

collaterals paid or received.

For the main currencies the average fixed rate for interest rate swaps used in cash flow hedge accounting are

1.81% (2024: 1.79%) for EUR, 4.27% (2024: 4.37%) for PLN, 3.85% (2024: 3.99%) for USD and 3.38% (2024: 3.29%)

for AUD. The average currency exchange rates for cross currency interest rate swaps used in cash flow hedge

accounting is for EUR/USD 0.97 (2024: 1.03) and for EUR/AUD 1.56 (2024: 1.52).


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The following table shows the net notional amount of derivatives designated in cash flow hedging split into the

maturity of the instruments. The net notional amounts presented in the table are a combination of payer (+) and

receiver (-) swaps.


Maturity derivatives designated in cash flow hedging
in EUR million	Less than 1 month	1 to 3 months	3 to 12 months	1 to 2 years	2 to 3 years	3 to 4 years	4 to 5 years	>5 years	Total
As at 31 December 2025
Hedging instrument on interest rate risk
– Interest rate swaps	-2,023	-3,542	-6,217	-15,357	-14,152	-4,549	-4,381	-11,676	-61,897
Hedging instrument on FX rate risk
– Cross currency swaps	456	964	654	-1,271	-446	607	-601	-1,572	-1,210
Hedging instrument on combined interest and FX rate risk
– Cross currency interest rate swaps				-1,246	-1,518				-2,765
As at 31 December 2024
Hedging instrument on interest rate risk
– Interest rate swaps	-1,805	-768	-10,590	-13,389	-10,551	-6,040	-4,522	-3,222	-50,886
Hedging instrument on FX rate risk
– Cross currency swaps		-241	-972	122	-1,029	-262	-238	-999	-3,619
Hedging instrument on combined interest and FX rate risk
– Cross currency interest rate swaps			-25		-1,283	-1,578			-2,887

The following table shows the cash flow hedge accounting impact on profit or loss and comprehensive income:


Cash flow hedging – impact of hedging instruments on the statement of profit or loss and other comprehensive income
in EUR million	Change in value of hedged item used for calculating hedge ineffectiveness for the period	Carrying amount cash flow hedge reserve at the end of the reporting period1	Amount reclassified from CFH reserve to profit or loss2	Change in value of hedging instrument recognised in OCI for the period	Hedge ineffectiveness recognised in the statement of profit or loss, gain (+) / loss (-)
As at 31 December 2025
Interest rate risk on:
– Floating rate lending	-1,265	-1,157	536
– Floating rate borrowing	289	-141	-146
– Other
– Discontinued hedges		-323	7
Total interest rate risk	-977	-1,619	397	602	7
FX rate risk on:
– Floating rate lending	-15	-58	-171
– Floating rate borrowing	34	-4	-38
– Other
– Discontinued hedges			-1
Total FX risk	20	-62	-209	195	3
Combined interest and FX rate risk on:
– Floating rate lending	37	47	-39
– Floating rate borrowing
– Other
– Discontinued hedges
Total combined interest and FX risk	37	47	-39	2	1
Total cash flow hedge	-920	-1,635	149	799	10


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-303


Cash flow hedging – impact of hedging instruments on the statement of profit or loss and other comprehensive income
in EUR million	Change in value of hedged item used for calculating hedge ineffectiveness for the period	Carrying amount cash flow hedge reserve at the end of the reporting period1	Amount reclassified from CFH reserve to profit or loss2	Change in value of hedging instrument recognised in OCI for the period	Hedge ineffectiveness recognised in the statement of profit or loss, gain (+) / loss (-)
As at 31 December 2024
Interest rate risk on:
– Floating rate lending	-668	-2,850	496
– Floating rate borrowing	114	125	-425
– Other	1	1
– Discontinued hedges		89	-51
Total interest rate risk	-553	-2,635	20	526	39
FX rate risk on:
– Floating rate lending	-79	-55	-121
– Floating rate borrowing	12	5	-37
– Other
– Discontinued hedges			-4
Total FX risk	-67	-51	-162	220	-3
Combined interest and FX rate risk on:
– Floating rate lending	70	72	-68
– Floating rate borrowing
– Other
– Discontinued hedges
Total combined interest and FX risk	70	72	-68	-3	-2
Total cash flow hedge	-550	-2,614	-209	743	35

1The carrying amount is the gross amount, excluding tax adjustments.

2The amounts are reclassified to Net interest income - interest income and/or expense on non-trading derivatives (hedge accounting).

In 2025, EUR -1 million was reclassified from CFH reserve to profit or loss for cash flows that are no longer expected

to occur (2024: nil).

The increase in the carrying amount of the cash flow hedge reserve is driven by the interest rate movements. No

material hedging relationship was discontinued as a result of the interest rate movements in 2025.

The main sources of ineffectiveness for cash flow hedges are:

§differences in timing of cash flows of the hedged item(s) and hedging instrument(s);

§mismatches in reset frequency between hedged item and hedging instrument.

The following table shows the movement of the cash flow hedge reserve:


Movement cash flow hedge reserve
in EUR million	2025	2024
Opening balance	-1,693	-2,058
Value changes recognised in OCI	799	743
Amounts recycled to profit or loss	149	-209
Income tax	-175	-140
Exchange rate and other changes	-12	-14
Adjustment for non controlling interest	-163	-14
Movement for the year	597	365
Ending balance	-1,096	-1,693

Hedges of net investments in foreign operations

A foreign currency exposure arises from a net investment in subsidiaries that have a different functional currency

from the presentation currency of ING. The risk arises from the fluctuation in spot exchange rates between the

functional currency of the subsidiaries and ING’s presentation currency, which causes the amount of the net

investment to vary in the consolidated financial statements of ING. This risk may have a significant impact on ING’s

financial statements. ING’s policy is to hedge these exposures only when these are expected to have a significant

impact on the regulatory capital ratios of ING and its subsidiaries.

ING’s net investment hedges principally consist of derivatives (including currency forwards and swaps) and non-

derivative financial instruments such as foreign currency denominated funding. When the hedging instrument is

foreign currency-denominated debt, ING assesses effectiveness by comparing past changes in the carrying

amount of the debt that are attributable to a change in the spot rate with past changes in the investment in the

foreign operation due to movement in the spot rate (the offset method).

Gains and losses on the effective portions of derivatives designated under net investment hedge accounting are

recognised in Other Comprehensive Income. The balance in equity is recognised in the statement of profit or loss

when the related foreign subsidiary is disposed of. The gains and losses on ineffective portions are recognised

immediately in the statement of profit or loss in 'Valuation results and net trading income'.

ING has the following derivative financial instruments used for net investment hedging:


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Gross carrying value of derivatives used for net investment hedging
	Assets	Liabilities	Assets	Liabilities
in EUR million	2025	2025	2024	2024
As at 31 December
– FX forwards and Cross currency swaps	68	74	82	117

The derivatives used for net investment hedge accounting are included in the statement of financial position line-

item ‘Financial assets at fair value through profit or loss – Non-trading derivatives’ EUR 68 million (2024: EUR 82

million) respectively ‘Financial liabilities at fair value through profit or loss – Non trading derivatives’ EUR 74 million

(2024: EUR 117 million).

For ING’s main currencies the average exchange rates used in net investment hedge accounting for 2025 are EUR/USD

1.12 (2024: 1.08), EUR/PLN 4.24 (2024: 4.31), EUR/AUD 1.75 (2024: 1.64) and EUR/THB 36.98 (2024: 38.00).

The following table shows the notional amount of derivatives designated in net investment hedging split into the

maturity of the instruments:


Maturity derivatives designated in net investment hedging
in EUR million	Less than 1 month	1 to 3 months	3 to 12 months	1 to 2 years	2 to 3 years	3 to 4 years	4 to 5 years	>5 years	Total
As at 31 December 2025
– FX forwards and cross currency swaps	-6,683	-4,298	-86						-11,066
As at 31 December 2024
– FX forwards and Cross currency swaps	-8,681	-4,158	-76						-12,916

The effect of the net investment hedge accounting in the statement of profit or loss and other comprehensive

income is as follows:


Net investment hedge accounting – Impact on statement of profit or loss and other comprehensive income
in EUR million	Change in value of hedged item used for calculating hedge ineffectiveness for the period	Carrying amount net investment hedge reserve at the end of the reporting period1	Hedged item affected statement of profit or loss	Change in value of hedging instrument recognised in OCI	Hedge ineffectiveness recognised in the statement of profit or loss, gain(+) / Loss(-)
As at 31 December 2025
Investment in foreign operations	-816	488		816
Discontinued hedges		535
As at 31 December 2024
Investment in foreign operations	295	-95		-295
Discontinued hedges		302

1The carrying amount is the gross amount, excluding tax adjustments.


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37 Assets by contractual maturity

Amounts presented by contractual maturity are the amounts as presented in the statement of financial position and are discounted cash flows. Reference is made to ‘Risk Management – Funding and liquidity risk’.


Assets by contractual maturity
in EUR million						Maturity not applicable
2025	Less than 1 month 1	1-3 months	3-12 months	1-5 years	Over 5 years	Maturity not applicable	Total
Cash and balances with central banks	52,889						52,889
Loans and advances to banks	12,910	1,581	3,735	2,258	720		21,204
Financial assets at fair value through profit or loss
– Trading assets	20,958	3,508	7,988	11,974	11,302		55,730
– Non-trading derivatives	160	62	185	517	732		1,657
– Mandatorily at fair value through profit or loss	31,075	14,907	14,182	9,967	1,881	310	72,322
– Designated as at fair value through profit or loss	14	233	383	1,698	1,120		3,448
Financial assets at fair value through other comprehensive income
– Equity securities						2,607	2,607
– Debt securities	135	628	1,136	23,026	25,892		50,817
– Loans and advances	321	569	654	1,056	639		3,238
Securities at amortised cost	1,714	1,932	5,629	24,150	20,442		53,867
Loans and advances to customers	61,904	23,768	62,643	241,614	337,804		727,733
Other assets 2	5,583	363	1,463	1,015	1,331	5,060	14,817
Total assets	187,664	47,551	97,998	317,273	401,863	7,977	1,060,329
2024
Cash and balances with central banks	70,353						70,353
Loans and advances to banks	16,826	1,254	1,322	1,759	610		21,770
Financial assets at fair value through profit or loss
– Trading assets	22,154	8,044	14,501	16,006	12,192		72,897
– Non-trading derivatives	602	368	465	356	672		2,463
– Mandatorily at fair value through profit or loss	30,002	11,263	7,222	5,931	1,835	228	56,481
– Designated as at fair value through profit or loss	145	198	1,070	2,110	2,217		5,740
Financial assets at fair value through other comprehensive income
– Equity securities						2,562	2,562
– Debt securities	365	456	2,027	18,064	21,307		42,219
– Loans and advances	2	4	94	871	637		1,608
Securities at amortised cost	2,075	2,646	5,729	22,838	16,985		50,273
Loans and advances to customers	53,672	26,456	61,544	219,414	322,526		683,611
Other assets 2	5,488	590	1,058	629	1,107	5,006	13,878
Total assets	201,683	51,279	95,030	287,977	380,089	7,796	1,023,856

1Includes assets on demand.

2Includes assets such as current and deferred tax assets as presented in the consolidated statement of the financial position. Additionally, assets are included in that position where maturities are not applicable such as property and equipment and investments in associates and joint ventures. Due to their nature,

non-financial assets consist mainly of assets expected to be recovered after more than 12 months.


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Liabilities and off-balance sheet commitments by maturity
in EUR million						Maturity not applicable
2025	Less than 1 month 1	1–3 months	3–12 months	1–5 years	Over 5 years	Maturity not applicable	Adjustment 2	Total
Deposits from banks	10,303	2,433	2,392	1,737	1,617		34	18,517
Customer deposits	649,785	26,346	37,769	3,618	2,049		1,805	721,373
Financial liabilities at fair value through profit or loss
– Other trading liabilities	704	48	110	1,028	610		247	2,745
– Trading derivatives	2,509	2,290	4,604	7,508	2,459		1,311	20,681
– Non-trading derivatives	170	199	229	304	128		309	1,338
– Designated at fair value through profit or loss	39,279	6,980	937	4,112	4,560	36	-136	55,768
Debt securities in issue	3,300	18,814	40,682	55,199	34,522		-1,285	151,231
Subordinated loans					10,612	7,627	-140	18,100
Lease liabilities	15	34	172	574	304		-50	1,050
Financial liabilities	706,066	57,144	86,894	74,079	56,862	7,663	2,095	990,803

Other liabilities 3	7,790	843	2,980	2,021	553			14,187

Total liabilities	713,856	57,986	89,874	76,100	57,415	7,663	2,095	1,004,990

Coupon interest due on financial liabilities	1,914	1,358	4,334	10,400	7,275	474		25,754

Commitments:
– Guarantees	28,690			552				29,242
– Irrevocable letters of credit	15,230							15,230
Guarantees issued by ING Groep N.V.	185							185
Irrevocable facilities	200,000	39	6	77	76			200,198
	244,105	39	6	629	76			244,855

1Includes liabilities on demand.

2This column reconciles the contractual undiscounted cash flows on financial liabilities to the statement of financial position values. The adjustments mainly relate to the impact of discounting and fair value hedge adjustments, and for derivatives, to the fact that the contractual cash flows are presented on a gross

basis (unless the cash flows are actually settled net).

3Includes Other liabilities, Current and deferred tax liabilities, and Provisions as presented in the Consolidated statement of financial position.


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Liabilities and off-balance sheet commitments by maturity
in EUR million						Maturity not applicable
2024	Less than 1 month 1	1–3 month	3–12 months	1–5 years	Over 5 years	Maturity not applicable	Adjustment 2	Total
Deposits from banks	9,104	1,367	2,085	1,637	2,484		47	16,723
Customer deposits	610,184	23,312	49,284	4,448	2,081		2,352	691,661
Financial liabilities at fair value through profit or loss
– Other trading liabilities	5,790	230	313	1,325	1,465		-34	9,089
– Trading derivatives	2,631	2,367	3,730	7,641	5,499		4,298	26,166
– Non-trading derivatives	419	57	-36	711	149		801	2,101
– Designated at fair value through profit or loss	32,644	5,842	1,798	5,097	4,367	34	-239	49,543
Debt securities in issue	1,949	18,610	33,037	55,221	34,857		-1,307	142,367
Subordinated loans					9,962	8,415	-499	17,878
Lease liabilities	20	44	162	607	328		-45	1,116
Financial liabilities	662,741	51,829	90,375	76,688	61,191	8,448	5,374	956,646

Other liabilities 3	7,718	530	3,371	1,423	470			13,512

Total liabilities	670,459	52,359	93,745	78,111	61,661	8,448	5,374	970,158

Coupon interest due on financial liabilities	2,284	1,603	5,903	10,191	8,137	514		28,632

Commitments:
– Guarantees	26,355			3	550			26,908
– Irrevocable letters of credit	16,388							16,388
Guarantees issued by ING Groep N.V.	210							210
Irrevocable facilities	175,000	9	15	143	56			175,222
	217,953	9	15	146	606			218,728

1Includes liabilities on demand.

basis (unless the cash flows are actually settled net).

3Includes Other liabilities, Current and deferred tax liabilities, and Provisions as presented in the Consolidated statement of financial position.


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39 Transfer of financial assets, assets pledged and received as collateral

Financial assets pledged as collateral

The financial assets pledged as collateral consist primarily of mortgages pledged to secure covered bonds and

securitisations, deposits from the Dutch Central Bank and other banks, as well as debt and equity securities used in

securities lending or sale and repurchase transactions. They serve to secure margin accounts and are used for

other purposes required by law. Pledges are generally conducted under terms that are usual and customary for

collateralised transactions including standard sale and repurchase agreements, securities lending and borrowing

and derivatives margining. The financial assets pledged are as follows:


Financial assets pledged as collateral
in EUR million	2025	2024
Banks
– Cash and balances with central banks	499	397
– Loans and advances to banks	2,672	2,211
Financial assets at fair value through profit or loss	20,561	28,905
Financial assets at fair value through OCI	1,519	3,037
Securities at amortised cost	3,339	3,184
Loans and advances to customers	71,321	67,706
Other assets	479	503
	100,392	105,944

In some jurisdictions ING Bank N.V. has an obligation to maintain a reserve with central banks. As at 31 December

2025, the minimum mandatory reserve deposits with various central banks amount to EUR 11,925 million (2024:

EUR 11,648 million).

Financial assets received as collateral

The financial assets received as collateral that can be sold or repledged in absence of default by the owner of the

collateral consists of securities obtained through reverse repurchase transactions and securities borrowing

transactions.

These transactions are generally conducted under standard market terms for most repurchase transactions and

the recipient of the collateral has an unrestricted right to sell or repledge it, provided that the collateral (or

equivalent collateral) is returned to the counterparty at term.


Financial assets received as collateral
in EUR million	2025	2024
Total received collateral available for sale or repledge at fair value
– equity securities	21,494	22,815
– debt securities	144,257	140,285

of which sold or repledged at fair value
– equity securities	16,018	12,024
– debt securities	98,422	90,708

Transfer of financial assets

The majority of ING's financial assets that have been transferred, but do not qualify for derecognition, are debt and

equity instruments used in securities lending or sale and repurchase transactions. These transferred financial

assets remain recognized on the balance sheet as ING retains substantially all the risk and rewards of ownership

and remains exposed to the changes in the fair value of the assets.


Transfer of financial assets not qualifying for derecognition
	Securities lending				Sale and repurchase
	Equity		Debt		Equity		Debt
in EUR million	2025	2024	2025	2024	2025	2024	2025	2024
Transferred assets at carrying amount
Financial assets at fair value through profit or loss	4,163	4,141	3	3	5,929	7,273	9,687	16,929
Financial assets at fair value through other comprehensive income			314	603			886	1,956
Securities at amortised cost			399	635			989	819

Associated liabilities at carrying amount1
Financial liabilities at fair value through profit or loss	n/a	n/a	n/a	n/a	5,398	7,005	6,684	11,901

1The table includes the associated liabilities which are reported after offsetting, compared to the gross positions of the encumbered assets.

The table above does not include assets transferred to consolidated securitisation entities as the related assets

remain recognised in the consolidated statement of financial position. Transferred financial assets that are

derecognised in their entirety are mentioned in Note 44 'Structured entities'.


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40 Offsetting financial assets and liabilities

The following tables include information about rights to offset and the related arrangements. The amounts

included consist of all recognised financial instruments that are presented net in the statement of financial

position under the IFRS netting criteria (legal right to offset and intention to settle net or to realise the asset and

settle the liability simultaneously) and amounts presented gross in the statement of financial position but subject

to enforceable master netting arrangements or similar arrangements.

At ING Group, amounts that are offset mainly relate to derivatives transactions, sale and repurchase agreements,

securities lending agreements and cash pooling arrangements. A significant portion of offsetting is applied to OTC

derivatives which are cleared through central clearing parties.

Related amounts not offset in the statement of financial position include transactions where:

§The counterparty has an offsetting exposure and a master netting or similar arrangement is in place with a

right to offset only in the event of default, insolvency or bankruptcy, or the offsetting criteria are otherwise not

satisfied; and

§In the case of derivatives and securities lending or sale and repurchase agreements, cash and non-cash

collateral has been received or pledged to cover net exposure in the event of a default or other predetermined

events. The effect of Over-collateralization is excluded.

The net amounts resulting after offsetting are not intended to represent ING’s actual exposure to counterparty

risk, as risk management employs a number of credit risk mitigation strategies in addition to netting and collateral

arrangements. Reference is made to the Risk Management Credit risk section ‘Credit risk mitigation'.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-311


Financial assets subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million 2025		Gross amounts of recognised financial assets	Gross amounts of recognised financial liabilities offset in the statement of financial position	Net amounts of financial assets presented in the statement of financial position	Related amounts not offset in the statement of financial position		Net amount	Amounts not subject to enforceable netting arrangements	Statement of financial position total ¹
in EUR million 2025		Gross amounts of recognised financial assets			Financial instruments	Cash and financial instruments received as collateral	Net amount	Amounts not subject to enforceable netting arrangements	Statement of financial position total ¹
Statement of financial position line item	Financial instrument
Loans and advances to banks 2	Reverse repurchase, securities borrowing and similar agreements	4,964	-77	4,886		4,859	27	1,949	6,836
		4,964	-77	4,886		4,859	27	1,949	6,836
Financial assets at fair value through profit or loss
Trading and Non-trading	Reverse repurchase, securities borrowing and similar agreements	102,179	-48,514	53,665	26	53,507	132	16,378	70,044
	Derivatives 3	81,453	-59,208	22,245	10,755	3,068	8,421	3,758	26,003
		183,632	-107,722	75,910	10,782	56,575	8,553	20,136	96,047
Loans and advances to customers 4	Reverse repurchase, securities borrowing and similar agreements	3,247	-32	3,215		3,205	9	652	3,866
	Cash pools	211,791	-209,568	2,222	37	1,847	338		2,222
		215,038	-209,601	5,437	37	5,052	347	652	6,089
Other items where offsetting is applied in the statement of financial position 5		742	-657	85	45		39		85

Total financial assets		404,375	-318,057	86,318	10,864	66,487	8,967	22,738	109,056

1‘The statement of financial position total’ is the sum of ‘Net amounts of financial assets presented in the statement of financial position’ and ’Amounts not subject to enforceable master netting arrangements’.

2At 31 December 2025, the total amount of ‘Loans and advances to banks’ excluding repurchase agreements is EUR 14,368 million which is not subject to offsetting.

3Derivative assets and derivative liabilities include certain exchange traded future and option positions with the same underlying.

4At 31 December 2025, the total amount of ‘Loans and advances to customers’ excluding repurchase agreements is EUR 723,867 million of which the net cash pool position of EUR 2,222 million is subject to offsetting.

5Other items include amounts to be settled with Central Clearing Counterparties regarding derivatives transactions and is included in ‘Other Assets – Amounts to be settled’ for EUR 4,076 million in the statement of financial position, of which EUR 85 million is subject to offsetting as at 31 December 2025.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-312


Financial assets subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million 2024		Gross amounts of recognised financial assets	Gross amounts of recognised financial liabilities offset in the statement of financial position	Net amounts of financial assets presented in the statement of financial position	Related amounts not offset in the statement of financial position		Net amount	Amounts not subject to enforceable netting arrangements	Statement of financial position total ¹
in EUR million 2024		Gross amounts of recognised financial assets			Financial instruments	Cash and financial instruments received as collateral	Net amount	Amounts not subject to enforceable netting arrangements	Statement of financial position total ¹
Statement of financial position line item	Financial instrument
Loans and advances to banks 2	Reverse repurchase, securities borrowing and similar agreements	3,752	-31	3,721		3,683	38	7,057	10,777
	Other
		3,752	-31	3,721		3,683	38	7,057	10,777
Financial assets at fair value through profit or loss
Trading and Non-trading	Reverse repurchase, securities borrowing and similar agreements	98,679	-49,365	49,315	219	48,676	420	16,112	65,426
	Derivatives	93,034	-66,877	26,157	17,598	3,643	4,916	6,111	32,268
		191,713	-116,241	75,472	17,818	52,319	5,336	22,222	97,694
Loans and advances to customers 3	Reverse repurchase, securities borrowing and similar agreements	4,444	-1,216	3,228		3,191	37	243	3,471
	Cash pools	237,248	-234,838	2,410	65	1,730	615		2,410
		241,691	-236,053	5,638	65	4,921	652	243	5,881
Other items where offsetting is applied in the statement of financial position 4		6,666	-6,284	382	79		303		382

Total financial assets		443,822	-358,609	85,213	17,962	60,922	6,329	29,522	114,735

2At 31 December 2024, the total amount of ‘Loans and advances to banks’ excluding repurchase agreements is EUR 10,992 million which is not subject to offsetting.

3Derivative assets and derivative liabilities include certain exchange traded future and option positions with the same underlying.

4At 31 December 2024, the total amount of ‘Loans and advances to customers’ excluding repurchase agreements is EUR 683,611 million of which the net cash pool position of EUR 2,410 million is subject to offsetting.

5Other items include amounts to be settled with Central Clearing Counterparties regarding securities and derivatives transactions and is included in ‘Other Assets – Amounts to be settled’ for EUR 3,550 million in the statement of financial position, of which EUR 382 million is subject to offsetting as at 31 December

2024.


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Financial liabilities subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million 2025		Gross amounts of recognised financial liabilities	Gross amounts of recognised financial assets offset in the statement of financial position	Net amounts of financial liabilities presented in the statement of financial position	Related amounts not offset in the statement of financial position		Net amount	Amounts not subject to enforceable netting arrangements	Statement of financial position total ¹
in EUR million 2025		Gross amounts of recognised financial liabilities			Financial instruments	Cash and financial instruments pledged as collateral	Net amount	Amounts not subject to enforceable netting arrangements	Statement of financial position total ¹
Statement of financial position line item	Financial instrument
Deposits from banks 2	Repurchase, securities lending and similar agreements	79	-77	1			1	329	330
	Other	287	-287
		366	-365	1			1	329	330
Customer deposits 4	Repurchase, securities lending and similar agreements	32	-32					182	182
	Cash pools	228,013	-209,568	18,445	8		18,437		18,445
		228,045	-209,601	18,445	8		18,437	182	18,627
Financial liabilities at fair value through profit or loss
Trading and Non-trading	Repurchase, securities lending and similar agreements	84,997	-48,514	36,483	26	36,520	-63	9,760	46,243
	Derivatives 3	71,427	-53,882	17,545	10,783	3,409	3,353	4,474	22,019
		156,424	-102,395	54,028	10,809	39,929	3,291	14,234	68,262

Other items where offsetting is applied in the statement of financial position 5		5,742	-5,697	45	45				45

Total financial liabilities		390,577	-318,057	72,520	10,862	39,929	21,729	14,745	87,265

1‘The statement of financial position total’ is the sum of ‘Net amounts of financial liabilities presented in the statement of financial position’ and ’Amounts not subject to enforceable master netting arrangements’.

2At 31 December 2025, the total amount of ‘Deposits from banks’ excluding repurchase agreements is EUR 18,186 million of which EUR 0 million is subject to offsetting.

3Derivative assets and derivative liabilities include certain exchange traded future and option positions with the same underlying.

4At 31 December 2025, the total amount of ‘Customers deposits’ excluding repurchase agreements is EUR 721,191 million of which the net cash pool position of EUR 18,445 million is subject to offsetting.

5Other items include amounts to be settled with Central Clearing Counterparties regarding derivatives transactions and is included in ‘Other Liabilities – Amounts to be settled’ for EUR 4,188 million in the statement of financial position, of which EUR 45 million is subject to offsetting as at 31 December 2025.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-314


Financial liabilities subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million 2024		Gross amounts of recognised financial liabilities	Gross amounts of recognised financial assets offset in the statement of financial position	Net amounts of financial liabilities presented in the statement of financial position	Related amounts not offset in the statement of financial position		Net amount	Amounts not subject to enforceable netting arrangements	Statement of financial position total ¹
in EUR million 2024		Gross amounts of recognised financial liabilities			Financial instruments	Cash and financial instruments pledged as collateral	Net amount	Amounts not subject to enforceable netting arrangements	Statement of financial position total ¹
Statement of financial position line item	Financial instrument
Deposits from banks 2	Repurchase, securities lending and similar agreements	64	-31	33		33			33
	Other	62	-62
		126	-93	33		33			33
Customer deposits 3	Repurchase, securities lending and similar agreements	1,214	-1,214					1
	Cash pools	251,655	-234,838	16,817	21		16,796		16,817
		252,868	-236,052	16,817	21		16,796	1	16,818
Financial liabilities at fair value through profit or loss
Trading and Non-trading	Repurchase, securities lending and similar agreements	81,384	-49,365	32,019	219	31,669	130	11,671	43,689
	Derivatives	89,386	-67,731	21,655	17,639	2,745	1,272	6,612	28,267
		170,769	-117,095	53,674	17,859	34,414	1,402	18,283	71,956

Other items where offsetting is applied in the statement of financial position 4		5,609	-5,368	242	83		159		242

Total financial liabilities		429,373	-358,608	70,765	17,962	34,447	18,357	18,283	89,049

2At 31 December 2024, the total amount of ‘Deposits from banks’ excluding repurchase agreements is EUR 16,690 million of which EUR 0 million is subject to offsetting.

3Derivative assets and derivative liabilities include certain exchange traded future and option positions with the same underlying.

4At 31 December 2024, the total amount of ‘Customers deposits’ excluding repurchase agreements is EUR 691,661 million of which the net cash pool position of EUR 16,817 million is subject to offsetting.

5Other items include amounts to be settled with Central Clearing Counterparties regarding securities and derivatives transactions and is included in ‘Other Liabilities – Amounts to be settled’ for EUR 4,290 million in the statement of financial position of which EUR 242 million is subject to offsetting as at 31 December

2024.


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41 Commitments

In the normal course of business, ING Group is party to activities where risks are not reflected in whole or in part in

the consolidated financial statements. In response to the needs of its customers, the Group offers financial

products related to loans. These products include traditional off-balance sheet credit-related financial instruments.


Commitments
in EUR million	2025	2024
– Guarantees	29,242	26,908
– Irrevocable letters of credit	15,230	16,388
	44,472	43,296

Guarantees issued by ING Groep N.V.	185	210

Irrevocable facilities	200,198	175,222
	244,855	218,728

Guarantees relate both to credit and non-credit substitute guarantees. Credit substitute guarantees are

guarantees given by ING Group in respect of credit granted to customers by a third party. Many of them are

expected to expire without being drawn on and therefore do not necessarily represent future cash outflows.

Irrevocable letters of credit mainly secure payments to third parties for a customer’s foreign and domestic trade

transactions in order to finance a shipment of goods. ING Group’s credit risk in these transactions is limited since

these transactions are collateralised by the commodity shipped and are of a short duration.

Irrevocable facilities mainly constitute unused portions of irrevocable credit facilities granted to corporate clients.

Many of these facilities are for a fixed duration and bear interest at a floating rate. ING Group’s credit risk and

interest rate risk in these transactions is limited. The unused portion of irrevocable credit facilities is partly secured

by customers’ assets or counter-guarantees by the central governments and other public sector entities under the

regulatory requirements. Irrevocable facilities also include commitments made to purchase securities to be issued

by governments and private issuers. In addition, irrevocable facilities includes certain revocable facilities where the

ability to withdraw such facilities is constrained in practice, and cancellation typically occurs only after a significant

increase in credit risk, these commitments are treated as “in substance irrevocable” and are therefore included

within the scope of the IFRS 9 impairment requirements.

As at 31 December 2025, ING Groep N.V. guarantees various US dollar debentures (that mature on 2026 and 2036)

which were issued by a subsidiary of Voya Financial Inc. In accordance with the Shareholder’s agreement, the net

exposure of ING Groep N.V. as at 31 December 2025 and as at 31 December 2024 was nil, as the outstanding

principal amount of the US dollar debentures was fully covered with collateral of EUR 196 million (2024: EUR 219

million ) pledged by Voya Financial Inc.

ING uses Irrevocable Payment Commitments (IPCs) for a part of its contributions to the Single Resolution Fund

(SRF). ING Group has EUR 346 million of IPCs outstanding to the SRF as at 31 December 2025 (31 December 2024:

EUR 346 million). No IPCs were provided to the SRF during 2025 (2024: nil). No IPCs were called by the SRF in 2025

(2024: nil). Cash collateral provided to the SRF is equal to the outstanding amount of IPCs.

ING also uses IPCs for a part of its contributions to the Deposit Guarantee Scheme in Germany. IPCs amount to EUR

322 million as at 31 December 2025 (31 December 2024: EUR 309 million). Of these, EUR 13 million of IPCs were

provided to the DGS during 2025 (2024: EUR 35 million). No IPCs were called by the DGS in 2025 (2024 : nil). ING

posted government bonds as collateral for the total nominal amount of EUR 336 million as at 31 December 2025

(31 December 2024: EUR 336 million).

In addition to the items included in commitments, ING Group has issued certain guarantees as a participant in

collective arrangements of national banking funds and as a participant in required collective guarantee schemes

which apply in different countries.

ING Bank N.V. provided a guarantee to the German Deposit Guarantee Fund (‘Einlagensicherungsfonds’ or ESF)

under section 5 (10) of the by-laws of this fund, where ING Bank N.V. indemnifies the Association of German Banks

Berlin against any losses it might incur as result of actions taken with respect to ING Germany. The ESF is a

voluntary collective guarantee scheme for retail savings and deposits in excess of EUR 100,000.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-316

42 Legal proceedings

ING Group and its consolidated subsidiaries are involved in governmental, regulatory, arbitration and legal

proceedings and investigations in the Netherlands and in a number of foreign jurisdictions, including the U.S.,

involving claims by and against them which arise in the ordinary course of their businesses, including in

connection with their activities as lenders, broker-dealers, underwriters, issuers of securities and investors and their

position as employers and taxpayers. In certain of such proceedings, very large or indeterminate amounts are

sought, including punitive and other damages. While it is not feasible to predict or determine the ultimate

outcome of all pending or threatened governmental, regulatory, arbitration and legal proceedings and

investigations, ING is of the opinion that the proceedings and investigations set out below may have or have in the

recent past had a significant effect on the financial position, profitability or reputation of ING and/or ING and its

consolidated subsidiaries.

Settlement agreement: On 4 September 2018, ING announced that it had entered into a settlement agreement

with the Dutch Public Prosecution Service relating to previously disclosed investigations regarding various

requirements for client on-boarding and the prevention of money laundering and corrupt practices. Following the

entry into the settlement agreement, ING has experienced heightened scrutiny from authorities in various

countries. ING is also aware, including as a result of media reports, that other parties may, among other things,

seek to commence legal proceedings against ING in connection with the subject matter of the settlement. Certain

parties filed requests with the Court of Appeal in The Netherlands to reconsider the prosecutor’s decision to enter

into the settlement agreement with ING and not to prosecute ING or (former) ING employees. In December 2020,

the Court of Appeal issued its final ruling. In this ruling the prosecutors' decision to enter into the settlement

agreement with ING was upheld, making the settlement final. However, in a separate ruling, the Court ordered the

prosecution of ING’s former CEO. In December 2025, the Court decided that ING’s former CEO does not have to be

prosecuted. This case is now closed.

Litigation by investors: In February and March 2024, ING and certain (former) board members were served with a

writ of summons for litigation in The Netherlands on behalf of investors who claim to have suffered financial losses

in connection with ING's disclosures on historic shortcomings in its financial economic crime policies, related risk

management and control systems, the investigation by and settlement with the Dutch authorities in 2018 and

related risks for ING. ING does not agree with the allegations and will defend itself against these and the claimed

damages of EUR 587 million. In February 2025, ING and the (former) board members filed their statement of

defence against the allegations and in November 2025, the court rejected all claims by the investors. In February

2026, the investors filed an appeal against this decision of the court. Separately, but relating to the same matters,

in July 2024 another group of investors claiming to have suffered financial losses requested disclosure of certain

ING documents and to question witnesses. The court issued a decision on the request in May 2025 where it

rejected the entirety of the request made by these investors. These investors may decide to pursue further legal

action. ING follows IFRS rules for taking legal provisions and would disclose material amounts in this regard if and

when applicable - which currently is not the case.

Findings regarding AML processes : As previously disclosed, after its September 2018 settlement with Dutch

authorities concerning anti-money laundering matters, and in the context of significantly increased attention on

the prevention of financial economic crime, ING has experienced heightened scrutiny by authorities in various

countries. The interactions with such regulatory and judicial authorities have included, and can be expected to

continue to include, onsite visits, information requests, investigations and other enquiries. Such interactions, as

well as ING’s internal assessments in connection with its global enhancement programme, have in some cases

resulted in satisfactory outcomes, and also have resulted in, and may continue to result in, findings, or other

conclusions which may require appropriate remedial actions by ING, or may have other consequences. ING intends

to continue to work in close cooperation with authorities as it seeks to improve its management of non-financial

risks in terms of policies, tooling, monitoring, governance, knowledge and behaviour.

In January 2022, a Luxembourg investigating judge informed ING Luxembourg that he intends to instruct the

relevant prosecutor to prepare a criminal indictment regarding alleged shortcomings in the AML process at ING

Luxembourg. In November 2024, a Luxembourg Court decided to refer the case to the ‘Tribunal Correctionnel’ for

alleged shortcomings in a limited number of individual client files. ING Luxembourg filed an appeal against this

procedural decision. In December 2025, the Court of Appeal upheld the first decision without making any

substantive changes, as a result of which the case can now be heard before the Tribunal Correctionnel. It is

currently not possible to determine how this matter will be resolved or the timing of any such resolution, ING does

not expect the outcome of this matter to have a material financial effect.

ING continues to take steps to enhance its management of compliance risks and embed stronger awareness

across the whole organisation. These steps are part of the global KYC programme and set of initiatives, which

includes enhancing KYC files and working on various structural improvements in compliance policies, tooling,

monitoring, governance, knowledge and behaviour.

Tax cases: Because of the geographic spread of its business, ING may be subject to tax audits, investigations and

procedures in numerous jurisdictions at any point in time. Although ING believes that it has adequately provided

for all its tax positions, the ultimate resolution of these audits, investigations and procedures is uncertain and may

result in liabilities which are materially different from the amounts recognised.

Litigation regarding products of a former subsidiary in Mexico : Proceedings in which ING is involved include

complaints and lawsuits concerning the performance of certain interest sensitive products that were sold by a

former subsidiary of ING in Mexico.

Claims regarding accounts with predecessors of ING Bank Türkiye :

ING Bank Türkiye has received numerous claims from (former) customers of legal predecessors of ING Bank

Türkiye. The claims are based on offshore accounts held with these banks, which banks were seized by the Savings

Deposit Insurance Fund (“SDIF”) prior to the acquisition of ING Bank Türkiye in 2007 from OYAK. Pursuant to the


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-317

acquisition contract, ING Bank Türkiye can claim compensation from SDIF if a court orders ING Bank Türkiye to pay

amounts to the offshore account holders. SDIF has made payments to ING Bank Türkiye pursuant to such

compensation requests, but filed various lawsuits to receive those amounts back. In April 2022, the Turkish

Supreme Court decided that the prescription period for the offshore account holders’ compensation claims starts

on the transfer date of the account holders to the offshore accounts.

In 2024 SDIF initiated enforcement procedures against ING Bank Türkiye, based on the decision in April 2022 by the

Turkish Supreme Court referred to above. SDIF alleges that this decision means that ING Bank Türkiye has to return

certain payments made by SDIF regarding the offshore depositors' receivables cases, as the statute of limitations

had already expired.

Additionally, ING Bank Türkiye has initiated enforcement proceedings against SDIF regarding accumulated

receivables that SDIF has either partially or completely failed to pay.

As of February 2026, four lawsuits have been finalized in favour of ING Bank Türkiye with the Turkish Supreme

Court's verdict, which are likely to be precedent decisions for the other files. At this moment it is not possible to

assess the outcome of these procedures nor to provide an estimate of the (potential) financial effect of these

claims.

Mortgage expenses claims : ING Spain has received claims and is involved in procedures with customers regarding

reimbursement of expenses associated with the formalisation of mortgages. In most first instance court

proceedings the expense clause of the relevant mortgage contract has been declared null and ING Spain has been

ordered to reimburse all or part of the applicable expenses. Since 2018, the Spanish Supreme Court and the

European Court of Justice ("CJEU") have issued rulings setting out which party should bear notary, registration,

agency, and stamp duty costs. In January 2021, the Spanish Supreme Court ruled that valuation costs of

mortgages, signed prior to 16 June 2019, the date the new mortgage law entered into force, should be borne by

the bank. Media attention for the statute of limitations applicable to the right to claim reimbursement of costs

resulted in an increased number of claims at the beginning of 2021. In June 2021, the Spanish Supreme Court

published a press release stating its decision to ask the CJEU for a preliminary ruling regarding the criteria that

should be applied to determine the date from which the action for claiming the reimbursement of mortgage

expenses is considered to be expired. In January 2024, the CJEU ruled that the limitation period for the judicial

claim for reimbursement of expenses cannot begin to run from a Supreme Court decision declaring the clause null

and void, nor from the moment of the payment of the expenses. The CJEU indicated that it is up to national case-

law to determine the criterion that should be applied for the calculation of the limitation period. In April 2024, the

CJEU ruled that it was not against European Union laws that the period of prescription began to be calculated from

the moment the clause was declared null. Following the CJEU approach, on 14 June 2024 the Spanish Supreme

Court issued its final decision stating in short that the 5-year period to claim the reimbursement of costs can only

begin from the date each individual clause is declared null by a judge. The Spanish Supreme Court also leaves a

small door open for banks in case they can demonstrate that a specific individual indeed had knowledge of the

unfairness of the clause before that moment. ING has adapted its strategy to the latest developments.

ING Spain was also included, together with other Spanish banks, in three class actions filed by customer

associations. In one of the class actions an agreement was reached with the association. In another class action

the association withdrew from the proceedings. With respect to the third class action, ING filed an appeal asking

the Spanish Court of Appeal to determine that the ruling of the court of first instance is only applicable to the

consumers that were part of the case. The National Court has revoked the ruling and declared that the consumers

will not be able to initiate an action for compensation based on the first instance ruling, as the claimant

association intended. This last decision is not yet final, as it has been appealed in the Supreme Court.

A provision has been established in the past and has been adjusted where appropriate.

Claims regarding mortgage loans in Swiss franc in Poland : ING Poland is a defendant in several lawsuits with

retail customers who took out mortgage loans indexed to the Swiss franc. Such customers have alleged that the

mortgage loan contract contains abusive clauses. One element that the court is expected to consider in

determining whether such contracts contain abusive clauses is whether the rules to determine the exchange rate

used for the conversion of the loan from Polish zloty to Swiss franc are unambiguous and verifiable. In December

2020, the Polish Financial Supervision Authority (PFSA) proposed that lenders offer borrowers voluntary out-of-

court settlements on foreign-currency mortgage disputes, with mortgages indexed to Swiss franc serving as a

reference point. In February 2021, ING Poland announced its support for this initiative and in October 2021 began

offering the settlements to the borrowers following the PFSA’s proposal. In October 2022, a hearing of the CJEU

was held inter alia on the question whether, after cancellation of a contract regarding a Swiss franc loan by a

court, banks may still charge interest for the amount borrowed under such loan prior to cancellation.

In June 2023, the CJEU issued a ruling. It ruled that under EU law when a loan agreement indexed to the Swiss

franc is declared null and void, banks cannot claim any remuneration (i.e. interest) for the duration the principal

amount was available to the customer. The customer, however, may assert claims against banks in addition to

reimbursement of interest and installments previously paid to the bank. In September and December 2023, the

CJEU issued rulings providing further clarity on the limitation period and about the question of when a contract

clause can be considered unfair. In April 2024, the Polish Supreme Court issued a ruling stating that if it is

impossible to establish a binding foreign currency exchange rate for the parties in the indexed or denominated

loan agreement, the agreement is also not binding in other respects. ING has recorded a portfolio provision. In

October and November 2024, seven new preliminary questions were referred to the CJEU which focus on the

claims of banks in a situation of annulment of a credit agreement.

In June 2025, the CJEU issued a judgement in one of the Polish cases concerning banks' capital recovery after

invalidation of the mortgage Swiss franc loan agreement. The verdict was passed in the case brought by a bank.


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The CJEU questioned the compliance with European Union law of the so-called two-claims theory, which has so far

been widely used in Polish jurisprudence. It was based on the assumption that each party of the invalidated

contract has its own claim. A consumer is entitled to ask for all the installments paid to the bank, and a bank is

entitled to ask for the capital (in two separate civil proceedings). CJEU said that this approach is against EU law.

Both claims should be taken into consideration in one proceeding. A bank is entitled to ask only for the result of

subtraction of its claim and a claim of a consumer (the balance theory). Despite this CJEU ruling, the majority of

Polish courts continues issuing judgments in accordance with two-claims theory.

Since September 2025, ING Poland has seen an increase in the number of settlements.

In January 2026, the CJEU issued a judgement confirming that it is permissible to settle both parties’ claims in a

Swiss franc dispute within a single proceeding by way of set off. The CJEU found that banks may raise the defence

of set-off even if the invalidity of the contract is disputed. The CJEU pointed out that if the bank were deprived of

the possibility of raising a set-off defence against the consumer, his right to effective judicial protection would be

disproportionately infringed. Although the judgment is generally favorable to banks, certain theses contained in

the judgment may result in an approach to calculating interest that is unfavorable for banks. At this point,

however, it is unclear how the courts will approach the application of this ruling. This requires observation.

Certain Consumer Credit Products : In October 2021, ING announced that it would offer compensation to its

Dutch retail customers in connection with certain revolving consumer loans with variable interest rates that

allegedly did not sufficiently follow market rates. This announcement was made in response to several rulings by

the Dutch Institute for Financial Disputes (Kifid) regarding similar products at other banks. ING has recognized a

provision of EUR 180 million in 2021 for compensation and costs in connection with this matter. On 22 December

2021, ING announced that it reached an agreement with the Dutch Consumers’ Association (Consumentenbond)

on the compensation methodology for revolving credits. Based on a Kifid ruling regarding similar products, ING has

amended its previously announced compensation scheme by also compensating interest on interest. In the third

quarter of 2022, ING increased its provision for this matter by EUR 75 million. In the fourth quarter of 2022, ING and

the Dutch Consumers’ Association reached an agreement on the compensation of customers who have had an

overdraft facility or a revolving credit card with a variable interest rate. ING has started compensating such

customers in line with Kifid rulings about revolving credits including ‘interest-on-interest’-effect in these cases.

Timelines for compensation vary depending on customer and product segmentation and are dependent on the

availability of data. In 2024 the compensation process was expedited. ING substantially finalized the compensation

process in the first half of 2025, with a spill-over to the third quarter of 2025 for after-care in individual cases. ING

has reached out to its customers with respect to the Kifid ruling, to also compensate amounts under EUR 50. Kifid

confirmed ING's calculation methodology in relation to older consumer credits, where there is no relevant data

available to determine the start delta and in relation to the interest-on-interest effect. The compensation process

is still ongoing and may take until Q2 2026.

Climate litigation: In January 2024, Friends of the Earth Netherlands (Milieudefensie) announced that it holds ING

liable for alleged contribution to climate change and threatened to initiate legal proceedings against ING. In March

2025, Milieudefensie started legal proceedings at the Court in Amsterdam against ING by serving the writ of

summons. ING will defend its science-based climate approach in court and submitted its statement of defence in

February 2026.

Russian claims: Several ING entities have received claims from, and are involved in litigation with, certain Russia-

linked entities. They claim the payment of principal or interest or other amounts that they have not received

pursuant to sanctions. Claims are also made related to the settlement of contracts that have been terminated

after sanctions were imposed. In at least one case, the claimant seized assets in Russia of ING entities. ING does

not agree with these claims, as they do not comply with the underlying contracts or applicable laws, including

sanctions. ING follows IFRS rules for taking legal provisions and would disclose material amounts in that regard if

and when applicable which currently is not the case.

43 Principal subsidiaries, investments in associates and joint ventures

For the majority of ING’s principal subsidiaries, ING Groep N.V. has control because it either directly or indirectly

owns more than half of the voting power. For subsidiaries in which the interest held is below 50%, control exists

based on the combination of ING’s financial interest and its rights from other contractual arrangements which

result in control over the operating and financial policies of the entity.

For each of the subsidiaries listed, the voting rights held equal the proportion of ownership interest, and

consolidation by ING is based on the majority of ownership.

For the principal investments in associates and joint ventures ING Group has significant influence but not control.

Significant influence generally results from a shareholding of between 20% and 50% of the voting rights, but also

the ability to participate in the financial and operating policies through situations including, but not limited to one

or more of the following:

§Representation on the board of directors;

§Participation in the policymaking process; and

§Interchange of managerial personnel.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-319

The principal subsidiaries, investments in associates and joint ventures of ING Groep N.V. and their statutory place

of incorporation or primary place of business are as follows:


Principal subsidiaries, investments in associates and joint ventures
			Proportion of ownership and interest held by the group
			Proportion of ownership and interest held by the group
			2025	2024
Subsidiary	Statutory place of Incorporation	Country of operation
ING Bank N.V.	Amsterdam	the Netherlands	100%	100%
ING Belgium S.A./N.V.	Brussels	Belgium	100%	100%
ING Luxembourg S.A.	Luxembourg City	Luxembourg	100%	100%
ING DiBa AG	Frankfurt am Main	Germany	100%	100%
ING Bank Slaski S.A.1	Katowice	Poland	75%	75%
ING Financial Holdings Corporation	Delaware	United States of America	100%	100%
ING Bank A.S.	Istanbul	Türkiye	100%	100%
ING Bank (Australia) Ltd	Sydney	Australia	100%	100%
ING Commercial Finance B.V.	Amsterdam	the Netherlands	100%	100%

Investments in associates and joint ventures
TMBThanachart Bank Public Company Ltd 2	Bangkok	Thailand	23%	23%

1The shares of the non-controlling interest stake of 25% are listed on the Warsaw Stock Exchange, for summarised financial information we refer to Note

31 'Information on geographical areas'.

2Reference is made to Note 8 'Investment in associates and joint ventures'.

44 Structured entities

ING Group’s activities involve transactions with various structured entities (SE) in the normal course of its business.

A structured entity is an entity that has been designed so that voting or similar rights are not the dominant factor

in deciding who controls the entity, such as when any voting rights relate to administrative tasks only and the

relevant activities are directed by means of contractual arrangements. ING Group’s involvement in these entities

varies and includes both debt financing and equity financing of these entities as well as other relationships. Based

on its accounting policies, ING establishes whether these involvements result in no significant influence, significant

influence, joint control or control over the structured entity.

The structured entities over which ING can exercise control are consolidated. ING may provide support to these

consolidated structured entities as and when appropriate. However, this is fully reflected in the consolidated

financial statements of ING Group as all assets and liabilities of these entities are included and off-balance sheet

commitments are disclosed.

ING’s activities involving structured entities are explained below in the following categories:

1. Consolidated ING originated securitisation programmes;

2. Consolidated ING originated Covered bond programme (CBC);

3. Consolidated ING sponsored Securitisation programme (Mont Blanc);

4. Unconsolidated Securitisation programme; and

5. Other structured entities.

1. Consolidated ING originated securitisation programmes

ING Group enters into liquidity management securitisation programmes in order to obtain funding and improve

liquidity. Within the programme ING Group sells ING-originated assets to a structured entity. The underlying

exposures include residential mortgages and SME loans in the Netherlands, Belgium, Spain, Italy, Australia and

Germany.

The structured entity issues securitised notes (traditional securitisations) which are eligible collateral for central

bank liquidity purposes. In most programmes ING Group acts as investor of the securitised notes. ING Group

continues to consolidate these structured entities if it is deemed to control the entities.

The structured entity issues securitisation notes in two or more tranches, of which the senior tranche obtains a

high rating (AAA or AA) by a rating agency. The retained tranche can subsequently be used by ING Group as

collateral in the money market for secured borrowings.

ING Group originated various securitisations, and as at 31 December 2025 , these consisted of EUR 76 billion (2024:

EUR 74 billion) of senior and subordinated notes, of which EUR 4 billion (2024: EUR 4 billion) were issued externally.


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The underlying exposures are residential mortgages and SME loans. Apart from the third party funding, these

securitisations did not impact ING Group’s Consolidated statement of financial position and profit or loss.

In 2025, there are no non-controlling interests as part of the securitisation structured entities that are significant

to ING Group.

2. Consolidated ING originated covered bond programme (CBC)

ING Group has entered into a covered bond programme. Under the covered bond programme, ING issues bonds.

The payment of interest and principal is guaranteed by the ING administered structured entities presented in table

below. In order for these entities to fulfil their guarantee, ING legally transfers mainly mortgage loans originated

by ING. Furthermore, ING offers protection against deterioration of the mortgage loans. The entities are

consolidated by ING Group.


Covered bond programme
	Fair value pledged mortgage loans
in EUR million	2025	2024
Dutch Covered Bond programmes	29,131	27,172
Diba Mortgage Pfandbriefe	18,811	15,050
ING Belgium Residential Pandbrieven Programme	8,986	9,024
IBAL Covered Bond	3,492	3,676
ING Bank Hipoteczny CBP	820	602
	61,240	55,524

For the covered bond programme, third-party investors in securities issued by the structured entity have recourse

to the assets of the entity and to the assets of ING Group.

3. Consolidated ING sponsored Securitisation programme (Mont Blanc)

In the normal course of business, ING Group structures financing transactions for its clients by assisting them in

obtaining sources of liquidity by selling the clients’ receivables or other financial assets to a Special Purpose Vehicle

(SPV). The senior positions in these transactions may be funded by the ING administered multi-seller Asset Backed

Commercial Paper (ABCP) conduit Mont Blanc Capital Corp. (rated A-1/P-1). Mont Blanc Capital Corp. funds itself

externally in the ABCP markets.

ING Group facilitates these transactions by acting as administrative agent, swap counterparty and liquidity

provider to Mont Blanc Capital Corp. ING Group also provides support facilities (i.e. liquidity) backing the

transactions funded by the conduit. The types of asset currently in the Mont Blanc conduit include trade

receivables, consumer finance receivables, car leases.

ING Group supports the ABCP programmes by providing Mont Blanc Capital Corp. with short-term liquidity facilities.

Once drawn these facilities bear normal credit risk.

The liquidity facilities provided to Mont Blanc are EUR 4,800 million (2024: EUR 3,119 million). The drawn liquidity

amount is nil as at 31 December 2025 (2024: nil).

The standby liquidity facilities are reported under irrevocable facilities. All facilities, which vary in risk profile, are

granted to the Mont Blanc Capital Corp. subject to normal ING Group credit and liquidity risk analysis procedures.

The fees received for services provided and for facilities are charged subject to market conditions.

4. Unconsolidated Securitisation programmes

In 2013 ING transferred financial assets (mortgage loans) for an amount of EUR 2 billion to a special purpose

vehicle (SPV). The transaction resulted in full derecognition of the financial assets from ING’s statement of financial

position. Following this transfer ING continues to have two types of ongoing involvement in the transferred assets:

as counterparty to the SPE of a non-standard interest rate swap, which is recognised as a non-trading derivative,

and as servicer of the transferred assets. Service fee income recognised, for the role as administrative agent, in the

statement of profit or loss in 2025 amounted to EUR 1 million (2024: EUR 1 million). The cumulative income

recognised in profit or loss since derecognition amounts to EUR 21 million (2024: EUR 20 million).

In 2025, ING established two SPVs, which are Designated Activity Companies incorporated in Ireland, for the

purpose of significant risk transfer securitizations. ING transferred the credit risk on the selected diversified

portfolios of corporate loans without transferring the assets to the SPVs. Each SPV has issued a series of credit

linked notes varying in seniority of the referenced loans to the investors. Subsequently, SPVs provide a financial

guarantee to ING in respect of the referenced loans and, in return for a fee, are liable to make protection

payments to ING upon the occurrence of a credit event in relation to any of the referenced loans. As of 31

December 2025, credit linked notes held by third parties amounted to EUR 676 million (2024: nil) and funds raised

by the sale of the credit linked notes are deposited within ING as collateral for the credit protection. The associated

corporate loans were EUR 10 billion (2024: nil). The SPVs are not consolidated by ING because the third-party

investors have the exposure, or rights to all variability of returns of the entities. No assets are transferred to, or

income received from these entities and the credit linked notes are fully cash collateralized.


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5. Other structured entities

In the normal course of business, ING Group enters into transactions with structured entities as counterparty.

Predominantly in its structured finance operations, ING can be instrumental in facilitating the creation of these

structured entity counterparties. These entities are generally not included in the consolidated financial statements

of ING Group, as ING facilitates these transactions as administrative agent by providing structuring, accounting,

funding, lending, and operation services.

ING Group offers various investment fund products to its clients. ING Group does not invest in these investment

funds for its own account nor acts as the fund manager.

45 Related parties

In the normal course of business, ING Group enters into various transactions with related parties. Parties are

considered to be related if one party has the ability to control or exercise significant influence over the other party

in making financial or operating decisions. Related parties of ING Group include, among others, its associates, joint

ventures, key management personnel, and various defined benefit and contribution plans. For post-employment

benefit plans, reference is made to Note 33 'Pensions and other post-employment benefits'. Transactions between

related parties include rendering or receiving of services, leases, transfers under finance arrangements and

provisions of guarantees or collateral. All transactions with related parties took place at conditions customary in

the market. There are no significant provisions for doubtful debts or individually significant bad debt expenses

recognised on outstanding balances with related parties.

Associates and joint ventures


Transactions with ING Group’s main associates and joint ventures
	Associates		Joint ventures
in EUR million	2025	2024	2025	2024
Assets	117	142	0	0
Liabilities	242	263	7	10
Off-balance sheet commitments	18	23	0	0

Income received	21	16	0	0
Expenses paid	0	2	0	0

Assets, liabilities, commitments, and income related to Associates and joint ventures result from transactions

which are executed as part of the normal Banking business. Dividends received by associates and joint ventures

are included in Note 8 'Investment in associates and joint ventures'.

Key management personnel compensation

The Executive Board of ING Groep N.V., the Management Board Banking and the Supervisory Board are considered

Key Management personnel of ING. In 2025, 2024 and 2023, the three members of the Executive Board of ING

Groep N.V. were also members of the Management Board Banking.

Transactions with key management personnel, including their compensation are included in the tables below.


Key management personnel compensation (Executive Board and Management Board Banking)
2025 in EUR thousands	Executive Board of ING Groep N.V.	Management Board Banking 1	Total
Fixed Compensation
– Base salary	4,615	4,306	8,921
– Collective fixed allowances 2	1,094	984	2,078
– Pension costs	83	111	194
– Severance benefits 3	1,347	444	1,791
Variable compensation
– Upfront cash		745	745
– Upfront shares	330	745	1,075
– Deferred cash		1,118	1,118
– Deferred shares	494	1,118	1,613
– Other emoluments 4	340	468	808
Total compensation	8,302	10,041	18,343

1Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.

2The collective fixed allowances consist of two savings allowances applicable to employees in the Netherlands; an individual savings allowance of 3.5%

and a collective savings allowance to compensate for the loss of pension benefits with respect to salary in excess of EUR 137,800.

3In accordance with the Executive Board remuneration policy and with due observance of applicable legal requirements, a severance payment equal to

one year's base salary has been granted.

4This includes expatriate allowances (such as housing, school/tuition fees and international health insurances, if applicable); banking and insurance

benefits from ING (on the same terms as for other employees of ING in the Netherlands); tax and financial planning services to ensure compliance with

the relevant legislative requirements; and the use of a company car or driver service.


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Key management personnel compensation (Executive Board and Management Board Banking)
2024 in EUR thousands	Executive Board of ING Groep N.V.	Management Board Banking 1	Total
Fixed Compensation
– Base salary	4,388	3,598	7,987
– Collective fixed allowances 2	1,033	790	1,823
– Pension costs	84	95	179
– Severance benefits
Variable compensation
– Upfront cash		609	609
– Upfront shares	302	609	911
– Deferred cash		914	914
– Deferred shares	453	914	1,367
– Other emoluments 3	306	418	724
Total compensation	6,566	7,948	14,513

1Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.

2The collective fixed allowances consist of two savings allowances applicable to employees in the Netherlands; an individual savings allowance of 3.5%

and a collective savings allowance to compensate for the loss of pension benefits with respect to salary in excess of EUR 137,800.

3This includes expatriate allowances (such as housing, school/tuition fees and international health insurances, if applicable); banking and insurance

benefits from ING (on the same terms as for other employees of ING in the Netherlands); tax and financial planning services to ensure compliance with

the relevant legislative requirements; reimbursement of costs under the Directors & Officers indemnity provided by ING; and the use of a company car or

driver service.


Key management personnel compensation (Executive Board and Management Board Banking)
2023	Executive Board of ING Groep N.V.	Management Board Banking 1	Total
in EUR thousands	Executive Board of ING Groep N.V.	Management Board Banking 1	Total
Fixed Compensation
– Base salary	4,220	4,200	8,420
– Collective fixed allowances 2	1,002	887	1,889
– Pension costs	78	107	185
– Severance benefits		734	734
Variable compensation
– Upfront cash		598	598
– Upfront shares	293	598	891
– Deferred cash		897	897
– Deferred shares	439	897	1,336
– Other emoluments 3	344	487	832
Total compensation	6,376	9,405	15,782

1Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.

2The collective fixed allowances consist of two savings allowances applicable to employees in the Netherlands; an individual savings allowance of 3.5%

and a collective savings allowance to compensate for loss of pension benefits with respect to salary in excess of EUR 128,810.

3This includes amongst others: housing, school/tuition fees, international health insurance, relocation costs and tax and financial planning.

ING indemnifies the members of the EB against direct financial losses in connection with claims from third parties

filed, or threatened to be filed, against them by virtue of their service as a member of the EB, as far as permitted

by law, on the conditions laid down in the Articles of Association and their commission contract. ING has taken out

liability insurance for the members of the EB.

In accordance with the Articles of Association ING indemnifies the members of the Supervisory Board as far as

legally permitted against direct financial losses in connection with claims from third parties filed or threatened to

be filed against them by virtue of their service as a member of the Supervisory Board.

Key management personnel compensation is generally included in Staff expenses in the statement of profit or

loss. The total remuneration of the Executive Board and Management Board Banking is disclosed in the table

above. Under IFRS, certain components of variable remuneration are not recognised in the statement of profit or

loss directly, but are allocated over the vesting period of the award. The comparable amount recognised in Staff

expenses in 2025 relating to the fixed expenses of 2025 and the vesting of variable remuneration of earlier

performance years, is EUR 16 million (2024: EUR 12 million; 2023: EUR 14 million).

The table below shows the total of fixed remuneration, expense allowances and attendance fees for the

Supervisory Board in 2025, 2024 and 2023.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-323


Key management personnel compensation (Supervisory Board)
in EUR thousands	2025	2024	2023
Total compensation	1,434	1,191	1,152

Loans and advances to key management personnel

As at 31 December 2025 Loans and advances outstanding to key management personnel amounted to EUR 1.1

million (2024: EUR 1.1 million) with an average interest rate of 1.7% (2024: 2.1%) and loan commitments to key

management personnel amounted to EUR 162 thousand (2024: EUR 145 thousand). Total interest received in

2025 on these loans and advances amounted to EUR 17 thousand (2024: EUR 28 thousand).

These loans and advances and loan commitments (1) were made in the ordinary course of business, (2) were

granted on conditions that are comparable to those of loans and advances granted to all employees and (3) did

not involve more than the normal risk of collectability or present other unfavourable features.

Deposits outstanding and bonds invested in by key management personnel

As at 31 December 2025 Deposits outstanding from key management personnel amounted to EUR 12.9 million

(2024: EUR 15.8 million) and bonds invested in by key management personnel amounted to EUR 226 thousand

(2024: nil). Total interest paid in 2025 on these deposits amounted to EUR 1.1 million (2024: EUR 324 thousand)

and total interest paid in 2025 on these bonds amounted to EUR 3 thousand (2024: nil). These transactions are

entered into under the same commercial and market terms, including interest rates, that apply to non-related

parties.

ING shares held by key management personnel


Number of ING Groep N.V. shares to key management personnel
	ING Groep N.V. shares
in numbers	2025	2024
Executive Board members	178,187	152,652
Management Board Banking	415,008	343,055
Supervisory Board members	9,395	5,295

46 Capital management

Capital management strategy

Group Treasury (GT) is responsible for maintaining adequate capitalisation across ING Group and its banking

entities to support the management of risks associated with ING’s business activities. This includes capital

planning, allocation, and management within the Group, as well as the execution of capital market, term capital

funding, and risk management transactions. ING employs an integrated approach to assessing capital adequacy,

whereby GT considers regulatory and internal economic capital metrics alongside the interests of key

stakeholders, including customers, shareholders, and rating agencies.

ING applies the following main capital definitions:

§Common Equity Tier 1 (CET1) capital consists of shareholders’ equity after the correction for applicable

regulatory adjustments. The CET1 ratio is calculated as CET1 capital divided by risk-weighted assets (RWAs).

§Tier 1 capital is defined as CET1 capital plus Additional Tier 1 (AT1) securities and other regulatory adjustments.

The Tier 1 capital ratio is defined as Tier 1 capital divided by RWAs.

§Total capital consists of Tier 1 capital plus Tier 2 subordinated liabilities, after regulatory adjustments. The Total

capital ratio is calculated as Total capital divided by RWAs.

§ING’s CET1 ratio target is built on the CET1 requirements specified for ING, potential increase in the regulatory

requirements, the potential impact of a standardised and predetermined stress scenario and available

mitigating actions, and general uncertainties in its baseline planning.

§Leverage ratio (LR) is defined as Tier 1 capital divided by the leverage exposure.

§Minimum Required Eligible Liabilities (MREL)/ Total Loss Absorbing Capacity (TLAC) is Total capital plus senior

unsecured bonds and amortisations. Related MREL and TLAC ratios are expressed relative to both risk-weighted

assets and leverage exposure.

Dividend and distribution policy

ING’s distribution policy is a pay-out ratio of 50% of resilient net profit. Resilient net profit is defined as net profit

adjusted for significant items not linked to the normal course of business. The 50% pay-out may be in the form of

cash, or a combination of cash and share repurchases, with the majority in cash. Additional distributions are to be

considered periodically, taking into account alternative opportunities, macroeconomic circumstances and the

outcome of our capital planning. The prerequisite for a distribution is a CET1 ratio of at least the prevailing MDA

level after distribution.

For more information on dividend and other distributions, reference is made to Note ‘Dividend per share’ and Note

‘Equity’.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-324

Capital position as per 31 December 2025


ING Group capital position according to CRR III / CRD V
in EUR million	2025	2024
Shareholders’ equity 1	49,698	50,314
- Interim profits not included in CET1 capital	-2,125	-2,152
- Other adjustments	-3,006	-2,902
Regulatory adjustments	-5,130	-5,054
Available common equity Tier 1 capital	44,567	45,260

Additional Tier 1 securities	7,459	7,965
Regulatory adjustments additional Tier 1	112	66
Available Tier 1 capital	52,138	53,291

Supplementary capital Tier 2 bonds	10,608	9,852
Regulatory adjustments Tier 2	98	50
Available Total capital	62,845	63,194

Risk weighted assets	340,739	333,708

Common equity Tier 1 ratio	13.1%	13.6%
Tier 1 ratio	15.3%	16.0%
Total capital ratio	18.4%	18.9%

1Shareholders’ equity is determined in accordance with IFRS-EU.

In accordance with the applicable regulation, credit and operational risk models used in the capital ratios

calculations are not audited.

Regulatory requirements

Capital adequacy and regulatory capital requirements are based on the standards issued by the Basel Committee

on Banking Supervision (the Basel Committee) and implemented in the European Union Directives through the

Capital Requirements Regulation (CRR) and Capital Requirements Directive (CRD), as implemented by De

Nederlandsche Bank (DNB) and the European Central Bank (ECB). Under the CRR, the minimum Pillar 1 capital

requirements applicable to ING Group are a CET1 ratio of 4.5%, a Tier 1 ratio of 6.0%, and a Total capital ratio of

8.0% of risk‑weighted assets.

The overall SREP CET1 requirement, including buffer requirements, for ING Group at a consolidated level increased

during 2025, mainly due to an increase of the countercyclical buffer requirement (CCyB), and was 11.03% at 31

December 2025. This requirement is the sum of a 4.5% Pillar 1 requirement, a 0.93% Pillar 2 requirement, a 2.5%

capital conservation buffer (CCB), a 0.93% CCyB, 0.16% Sectoral Systemic Risk buffer (s-SyRB), and a 2.0% Other

Systemically Important Institutions (O-SII) buffer that is set separately for Dutch systemic banks by DNB. This

requirement excludes the Pillar 2 guidance, which is not disclosed. ING met the externally imposed regulatory

capital requirements in 2025.

ING’s fully loaded CET1 requirement stood at 11.09% at the end of 4Q2025 (4Q2024: 10.88%), which is higher than

the prevailing CET1 ratio requirement. This reflects an update of the s-SyRB in Belgium, an increase in the CCyB

requirements in Belgium, Poland and Spain, and a higher Pillar 2 requirement.

The MDA trigger level stood at 11.03% per end of 4Q2025 for CET1, 12.84% for Tier 1 Capital, and 15.25% for Total

capital. These MDA levels are in line with the application of Art.104a in CRD V, which allows ING to partly fulfil the

total Pillar 2 requirement with Additional Tier 1 and Tier 2 capital.

An MDA requirement on the leverage ratio of 3.5% applies to ING Group. In the event that ING Group breaches an

MDA level, ING may face restrictions on dividend payments, coupons on AT1 securities and payment of variable

remuneration.


ING Group Annual Report on Form 20-F	Contents	Part I	Part II	Part III	Additional information	Financial statements	F-330

Parent company condensed statement of cash flows

for the years ended 31 December



in EUR million		2025	2024	2023		2025	2024	2023
Cash flows from operating activities					Cash flows from financing activities
Result before tax		135	273	167	Proceeds from debt securities	7,444	9,480	6,012
Adjusted for:	– non-cash items in Result before tax	56	232	221	Repayments of debt securities	-5,224	-3,695	-4,591
Taxation paid		-115	0	0	Proceeds from issuance of subordinated loans	3,734	4,492	2,240
Changes in:	– Net change in Loans and advances to/from banks, not available/payable on demand	3,036	-5,899	-6,485	Repayments of subordinated loans	-2,808	-2,944	-2,132
	– Other	51	-66	19	Purchase of treasury shares (share buyback programme)	-3,705	-3,817	-3,524
Net cash flow from/(used in) operating activities		3,163	-5,461	-6,079	Dividends and other cash distributions paid	-3,689	-3,626	-2,964
					Other financing
Cash flows from investing activities					Net cash flow from/(used in) financing activities	-4,248	-109	-4,959
Disposals and redemptions:	– dividends received from ING Bank N.V.	1,129	4,986	10,269
	– securities at amortised cost			1,000	Net cash flow	44	-583	231
Net cash flow from/(used in) investing activities		1,129	4,986	11,269
					Cash and cash equivalents at beginning of year	31	614	383
					Effect of exchange rate changes on cash and cash equivalents	0	0	0
					Cash and cash equivalents at end of year	75	31	614

Five-year schedule of maturities of subordinated and debenture loans



	Subordinated loans		Debenture loans
in EUR million	2025	2024	2025	2024
Less than 1 year			3,284	1,010
1 to 2 years			6,859	8,053
2 to 3 years			7,180	7,401
3 to 4 years			7,326	7,523
4 to 5 years			7,747	6,220
Longer than 5 years	10,735	10,035	17,167	19,544
Maturity not applicable	7,695	8,487
	18,429	18,522	49,562	49,751

As at 31 December 2025 ING Groep N.V. has issued USD 9,000 million (2024: USD 8,750 million) Perpetual

Additional Tier 1 Contingent Convertible Capital Securities which can, in accordance with their terms and

conditions, convert by operation of law into ordinary shares if the conditions to such a conversion are fulfilled. As a

result of this conversion, the issued share capital can increase by up to 1,014 million (2024: 982 million) ordinary

shares. Reference is made to the ING Group Consolidated financial statements, Note 18 'Subordinated loans' and

Note 19 'Equity'.

The amount of debentures held by Group companies as at 31 December 2025 is EUR 25 million (2024: EUR 10

million).

48 Subsequent events

There are no subsequent events to report.


☐	REGISTRATION STATEMENT PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934


☒	ANNUAL REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934


☐	TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934


☐	SHELL COMPANY REPORT PURSUANT TO SECTION 13 OR 15(d) OF THE SECURITIES EXCHANGE ACT OF 1934


U.S. GAAP ☐		International Financial Reporting Standards as issued by the International Accounting Standards Board ☒		Other ☐


	Presentation of information	6
	Cautionary Statement with respect to Forward- looking Statements	7
1	Identity of Directors, Senior Management and Advisors	10
2	Offer Statistics and Expected Timetable	10
3	Key Information	11
4	Information on the Company	28
4A	Unresolved Staff comments	58
5	Operating and Financial Review and Prospects	59
6	Directors, Senior Management and Employees	75
7	Major Shareholders and Related Party Transactions	108
8	Financial Information	110
9	The Offer and Listing	111
10	Additional Information	112
11	Quantitative and Qualitative Disclosure about Market Risk	117
12	Description of Securities other than Equity Securities	118


13	Defaults, Dividend Arrearages and Delinquencies	121
14	Material Modifications to the Rights of Security Holders and Use of Proceeds	121
15	Controls and Procedures	122
16A	Audit Committee Financial Expert	124
16B	Code of Ethics	125
16C	Principal Accountant Fees and Services	126
16D	Exemptions from the Listing Standards for Audit Committees	127
16E	Purchases of Equity Securities s by the Issuer and Affiliated Purchasers	128
16F	Change in Registrant's Certifying Accountant	130
16G	Corporate Governance	131
16H	Mine Safety Disclosure	133
16I	Disclosure Regarding Foreign Jurisdictions that Prevent Inspections	134
16J	Insider Trading Policies	135
16K	Cybersecurity	136


17	Consolidated Financial Statements	139
18	Consolidated Financial Statements	140
19	Exhibits	141


		Executive Board in numbers



				Board members 3

				Average age 56

				Nationalities 3

				Average board tenure (years) 6

				Female 33%


		Management Board Banking in numbers



				Board members 7

				Average age 55

				Nationalities 6

				Average board tenure (years) 4.5

				Female 29%


Exhibit 1.1	Amended and Restated Articles of Association of ING Groep N.V., dated 12 May 2022 (incorporated by reference to Exhibit 99.1 of ING Groep N.V.’s Report on Form 6-K filed on 17 May 2022)

Exhibit 2.1	Description of Securities Registered under Section 12 of the Exchange Act

Exhibit 2.2	Subordinated Indenture, dated 18 July 2002, between the Company and The Bank of New York (incorporated by reference to Exhibit 2.1 of ING Groep N.V.’s Annual Report on Form 20-F for the year ended 31 December 2002, File No. 1-14642 filed on 27 March 2003)

Exhibit 2.3	Third Supplemental Indenture, dated 28 October 2003, between the Company and The Bank of New York (incorporated by reference to Exhibit 2.4 of ING Groep N.V.’s Annual Report on Form 20-F for the year ended 31 December 2003, File No. 1-14642 filed on 30 March 2004)

Exhibit 2.4	Fourth Supplemental Indenture, dated 26 September 2005, between the Company and The Bank of New York (incorporated by reference to Exhibit 4.2 of ING Groep N.V.’s Report on Form 6-K filed on 23 September 2005)

Exhibit 2.5	Sixth Supplemental Indenture, dated 13 June 2007, between the Company and The Bank of New York (incorporated by reference to Exhibit 4.1 of ING Groep N.V.’s Report on Form 6-K filed on 12 June 2007)


Exhibit 2.6	Indenture, dated as of April 16, 2015, between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, (incorporated by reference to Exhibit 4.1 of ING Groep N.V.’s Report on Form 6-K filed on 16 April 2015)


Exhibit 2.7	First Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 16 April 2015, in respect of 6.000% Perpetual Additional Tier 1 Contingent Convertible Capital Securities (incorporated by reference to Exhibit 4.2 of ING Groep N.V.’s Report on Form 6-K filed on 16 April 2015)

Exhibit 2.8	Second Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 16 April 2015, in respect of 6.500% Perpetual Additional Tier 1 Contingent Convertible Capital Securities (incorporated by reference to Exhibit 4.3 of ING Groep N.V.’s Report on Form 6-K filed on 16 April 2015)

Exhibit 2.9	Senior Debt Securities Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as Trustee, dated 29 March 2017 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.’s Report on Form 6-K filed on 29 March 2017)

Exhibit 2.10	First Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 29 March 2017, in respect of 3.150% Fixed Rate Senior Notes due 2022, 3.950% Fixed Rate Senior Notes due 2027 and Floating Rate Senior Notes due 2022 (incorporated by reference to Exhibit 4.2 of ING Groep N.V.’s Report on Form 6-K filed on 29 March 2017)

Exhibit 2.11	Second Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 2 October 2018, in respect of 4.100% Fixed Rate Senior Notes due 2023, 4.550% Fixed Rate Senior Notes due 2028 and Floating Rate Senior Notes due 2023 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.’s Report on Form 6-K filed on 2 October 2018)


Exhibit 2.12	Third Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 9 April 2019, in respect of 3.550% Fixed Rate Senior Notes due 2024 and 4.050% Fixed Rate Senior Notes due 2029 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 9 April 2019)

Exhibit 2.13	Third Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 10 September 2019, in respect of 5.750% Perpetual Additional Tier 1 Contingent Convertible Capital Securities (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 10 September 2019)

Exhibit 2.14	Fourth Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 1 April 2021, in respect of 1.726% Callable Fixed-to-Floating Rate Senior Notes due 2027, 2.727% Callable Fixed-to-Floating Rate Senior Notes due 2032 and Callable Floating Rate Senior Notes due 2027 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 1 April 2021)

Exhibit 2.15	Fourth Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 14 September 2021, in respect of 3.875% Perpetual Additional Tier 1 Contingent Convertible Capital Securities and 4.250% Perpetual Additional Tier 1 Contingent Convertible Capital Securities (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 14 September 2021)

Exhibit 2.16	Fifth Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 28 March 2022, in respect of 3.869% Callable Fixed-to- Floating Rate Senior Notes due 2026, 4.017% Callable Fixed-to-Floating Rate Senior Notes due 2028, 4.252% Callable Fixed-to-Floating Rate Senior Notes due 2033 and Callable Floating Rate Senior Notes due 2026 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 28 March 2022)

Exhibit 2.17	Sixth Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 11 September 2023, in respect of 6.083% Callable Fixed-to- Floating Rate Senior Notes due 2027, 6.114% Callable Fixed-to-Floating Rate Senior Notes due 2034 and Callable Floating Rate Senior Notes due 2027 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 11 September 2023)


Exhibit 2.18	Seventh Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated as of 19 March 19 2024, in respect of 5.335% Callable Fixed- to-Floating Rate Senior Notes due 2030 and 5.550% Callable Fixed-to-Floating Rate Senior Notes due 2035 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6- K filed on 19 March 2024)

Exhibit 2.19	Eighth Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 25 March 2025, in respect of 4.858% Callable Fixed-to- Floating Rate Senior Notes due 2029, 5.066% Callable Fixed-to-Floating Rate Senior Notes due 2031, 5.525% Callable Fixed-to-Floating Rate Senior Notes due 2036 and Callable Floating Rate Senior Notes due 2029 (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 25 March 2025)

Exhibit 2.20	Fifth Supplemental Indenture between ING Groep N.V. and The Bank of New York Mellon, London Branch, as trustee, dated 9 September 2025, in respect of 7.000% Perpetual Additional Tier 1 Contingent Convertible Capital Securities (incorporated by reference to Exhibit 4.1 of ING Groep N.V.'s Report on Form 6-K filed on 9 September 2025)

Exhibit 8	List of Subsidiaries of ING Groep N.V.

Exhibit 11	Insider Trading Policies

Exhibit 12.1	Certification of the Registrant’s Chief Executive Officer pursuant to Section 302 of the Sarbanes Oxley Act of 2002

Exhibit 12.2	Certification of the Registrant’s Chief Financial Officer pursuant to Section 302 of the Sarbanes- Oxley Act of 2002


Exhibit 13.1	Certification of the Registrant’s Chief Executive Officer pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002

Exhibit 13.2	Certification of the Registrant’s Chief Financial Officer pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002

Exhibit 15.1	Consent of KPMG Accountants

Exhibit 97	Clawback rules for erroneously awarded variable remuneration for executive officers (incorporated by reference to Exhibit 97 of ING Groep N.V.'s Annual Report on Form 20-F for the year ended 31 December 2023, File No. 1-14642 filed on 8 March 2024)

Exhibit 101	Inline eXtensible Business Reporting Language (Inline XBRL)

Exhibit 104	Cover Page Interactive Datafile (embedded in Exhibit 101)


Financial assets modified (*)
in EUR million	2025	2024
Financial assets modified during the period
Amortised cost before modification	1,746	1,888
Net modification results	-72	-107

Financial assets modified since initial recognition
Gross carrying amount at 31 December of financial assets for which loss allowance has changed to 12-month measurement during the period	1,027	1,506


Retail Banking: Forborne portfolio by geographical area (*)
in EUR million		2025			2024
Region		Outstandings	Of which: performing	Of which: non- performing	Outstandings	Of which: performing	Of which: non- performing
Region		Outstandings	Of which: performing	Of which: non- performing	Outstandings	Of which: performing	Of which: non- performing
Europe	Netherlands	2,136	1,711	424	1,548	1,134	414
	Belgium	2,153	978	1,175	1,942	800	1,142
	Germany	1,304	965	338	1,379	1,052	327
	Poland	793	361	432	777	403	374
	Spain	92	55	37	159	127	31
	Italy	104	33	70	122	43	79
	Türkiye	22	16	6	13	9	4
	Romania	216	106	110	173	72	101
	Rest of Europe	91	32	59	102	50	52
America		5		5	22	17	6
Asia		1			1		1
Australia		635	279	357	646	279	367
Africa
Total		7,551	4,538	3,013	6,883	3,987	2,897


Sensitivity analysis as at December 2025 (*)
		2026	2027	2028	Unweighted ECL (€ mln)	Probability-weighting	Reportable ECL (€ mln)1
Netherlands Upside scenario	Real GDP	2.6	2.9	2.3	288	20%	389
	Unemployment	3.5	3.2	3.2
	HPI	8.2	8.5	7.0
Baseline scenario	Real GDP	1.1	1.4	1.5	364	60%
	Unemployment	4.0	3.9	4.1
	HPI	4.4	3.0	2.9
Downside scenario	Real GDP	-1.2	-0.9	0.2	566	20%
	Unemployment	5.5	6.5	7.4
	HPI	-0.8	-5.1	-5.1
Germany Upside scenario	Real GDP	2.8	3.0	1.8	584	20%	633
	Unemployment	3.0	2.4	2.2
	HPI	8.2	9.8	9.4
Baseline scenario	Real GDP	1.1	1.5	1.3	623	60%
	Unemployment	3.5	3.2	3.1
	HPI	5.0	6.2	6.3
Downside scenario	Real GDP	-1.7	-1.1	0.4	713	20%
	Unemployment	4.7	5.3	5.6
	HPI	0.9	0.4	2.7
Belgium Upside scenario	Real GDP	2.7	2.3	1.9	544	20%	596
	Unemployment	5.1	4.6	4.5
	HPI	5.2	4.9	5.4
Baseline scenario	Real GDP	1.1	1.4	1.6	585	60%
	Unemployment	5.9	5.6	5.5
	HPI	3.7	4.2	4.4
Downside scenario	Real GDP	-1.5	0.1	1.4	682	20%
	Unemployment	7.0	7.7	7.9
	HPI	1.8	2.6	2.6
United States Upside scenario	Real GDP	3.2	2.9	2.7	64	20%	105
	Unemployment	3.2	2.5	2.6
	HPI	4.8	9.4	10.9
Baseline scenario	Real GDP	2.0	2.0	2.0	92	60%
	Unemployment	4.3	4.1	4.1
	HPI	1.4	2.7	3.6
Downside scenario	Real GDP	-0.4	-0.1	0.8	184	20%
	Unemployment	6.7	7.2	7.5
	HPI	-5.1	-7.9	-5.5
1Excluding management adjustments.


Sensitivity analysis as at December 2024 (*)
		2025	2026	2027	Unweighted ECL (€ mln)	Probability-weighting	Reportable ECL (€ mln)1
Netherlands Upside scenario	Real GDP	2.6	3.0	2.5	193	20%	270
	Unemployment	3.5	3.3	3.3
	HPI	18.9	11.7	2.5
Baseline scenario	Real GDP	1.5	1.4	1.5	249	60%
	Unemployment	4.0	4.1	4.3
	HPI	9.1	3.5	2.4
Downside scenario	Real GDP	-0.4	-1.4	-0.2	411	20%
	Unemployment	5.7	7.2	8.1
	HPI	-3.7	-7.2	2.2
Germany Upside scenario	Real GDP	2.0	2.8	1.6	510	20%	548
	Unemployment	2.9	2.4	2.0
	HPI	5.4	8.9	9.9
Baseline scenario	Real GDP	0.5	1.1	1.2	540	60%
	Unemployment	3.4	3.3	3.2
	HPI	2.6	5.6	6.3
Downside scenario	Real GDP	-1.7	-1.7	0.3	609	20%
	Unemployment	4.7	5.6	5.9
	HPI	-1.7	1.3	2.2
Belgium Upside scenario	Real GDP	2.2	2.6	2.1	534	20%	579
	Unemployment	5.1	5.0	4.9
	HPI	4.8	4.5	4.4
Baseline scenario	Real GDP	1.1	1.5	1.6	569	60%
	Unemployment	5.7	5.7	5.6
	HPI	3.2	4.1	3.8
Downside scenario	Real GDP	-0.6	-0.2	1.1	654	20%
	Unemployment	7.0	8.0	8.0
	HPI	1.2	2.9	2.5
United States Upside scenario	Real GDP	3.1	3.5	3.2	74	20%	113
	Unemployment	3.4	2.4	2.3
	HPI	4.3	8.4	9.4
Baseline scenario	Real GDP	2.0	2.0	2.0	101	60%
	Unemployment	4.2	4.1	4.0
	HPI	3.3	3.7	3.9
Downside scenario	Real GDP	-0.1	-1.1	-0.4	187	20%
	Unemployment	5.9	7.3	8.0
	HPI	-0.7	-3.0	-2.5
1Excluding management adjustments.


EU MR2-A: Market risk under Internal Model Approach
in EUR million		2025		2024
		RWA	Total own funds requirements	RWA	Total own funds requirements
1	VaR (higher of values a and b)	1,521	122	1,964	157
(a)	Previous day’s VaR (VaRt-1)		33		49
(b)	Multiplication factor (mc) x average of previous 60 working days (VaRavg)		122		157
2	SVaR (higher of values a and b)	2,877	230	4,915	393
(a)	Latest available SVaR (SVaRt-1))		51		116
(b)	Multiplication factor (ms) x average of previous 60 working days (sVaRavg)		230		393
3	IRC (higher of values a and b)	2,014	161	1,457	117
(a)	Most recent IRC measure		144		116
(b)	12 weeks average IRC measure		161		117
4	Comprehensive risk measure (higher of values a, b and c)
(a)	Most recent risk measure of comprehensive risk measure
(b)	12 weeks average of comprehensive risk measure
(c)	Comprehensive risk measure - Floor
5	Other	582	47	340	27
6	Total	6,994	560	8,676	694


38 Liabilities and off-balance sheet commitments by maturity	F-306
39 Transfer of financial assets, assets pledged and received as collateral	F-309
40 Offsetting financial assets and liabilities	F-310
41 Commitments	F-315
42 Legal proceedings	F-316
43 Principal subsidiaries, investments in associates and joint ventures	F-318
44 Structured entities	F-319
45 Related parties	F-321
46 Capital management	F-323
47 Condensed financial information of the parent company	F-325
48 Subsequent events	F-330



in EUR million	Share capital and share premium	Other reserves	Retained earnings	Shareholders' equity (parent)	Non-controlling interests	Total equity
Balance as at 31 December 2024	17,148	-687	36,243	52,703	995	53,698
Net result		14	8,310	8,324	275	8,599
Other comprehensive income		-151		-151	181	30
Total comprehensive income net of tax		-137	8,310	8,173	456	8,628

Dividends and other cash distributions 29			-3,691	-3,691	-195	-3,886
Share buyback programmes, commitment			-3,100	-3,100		-3,100
Share buyback programmes, repurchases of shares		-3,705	3,641	-64		-64
Share buyback programmes, cancellation of shares	-1	2,000	-1,999			0
Employee share-based compensation plans		60	-8	52	0	52
Other changes in treasury shares		6		6		6
Transfers		-616	616			0
Other changes			5	5	-1	4

Balance as at 31 December 2025	17,147	-3,080	40,016	54,083	1,255	55,339