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Contents
Introduction

About this report | 3 |

Strategy and performance

The w orld around us | 4 |
Our strategy | 6 |
Superior customer experience | 7 |
How we are making the difference | 23 |
Our performance | 30 |

Our leadership and corporate governance

Our leadership | 34 |
Supervisory Board report | 36 |
Corporate governance | 47 |
Conformity Statement | 49 |

Risk management

Risk management at ING Bank | 50 |
Solvency risk | 61 |
Credit risk | 64 |
Market risk | 97 |
Funding and liquidity risk | 110 |
Environmental, social and governance risk | 114 |
Non-financial risk | 119 |
Compliance risk | 121 |

Model risk | 127 |
Business risk | 130 |

Consolidated financial statements

Consolidated statement of financial position | 133 |
Consolidated statement of profit or loss | 134 |
Consolidated statement of comprehensive income | 135 |
Consolidated statement of changes in equity | 136 |
Consolidated statement of cash flows | 139 |
Notes to the consolidated financial statements | 141 |

Parent company financial statements

Parent company financial statements | 237 |

Other information and appendices

Independent auditor’s report | 258 |
Articles of Association – Appropriation of results | 266 |
Risk factors | 267 |

Contents |  | Introduction |  | Strategy and performance |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

ING Bank Annual Report 2022 2
About this report
ING’s purpose is empowering people to stay a step ahead in life and in business. I n this report we describe
how we live up to this purpose and create value. When assessing ING’s ability to create value in the short,
medium and long term, stakeholders look at our financial and non-financial performance.
In this report, the sections Strategy and performance, Risk management and Our leadership and corporate
governance, together form the Report of the Management Board Banking. This annual report also contains
ING Bank N.V. consolidated and parent company financial statements, and other information.
This report is intended to inform stakeholder groups that have an impact on or are impacted by our
business. This includes customers, investors and shareholders, regulators and supervisors, employees,
government authorities and non-governmental organisations.
It aims to give our stakeholders a balanced overview of our activities and ING’s ability to create and sustain
value.
In this annual report, unless otherwise stated or implied by context, references to 'ING Bank' refer to ING
Bank N.V. and references to 'ING', the 'Company', the 'Group', 'we' and 'us' refer to ING Bank N.V. and its
consolidated subsidiaries.

Contents |  | Introduction |  | Strategy and performance |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

ING Bank Annual Report 2022 3
The world around us
Despite the initial threat posed by the omicron variant of Covid-19, the
world economy started 2022 with a strong economic recovery to the
point where many advanced economies returned to levels of output
seen prior to the pandemic. This was mainly driven by catch-up
demand for consumer services as households spent more on leisure in
the first quarters of reopening. In some cases, like the Netherlands, the
pre-pandemic level of GDP was quickly surpassed.
With economies reopening, a surge in economic activity in the first half of the year was met by high
inflation rates, mainly related to the energy crisis. The war in Ukraine and related energy crisis was the most
dominant factor in the global economy in 2022. It pushed up inflation dramatically in Europe, to levels not
seen for decades. It has also added to shortages that were already plaguing the European economy.
This caused pain among businesses and consumers alike and rapidly slowed the eurozone to stagnation,
bordering on recession. The US also battled a surge in prices and China continued to struggle economically
due to the continued impact of Covid-related lockdowns and a struggling real estate sector. The UK battled
financial instability after the Truss Government's mini-budget and the budget cuts announced afterwards.
High inflation also prompted a strong response from central banks worldwide. The Fed led the global interest
rate hike cycle, but the ECB also made quick moves towards normalisation of interest rate policy. Ending net
purchases in the ECB’s Pandemic Emergency Purchase Programme and Asset Purchase Programme was
followed by rapid rate hikes over the course of the second half of 2022, which turned into the most
aggressive hike cycle ever by the ECB. This had a marked impact on the financing environment globally with
investment appetite slowing for both households and corporates.
Climate change risk
ING is aware of the risks associated with climate change and how these can impact customers and their
financial health. This includes physical risk and transition risk. Physical risk can be acute, such as flood and
wildfires, or chronic, such as increased temperature and rising sea levels. Transition risk can be driven by
policy, technological or market changes as we shift towards a low-carbon global economy and potentially
lead to stranded assets.
Financial crime risk
We’re committed to fulfilling our role as a gatekeeper to the financial system, to protect customers, society
and our bank from the corrosive effects of financial crimes such as money laundering, terrorist financing,
bribery and corruption, sanctions evasion and tax offences. It’s our intention to not just comply with
applicable laws and regulations in relation to financial crime, but also to continue to strengthen our financial
crime control framework in a robust and sustainable way to prevent, detect and respond to illicit activity.
We continue to seek to harness new and innovative technological capabilities to create a safer environment
for customers, our bank and society. In 2022, we further adjusted our financial crime risk appetite and
framework of policies and procedures to reflect changes in the risk environment and responded to external
developments.
We also sought to further empower our people with the skills and knowledge to fight financial crime, sharing
insights with them about emerging and evolving threats (including in relation to financial crime risks linked
to or heightened by the Covid-19 pandemic) and enhancing our training framework.
Fighting financial crime and protecting the integrity of the financial system is a challenge for all banks, given
the constantly changing environment and pace at which criminals evolve their methods. We believe we can
be more effective in our efforts if we collectively join forces and share intelligence with other banks and with
national, European and international authorities and law enforcement to combat financial crime. We
therefore continue to proactively participate in public-private partnerships, such as Transaction Monitoring
Netherlands and Germany’s Anti-Financial Crime Alliance, and to collaborate with other banks. Read more in
‘How we are making the difference’ and ‘Compliance risk’.
Cybercrime
Cybercrime remains a continuous threat to companies in general and to financial institutions in particular.
Both the frequency and the intensity of attacks are increasing on a global scale. The sophistication and
implications of ransomware attacks are growing concerns.

Contents |  | Introduction |  | Strategy and performance |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> The world around us
ING Bank Annual Report 2022 4
Continuous enhancement of the control environment, to protect from and detect and respond to e-banking
fraud, distributed denial of service (DDoS), targeted attacks and more specific ransomware attacks remains
one of the highest priorities. Additional 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. In
addition, ING continues to strengthen its global cybercrime and fraud resilience through extensive
collaboration across the globe with financial industry peers, law enforcement authorities, government (e.g.
National Cybersecurity Centre) and Internet Service Providers (ISPs). See also ‘How we are making the
difference’ and ‘Non-financial risk’.
Inflation risk
Inflation rates accelerated across the globe at the beginning of 2022, fuelled by the war in Ukraine.
Inflationary pressure prompted an adjustment in monetary policy by major central banks and lead to rising
interest rates and tighter global financial conditions.
The mix of high inflation and rising interest rates further deteriorated macro-financial conditions,
aggravating pre-existing vulnerabilities for both businesses and households, which were recovering from the
economic consequences of the Covid-19 pandemic, and ultimately increasing banks’ credit risk. Against this
background while ING took additional provisions throughout 2022, it also benefited from the significantly
higher interest rates.
EU member-state governments introduced several supporting measures to cushion the rise in energy prices
and inflation. These measures, in conjunction with the reduced fiscal space resulting from pandemic-related
support measures and the normalisation of the monetary policy stance, increased sovereign vulnerabilities
in financially weaker countries.

Contents |  | Introduction |  | Strategy and performance |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> The world around us
ING Bank Annual Report 2022 5
Our strategy
ING’s purpose is to empower people to stay a step ahead in life and in
business. Our updated strategy, introduced in 2022, is built around this
purpose and making the difference for people and the planet. In a world
that’s constantly changing, we’re digital and sustainability pioneers,
adept at adapting to the trends impacting our business.
Our two overarching priorities are giving customers a superior customer experience (CX) and putting
sustainability at the heart of what we do.
We also have four enabling priorities:
1. Providing seamless, digital services.
2. Using our scalable technology and operations.
3. Staying safe and secure.
4. Unlocking our people's full potential.
Giving customers a superior experience
We want to put customers at the centre, providing them with the superior experience that is our true source
of differentiation. We believe that banking is a secondary need, and that financial products and services, for
the most part, are commoditised. A superior customer experience is how we can stand out from the crowd.
The rapid digitalisation of society has huge impact on what customers expect from us. They don’t just
expect an experience that is digital and seamless, they expect a specific level and quality of experience. A
digitally-enabled personal, easy, relevant and instant experience is now the base expectation of all
customers, but we also realise that different types of customers have different needs and different ways of
interacting with us.
Putting sustainability at the heart of what we do
We have a responsibility to society to define new ways of doing business that align with economic growth
and social impact. Climate change is one of the world’s biggest challenges, threatening both our planet and
its people, many of whom also struggle with inequality, poor financial health and even a lack of basic
human rights. We’re determined to be a banking leader in building a sustainable future for customers,
society and the environment. We want to lead by example by striving for net zero in our own operations.
We also want to play our part in the low-carbon transformation that's necessary to achieve a sustainable
future, aiming to steer our financing towards meeting global climate goals and working with clients to
achieve their own sustainability goals. For more information go to our 'Sustainability at the heart' chapter.
Our enablers
Providing seamless, digital services
We know that we can make customers happy with robust, 'always-on' channels, data-enabled personalised
experiences and digitalisation of processes with limited human intervention there where needed.
Using scalable technology and operations
A technology and operations foundation that is modular and scalable brings many benefits, including
superior customer experience and safety, speeding up time-to-volume, shortening time-to-market, and
lowering cost-to-serve.
Staying safe and secure
Trust is the starting point, the most basic requirement, for all stakeholders. That’s especially true for a
digital-first bank like ING. People trust us with their money and with their data. Keeping it safe, and
maintaining this trust are crucial.
Unlocking our people's full potential
We want all employees to have skills and capabilities that equip them for the future. We also want to
provide them with an excellent employee experience and promote a diverse, inclusive and vital culture
where everyone feels they belong.

Contents |  | Introduction |  | Strategy and performance |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> Our strategy
ING Bank Annual Report 2022 6
Superior customer experience
Customers expect an experience that’s personal, easy, relevant and
instant. What this looks like depends, of course, on the type of
customer. For individual customers and small businesses our emphasis
is predominantly on mobile banking, while for mid-corporate and
Wholesale Banking clients it’s all about personal relationships and
superior sector and network expertise supported by seamless digital
delivery.
As an organisation we need to be customer focused – after all, customers are who we’re here for, our
reason for being. And if we want customers to choose us for more of their banking needs, to become
primary customers, we need to nurture relationships with them so that they choose ING before any other.
At every step of their ING journey, customers should feel an emotional connection with us: that’s how we
win customers’ hearts and their business. Banking is a relationship just like any other, and the best
relationships are those in which people feel valued, confident, empowered and in control. In response to
customers’ changing expectations in today’s always-on digital society, we’ve updated our customer
experience principles. We want to provide customers with an experience that is personal, easy, relevant and
instant.
Personal is about recognising customers as individuals and getting to know their needs, goals and
challenges so they feel valued. For example, we should not ask for information twice when we interact with
them, and we tailor messaging to their specific situation.
Easy is about taking the complexity out of banking, making it intuitive, transparent and understandable so
customers feel confident. For example, we aim to clearly price products and services, we avoid complicated
jargon and we’re always accessible.
Relevant is about bringing value to customers, anticipating their needs and proactively providing the right
insights, advice and solutions at the right time, making them feel empowered. For example, guiding them
on difficult financial decisions, like re-financing a mortgage in an environment of rapidly increasing interest
rates.
Instant is about having solutions at their fingertips that put the customer in the driver’s seat of their
finances and making them feel in control by allowing them, for instance, to switch seamlessly between self-
service banking on the app and personal advice in a branch. Different groups of customers have different
requirements. For Retail Banking and some Business Banking customers (i.e. consumers, the self-employed
and small and medium-sized enterprises), the emphasis is on mobile, for both products and services. For
Wholesale Banking (corporate clients) and Business Banking mid-corporates, the emphasis remains on
deepening client relationships, with superior sector knowledge and networking expertise, relevant advice
and tailored products, all supported by seamless digital delivery and services.
CX Day
On 15 November, ING held a global CX Day, with over 5,500 colleagues from across the bank joining
together to come up with ways to make customer experiences personal, easy, relevant and instant. The
event attracted employees from Retail Banking, Business Banking, Wholesale Banking and the support
functions in 11 countries. Together, they identified over 1,000 improvements to delight our customers.
Some of those improvements were implemented live on the day.
Retail Banking
For customers using Retail Banking products and services, ING wants to provide a seamless digital, mobile-
first experience that’s personal, easy, instant and relevant. We want to engage with our customers on
mobile at every stage of their journey and provide more personalised products and services based on data-
driven, relevant insights. Seamless end-to-end digital delivery of customer services is a an enabler for a
superior customer experience to earn, and keep, the primary relationship.
Earning ‘primary relationships’ with customers is an important driver for profitable growth. It leads to deeper
relationships, greater customer satisfaction and ultimately customers choosing us for more of their banking
needs. We want to be our customers’ first partner for their financial business. In Retail Banking, primary
customers have at least two active ING products. One of these should be a current account into which they
deposit regular income.

Contents |  | Introduction |  | Strategy and performance |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> Superior customer experience
ING Bank Annual Report 2022 7
Mobile-first
Reflecting customer demand, we are continuously improving our mobile capabilities. In 2022, over 58
percent of customers used mobile banking only (mobile device log in through the app or mobile device log in
through the website) compared to 51 percent in 2021. High adoption of mobile banking is especially visible
in Turkey (88 percent), Romania (74 percent), Spain (63 percent) and in the Netherlands (61 percent).
In the Netherlands, we increased our reach for iOS and Android users to 70 percent with a new method to
fully onboard new customers via their mobile phone. The process takes about 10 minutes and customers
can immediately start using the account afterwards. Our reach extends to all customers that can use
mobile onboarding, i.e. customers with a Dutch passport, ID card or residence permit, those from other
European Economic Area countries and refugees from Ukraine.
Visa Mobile is a new online payment method available for retail customers in Poland. Visa contactless and
prepaid virtual card users may activate Visa Mobile in their ING mobile app. Customers can pay with their
card without using the card's data, by entering the recipient's phone number and confirming payment in
their ING mobile app. Payment is fast and secure. In Romania, ING became the first bank to digitalise the
mortgage journey, launching 100 percent online financial pre-approval, directly from Romania’s internet
banking platform. Customers interested in a mortgage loan are able to find out the exact amount they can
borrow without having to go to the bank.
At Interhyp, our online mortgage broker in Germany, the HOME platform digitalises the mortgage process
for home buyers, advisors, brokers and bank partners. Interhyp customers can connect directly to real-
estate portals, create financing scenarios and upload documents from their smartphones, speeding up the
mortgage decision process. In Spain, we launched instant lending for customers that are new to the bank.
This new service uses instant and automatic processes that provide a differentiated, quick and convenient
lending solution.
Daily banking and savings
Everyday Roundup is a digital product that aims to make saving simpler at a time when customers may be
financially vulnerable (due to the cost-of-living crisis). It is used by over 1.1 million customers in six countries
(Poland, Australia, Germany, Romania, Turkey and, since 2022, Spain). It works by rounding up every
transaction on a customer’s current account and automatically transferring the difference to their savings
account. ING in Australia, Germany and Turkey also have a round-up option for donations to charities.
Similarly, Australia has a round-up option for mortgages, while Spain has a round-up option for investments.
Dealwise, a smart shopping platform (accessible in the banking app), is another initiative that encourages
customers to save on their daily spending. It gives users access to discounts and cashback offers from
participating merchants. Dealwise is available to customers in Romania, Germany and Belgium. Additionally,
in Spain, we updated our daily banking proposition, including the launch of a new, commitment-free
account, that aims to increase new-to-bank customers, has a fully online and instant onboarding process,
and has new services like e-commerce insurance and a subscriptions manager.
Remote advice
More customers are using remote video advice and digital self-service channels. We can connect with
customers across multiple channels through ING’s cloud-based customer interaction platform for phone,
chat and video contacts. Our global customer interaction platform is used in seven countries to harmonise
the experience and ensure customers receive the same services everywhere. Compared to last year, we
doubled the number of remote advice video meetings and witnessed a rise in customers using the chat
function on our websites and mobile apps while realising a reduction in branch traffic. As we continue to
optimise our assisted channels, we are also reducing the number of ING branches, with 94 branches closed
in 2022.
Investment products
ING customers have access to smart digital investment tools like My Money Coach in Italy, Naranja+ in
Spain, Easy Invest in the Netherlands, Komfort-Anlage (Comfort Investing) in Germany and ING Self Invest in
Belgium.
Insurance
ING has teamed up with insurance partners in various Retail Banking markets to offer customers insurance
products via the ING app or website, based on the local needs within those markets. We offer insurance
linked to loans as well as a range of standalone non-life insurance policies. In the Netherlands, we set-up a
new distribution partnership with Dutch health insurer CZ. In Romania, we launched salary protection
insurance offering customers financial support in case of job loss, prolonged medical leave or permanent
invalidity. In Turkey, we introduced digital assistance for insurance and pension products, which led to one
of the very first digital remote offers for pensions in the Turkish market. During 2022, we also set up new
offers linked to our daily banking activities, including group travel insurance in Romania and online purchase
and cash withdrawal protection in Poland.

Contents |  | Introduction |  | Strategy and performance |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> Superior customer experience
ING Bank Annual Report 2022 8
Measuring Retail Banking NPS
One of the ways we measure our progress is through the Net Promoter Score (NPS), which indicates
customer satisfaction and loyalty (whether they would recommend ING to others) compared to selected
peers in each market. The score is calculated as the difference between the percentage of promoters (who
rate ING as 9 or 10 out of 10) and detractors (those scoring ING below 6). Our peers have been selected
based on qualitative and quantitative criteria like size, brand strength, types of clients served and types of
products and services. The yearly NPS score is an average of reported four quarter figures, based on a six
months’ rolling average. In 2022, ING enhanced its methodology from an average of two quarters to a six
months’ rolling average. The updated methodology concerns a refinement and does not significantly
impact the NPS score and ING’s ranking for 2021 and 2022. Our aim is to achieve a number one NPS ranking
in all our Retail markets, with a 10-point lead over our main competitors. In 2022, ING ranked number one in
five of 10 Retail markets. In these five markets, we have a 10-point lead on the nearest competitor. In
Germany and Spain, ING’s scoring improved on last year while Australia, Poland and Romania maintained
their strong scores. ING ranks in the top-three in another four markets: the Netherlands and Luxembourg
(ranked second) and Italy and Turkey (ranked third).
Closing of Retail businesses
In 2022, ING took the decision to close its Retail Banking operations in the Philippines. We concluded that the
time to achieve the desired scale was too long and we decided to concentrate on our core markets. ING
started its Retail Banking operations in late 2018 and retains a Shared Service Hub and Wholesale Banking
presence in the country. In 2021, ING announced it would leave the Retail Banking market in France
following a strategic review. In 2022, ING and Boursorama (a subsidiary of Société Générale) signed an
agreement to offer services to ING customers in France. The contract allowed ING customers to join
Boursorama and benefit from a simplified account opening process and exclusive offers. The agreement
also includes the transfer to Boursorama of ‘assurance-vie’ (investment products) contracts, for which ING
acts as a broker with Generali Vie. Home loans and consumer loans were not included in the agreement.
Business Banking
Business Banking is set up as a third pillar within ING and is a part of Retail Banking. While definitions can
differ slightly per country, we’ve defined three customer segments using the following global framework:
Self-employed and micro companies: Independent professionals or small companies that employ up to 10
people and have a turnover up to one million euros.
SMEs: Small to medium-sized companies that employ between 10 and 250 people and have a turnover
between one and 10 million euros.
Mid-corporates: Sophisticated larger companies employing more than 250 employees with a turnover of
between 10 million and 250 million euros.
Business Banking serves 1.7 million customers and generates €3 billion in revenue across seven markets: the
Netherlands, Belgium, Luxembourg, Poland, Romania, Turkey and Germany. Customers want to manage
and grow their businesses in a constantly changing and increasingly complex world. Our aim is to empower
them by providing all their financial solutions in one place and offering the right insights, products and
services at the right time, to create an personal, easy, relevant and instant experience.
We apply a needs-based customer segmentation approach that differentiates between basic and more
complex (specific) needs. This enables customers to 'self-serve' using our strong digital foundation, but also
access remote and face-to-face advice, when needed. With digitalisation at the core of our strategy and to
meet increased demand for digital solutions and self-service, our ambition is to serve over 80 percent of
SMEs digitally. We focus our efforts on the most important interactions: KYC outreach for customer due
diligence, onboarding, account opening and loan or card requests.
For example, in Germany, we launched our second lending product, Flexkredit, where Amazon sellers can
easily make their loan application from the Amazon Marketplace seller portal (Seller Central). The
disbursement and management of the product is via their online banking, Business Banking Home. If
eligible, an offer is available within 48 hours. In Belgium, we offer customers, based on their financial
situation, instant business credit within minutes, which is available the next working day. We inform them
about this offer in our mobile banking app and on internet banking, including personalised eligibility and
maximum credit availability details. For Polish customers, we have created a product offer page within their
online banking listing products and services tailored to individual customer needs. Product
recommendations for each customer can be directly acquired online.
As well as providing improved customer experiences through digitalisation and personalisation, we are
putting sustainability at the heart of what we do with our efforts on climate action and financial health. We
help customers to future-proof their businesses by offering sustainable financing alternatives. For example,
we offer sustainable finance alternatives (loans and/or lease) for SMEs and mid-corporates in most Business
Banking countries where we operate (the Netherlands, Belgium, Poland, Romania, Turkey and Luxembourg).
Wholesale Banking
In Wholesale Banking, we aim to empower clients by partnering with them to offer relevant financial
solutions to their business needs across their value chains, and to support them through the 'ING difference',
three major characteristics that offer particular value to clients:

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> Superior customer experience
ING Bank Annual Report 2022 9
1.Our global reach, with local experts: no matter where clients are, our network of experts offer them a
seamless local experience with a global view.
2.We’re sector experts: clients trust us to provide tailored solutions to meet their needs.
3.We’re sustainability pioneers: we’re not just leaders in sustainable finance, we work hand-in-hand with
clients to address some of the most pressing issues in the world today.
We're driving growth by making the most of our strengths and broadening our value proposition to clients,
while optimising our use of capital and enhancing financial performance. This is highlighted in deals such as
that with GlobalConnect, a Nordic technology media and telecom (TMT) company. After ING co-advised on a
sustainability-linked loan structure in 2021, GlobalConnect enhanced its sustainability strategy on ING’s
recommendations and ING ultimately supported them by securing the sole sustainability coordinator role
on both their €2.7 billion existing and €1 billion incremental financing rounds. The ING difference is reflected
in partnership initiatives such as leveraging ING’s sector knowledge to lead a working group to design a
climate-aligned finance agreement for steel. In 2022, we were proud to be one of six banks to sign up to the
Sustainable STEEL Principles, which aims to help banks measure and report emissions associated with their
steel loan portfolios compared to net-zero emissions pathways. Read more in the 'Sustainability at the
heart' chapter.
In 2022, at the Global Finance magazine Sustainable Finance Awards ING won the global award for
Outstanding Leadership in Sustainable Bonds for the second year running and the Sustainable Project
Finance award for Western Europe. Our client segmentation model aligns our strengths with client needs
and is an important element for deepening relationships. ING’s way of working allows us to respond rapidly
to our clients’ changing needs and to close the gap between local and global specialists, making an impact
in our markets.
During the year, we continued to combine our sector knowledge and financial expertise to support
companies with tailored advisory and daily banking, in line with the client segmentation model. We aim to
provide relevant advice, data-driven insights and customised, integrated solutions that make our clients
day-to-day banking more efficient and support their business ambitions. Corporate clients also benefit from
gains in speed, transparency, security and efficiency created by technologies such as blockchain and
artificial intelligence.
Measuring Wholesale Banking NPS
A relationship NPS programme ran in 32 WB markets throughout 2022, it concerns a qualitative measure of
the client experience and the quality of the relationship and how likely clients are to recommend ING. The
score is calculated as the difference between the percentage of promoters (who rate ING as 9 or 10 out of
10) and detractors (those scoring ING below 6). In 2022, ING’s relationship NPS score rose to an all-time high
of 67 (on a scale of -100 to +100), from +59 in 2021, an increase of 13.5%. Increases were prevalent in most
of the sectors and regions. The response rate increased to 71% from 62%.
Finding new ways to help customers stay a step ahead
ING has always prided itself on its innovative culture and considers this an important contributor to a
superior customer experience. To keep surprising customers in a fast-moving competitive environment, we
need to keep finding fresh ways to translate emerging trends and technologies into new business
opportunities. In 2022, we announced a move to bring innovation closer to our Retail, Business Banking and
Wholesale Banking business lines to create more impact for our innovation efforts. For incremental-type
innovations that support our strategic priorities of CX and sustainability, such as digitalising processes, we
believe this is better done within individual business lines where we are closer to the customer. Innovation
projects like CoorpID and Blacksmith, for instance, continue under Wholesale Banking's leadership.
In 2022, ING invested and partnered financial technology (fintech) companies via its venture capital arm,
ING Ventures. One such investment was in SeMI Technologies, offering AI-powered search engine software
to companies who want to make better use of their data. Other investments include Vault (cloud-based core
banking technology), OpenFin (unified workspace solution for financial institutions) and Sardine (safer, faster
payments). ING in Belgium also collaborated with Flowcast, an early warning system to predict when retail
customers might go into financial distress.
ING announced in 2022 that it would phase out Yolt's business-to-business open banking operations
following an evaluation that it was not feasible to achieve the preferred scale in their market within a
reasonable time frame. The announcement followed the closure in 2021 of Yolt's personal finance
management app. The phase-out process is expected to be completed in 2023.

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> Superior customer experience
ING Bank Annual Report 2022 10
Sustainability at the heart
Sustainability is at the heart of what we do because we believe we have
a role in defining new ways of doing business that aligns economic
growth with positive social and environmental impact. This includes
aiming to bring our own operations in line with a low-carbon future and
respecting and advancing human rights. As a global bank we can also
have a positive impact, not just by mitigating harm, but by bringing
aspects of climate change, biodiversity and human rights into our
financing decisions and client dialogues.
ING takes a holistic approach to sustainability, with climate change mitigation, climate adaptation, climate
and environmental risk, biodiversity, human rights, financial health, business ethics and other ESG issues all
in scope.
As well as aiming to be a pioneer in defining new ways of doing business, ING wants to be a leader in
building a sustainable future for customers, the environment and our company. How? By focusing on:
Climate action: We lead by example by striving for net zero in our own operations.
Collaboration: We work with clients to achieve their own sustainability goals, increasing our impact through
partnerships and coalition-building.
Managing climate-related, environmental and social risk: We manage the most relevant environmental
and social risks while fostering the protection of biodiversity and human rights across all of our relationships.
Financial health and inclusion: We’re working to advance financial health and inclusion for customers and
communities.
Empowering colleagues: We empower colleagues to contribute to it all. ING's sustainability efforts were
recognised externally. In 2022, Sustainalytics assessed our management of environmental, social and
governance (ESG) material risk again as 'strong' while investment research firm MSCI awarded ING an AA
ESG rating for the third consecutive year. S&P rated our ESG practices for the second year in a row as
'strong'.
While we are committed to doing our part, we know that the world's problems cannot be solved by one
sector, much less by one bank. We look to governments, for example, to direct and guide the change
needed to reach net zero by 2050. We believe that an inclusive approach is the only way we can make any
meaningful positive impact. From climate to human rights and financial health, we seek to increase our
impact through partnerships and coalition-building.
Climate action
We have defined four climate action objectives: to reach net zero in our own operations, to steer the most
carbon-intensive parts of our portfolio towards net zero by 2050 or sooner, to finance and advise specific
clients in line with a net-zero economy and to manage climate and environmental risks. In 2022, we
published our second integrated climate report, which can be found on ing.com. We have now published
four overall climate reports.
Aiming for net zero in our own operations
We aim to bring our business in line with the net-zero economy of the future and use our Environmental
Programme to steer our progress towards this. Adjusting to the post-pandemic ‘new normal’, we have set a
new mid-term target for 2025 to reduce our CO2e emissions by 75 percent compared to our 2014 baseline,
for emissions from scope 1, scope 2, and business travel scope 3. In 2022, we reduced emissions by 72
percent from 2014, to 29 kilotonnes – 28 percent of where we were in 2014. In 2021 the figure was 26
kilotonnes where our operations were heavily impacted by Covid-19-related restrictions.
Following migration to a new data platform, we conducted a historical review of our carbon-related data. In
doing so, we made corrections to previously reported datapoints, corrected our coverage statistics for
extrapolation where those were incorrectly applied, and improved our methodology by applying more
granular emission factors for our use of district heating. Comparative figures and baseline year data were
updated to reflect these improvements. Read more in the technical appendix to this report.
We previously shared a scope 1 and scope 2 mid-term target of a 90 percent reduction by 2030. We plan to
review this and publish a combined 2030 target for scope 1, scope 2 and scope 3 for business travel. Scope 1
covers our direct, controlled emissions from natural gas and heating oils, scope 2 covers our indirect
emissions from the generation of purchased energy i.e. electricity and district heating, and scope 3
currently covers emissions in our value chain from business travel (air and car). We intend to review our
scope 3 reporting to include new emission categories. As we conduct the review, we will likely set a new
baseline year for our reporting.
ING buildings
For building emissions, we are committed to improving energy efficiency and reducing our emissions from
heating systems. In 2022, we completed a net-zero assessment on major buildings, which will form the
basis of our approach going forward.

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> Sustainability at the heart
ING Bank Annual Report 2022 11
Since 2014, ING has increased the percentage of renewable electricity sourced for our operations. In 2022,
we further aligned with the reporting guidance of the RE100, a technical group that sets industry standards
around corporate use of renewable electricity. We assessed that our renewable electricity sourcing in 2022
was 99.2 percent aligned with RE100's market boundary criteria. The remaining 0.8 percent was not in
alignment due to difficulties in purchasing renewable electricity in Russia, Ukraine, South Korea and
Kazakhstan. For these markets, in addition to reporting CO2 emissions for electricity used, we sourced
renewable Energy Attribute Certificates in neighbouring markets to support an in-sector reduction in line
with the amount of electricity used. In 2020, 99.7 percent was aligned with the RE100 market boundary
criteria; in 2021 that was 99.2 percent. We acknowledge that over time we should move towards more on-
site renewables and direct purchasing agreements from local renewable projects. Read more about our
renewable electricity sourcing types in the technical appendix to this report.
The Environmental Programme also covers targets to reduce our water consumption and residual waste. In
2022, we decreased our residual waste by 48 percent compared to 2014. In 2022, we decreased our water
consumption by 49 percent compared to 2014.
Business travel
In 2022 we launched a Green Travel Budget Programme to make employees aware of the CO2e impact of
their travel choices and encourage them to find greener options. We also updated global travel procedures
to restrict most air travel on short-haul distances where high-speed rail options exist as alternatives. This
includes travel between Amsterdam, Brussels, London and Frankfurt.
Next to efforts to reduce air travel, in 2022 we also started procuring sustainable aviation fuel (SAF) and SAF
certificates from our partners at Air France-KLM, Lufthansa Group, Neste and SkyNRG. Although we still
report the emissions resulting from our flights the SAF and SAF certificates we purchased supported an in-
sector reduction of approximately 3.2 kilotonnes of CO2e emissions. In addition, we entered into a
partnership with Singapore Airlines as part of our sourcing approach for 2023.
To limit the impact of car travel, we continued to electrify our fleet of leased cars. In 2022, ING in Belgium
and the Netherlands announced that only fully electric vehicles (EVs) would be available in its range of new
lease cars. Together, Belgium and the Netherlands represent 72 percent of our lease cars. Globally, we have
an ambition to reach at least 90 percent EVs in our fleet by 2030. This ambition requires countries like the
Netherlands and Belgium to reach 100 percent earlier, while accounting for EV infrastructure challenges in
other countries.
Empowering clients on their road to net zero
In line with our objective to steer the most carbon-intensive parts of our portfolio towards net zero by 2050
or sooner, through our Terra approach, in 2021 we joined the Net-Zero Banking Alliance. This allows us to
use our experience and knowledge to help standardise the way banks measure their alignment with climate
goals and to base our approach on the most recent developments in each sector. We are convinced that all
banks benefit from having an industry-wide standard for measuring the effectiveness and impact of their
efforts as well as increasing transparency. We continue to collaborate with others to develop roadmaps and
methodologies, including for hard-to-abate sectors.
Supporting the energy transition
While we engage with different stakeholders in our ambition to help create a low-carbon society, we believe
that financial support for the energy transition could play the largest part in realising this ambition. Today,
around 80 percent of the global energy mix is fossil-fuel based. Reducing that figure is vital in reaching
society's net-zero emissions targets. Our approach to financing the energy sector balances three main
societal interests: the need to decarbonise to fight climate change, the need for energy to remain accessible
and affordable for people and companies, and the need for security of the energy supply.
Ultimately, building enough new renewable and low-carbon sources of energy will remove the need for
fossil fuels and ING strongly supports the objective of this transition. However, fossil fuels currently play an
important role in the global energy mix, considering the current availability of renewable and low-carbon
sources, and the need to fulfil other, social, sustainable development goals. The global economy’s reliance
on fossil fuels, in particular a phase-out of coal for power generation, must reduce to significantly lower
levels over the next 10 to 15 years, according to the energy transition pathway set out in the International
Energy Agency’s Net-Zero Emissions by 2050 (NZE 2050) Scenario.
In recent years, ING has stepped up its support for the energy transition to a low-carbon economy. In 2017,
ING set a goal to restrict our financing of coal-fired power generation to close to zero by 2025. So far, we
have decreased lending to individual coal-fired power plants by over 80 percent to €83 million.
With our commitment to develop the Terra approach in 2018, ING set out to develop methodologies and
science-based targets to enable steering of the most emissions-intensive parts of our loan book in line with
the emissions levels required to meet the Paris Agreement goals. Methodologies and targets for power
generation and upstream oil and gas portfolio alignment were set out in the 2019 and 2020 Terra progress
reports respectively. ING’s 2022 Climate Report shows how interim and long-term targets for these activities
are benchmarked against sector-specific indicators set out in the NZE 2050 Scenario, and the
outperformance to date in steering our energy sector lending portfolio in line with the global energy mix
required to hold the global average temperature increase to below 1.5˚C by 2050.

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> Sustainability at the heart
ING Bank Annual Report 2022 12
Next to our Terra approach, which lays out transition plans for the nine sectors we believe to have the most
impact, we reinforced our commitments to supporting the energy transition in March, when we announced
we would step up our renewables energy financing efforts. Our announcement included the aim of growing
new commitments in this area by 50 percent by the end of 2025 for Wholesale Banking clients, compared to
the baseline year of 2021. We also committed to end the provision of dedicated upstream finance to new oil
and gas fields approved for development after 31 December 2021.
Our power generation portfolio follows the North American Industry Classification System (NAICS), which
links power generation to the categories shown below. All relevant NAICS codes have been selected to derive
the O/S (outstandings) per category.

Phasing out coal, reducing oil and gas combustion and increasing renewable and low-carbon energy
sources will not on their own solve the challenge of achieving a net-zero emissions world by 2050.
Recognising that technology and new market developments are essential drivers of the energy transition,
ING has established cross-sector and multi-disciplinary centres of expertise to support client investment in
new energy systems. One important area is batteries, which address the inherent intermittency of
renewable energy resources like wind and solar, as well as providing grid stabilisation services. We are also
looking at other energy storage mediums like hydrogen, which have additional applications such as
alternative fuel for transport and for energy-intensive industry. Finally, we are closely following the
evolution of large-scale carbon-capture utilisation and storage (CCUS) which will be essential where fossil
fuels are required in industrial processes that are needed for the global economy and for which there is
currently no alternative.

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> Sustainability at the heart
ING Bank Annual Report 2022 13
Terra approach
We use our Terra approach to steer the most carbon-intensive parts of our loan book towards net zero by
2050. These are power generation, upstream oil and gas, automotive, shipping, aviation, steel, cement,
residential mortgages and commercial real estate. Within Terra, we apply what we consider to be the best-
fit methodology per sector, (our 'toolbox approach'), to measure and steer our loan book.
In 2022, to promote immediate action towards decarbonisation and to adhere to our Net-Zero Banking
Alliance commitment, we set intermediate 2030 targets for all Terra sectors. Of the nine intermediate
targets, eight are aligned with net-zero scenarios. A net-zero target for shipping will be set as soon as one is
adopted under the Poseidon Principles, a financial industry framework for assessing climate alignment for
the shipping sector. At the end of 2021, five of the nine sectors were on track with their respective climate-
alignment pathways: power generation, upstream oil and gas, commercial real estate, automotive, and
shipping. Two sectors, cement and residential real estate, were within five percent of their pathway, while
steel was just above five percent of its pathway. Aviation came out well above the pathway due to the
extraordinary impact that Covid-19 had on the sector, although it is beginning to trend back to its
decarbonisation pathway as the sector recovers. Our 2023 Climate Report will include updated performance
figures.
In 2022, building on other sector-specific working groups like the Poseidon Principles, ING launched the
Sustainable STEEL Principles, a solution for measuring and disclosing the 1.5 degree alignment of steel
lending portfolios. This was developed with other banks and facilitated by the Rocky Mountain Institute’s
Center for Climate-Aligned Finance. The sector emits roughly seven percent of global CO2 emissions and is
heavily dependent on coal. Chaired by ING, the principles provide a pathway to net-zero steelmaking by
2050 and have been incorporated into our Terra approach. ING started a similar initiative in the aluminium
sector.
Detailed information on ING’s transition plans are available in our integrated climate report on ing.com.
The process for reporting on Terra consists of several steps, most of them carried out by ING’s Global
Sustainability department in collaboration with colleagues in the front office. Internal data relating to our
portfolio composition is made available soon after ING’s year-end close in February. External data relating to
climate performances is collected in or around April. External data is checked for consistency and matched
with internal data. A year-on-year portfolio comparison is made to analyse fluctuations at company or
asset level for each sector. This helps us to understand the drivers behind any changes, which can usually be
attributed to the climate performance of clients, the composition of sector portfolios and improvements in
methodologies. When necessary, scenarios and targets are updated in line with scientific updates to the
decarbonisation pathways aimed at keeping global temperature rises within the necessary limits for a
sustainable future.
Once the process is complete, we draft a progress report, which is incorporated into our integrated climate
report. The report, approved at Board level, was published in September 2022. All progress reported in 2022
relates to 2021. Reporting on progress in the shipping sector is linked to, and aligned with, the Poseidon
Principles timelines. A Poseidon Principles report containing 2021 data was published in December 2022.
Sustainable finance for Wholesale Banking clients
Advancing financing opportunities in line with a net-zero economy for Wholesale Banking clients is a
strategic ambition, and by 2025 we aim to channel €125 billion annually to sustainable finance solutions.
The Sustainable Finance team advises clients on translating their sustainability ambitions into their
financing through sustainability-linked structures, green and social financing solutions, ESG rating advice,
and other ESG advice.
In 2022, the Sustainable Finance team mobilised €101 billion, supported by a broad range of financial
products linked to sustainability elements. Most of these were related to sustainability-linked loans (€39
billion), green bonds (€23 billion) and green loans (€17 billion). However, we believe that alongside volume, it
is also the impact that measures the success of sustainable transactions. This, we believe, is shown in the
additional products and services we develop for customers such as social loans and bonds, sustainable
structured finance, sustainability-linked Schuldscheine and sustainable transaction services such as
guarantees and supply chain finance.
The commitment to mobilise €125 billion annually makes a distinction between transactions where we are
ESG lead, such as ESG coordinator or an ESG structuring role, and transactions where we do not fulfil such a
position, like where we are part of a consortium of banks. Where we are one of several ESG leads or one of
several participants, we record the pro-rata share of the total transaction amount, however, when we are
the sole ESG lead on a transaction, we count the full transaction amount. For bonds, we make a distinction
between active and passive bookrunner role. The reason for selecting this methodology is that if we are ESG
lead in a transaction, we can pro-actively engage with our clients on their sustainability strategy, so our
impact is more significant than if we only participate. See ing.com for more information about the
methodology.
Moreover, we closed 491 sustainability deals (including sustainability loans and bonds, green loans and
bonds, sustainable structured finance, social loans and bonds, and sustainable investments) at year end, up
from 411 in 2021.
Green and social financing structures
We aim to accelerate the green economy by growing our green asset portfolio. Green financing solutions
such as green bonds and loans form an integral part of that. For instance, we acted as sole green loan
structurer in the construction of a transmission line for Champlain Hudson Power Express, ultimately owned
by Blackstone; overall project costs were around USD 6 billion. The 545 km, fully buried transmission line

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> Sustainability at the heart
ING Bank Annual Report 2022 14
should bring 1,250 MW of renewable hydropower from Quebec to New York City. The project is expected to
be finalised in the first half of 2026. This is the largest volume mobilised for a green loan closed by ING to
date.
Our sustainability efforts are also directed towards addressing social challenges. For example, ING acted as
joint lead manager, joint bookrunner and joint social structuring adviser for Singapore-based healthcare real
estate investment trust First REIT’s SGD100 million social bond. This issuance, guaranteed by a trust fund of
the Asian Development Bank, became Singapore’s first-ever healthcare social bond and was awarded Best
Social Bond in The Asset Triple A Country Awards for Sustainable Finance. We also acted as lead arranger,
sustainability adviser and majority investor for Woori Card’s Social Asset Backed Securities, valued at around
€195 million. The transaction won the Best Sustainability Securitisation in The Asset Triple A Country (South
Korea) Award for Sustainable Finance 2022.
Sustainability-linked structures
We incentivise clients who are shifting to more sustainable business models. Sustainability-linked loans
(SLLs) link interest margins to a company’s sustainability performance through mutually agreed KPIs. They
are a way for ING to support, motivate and reward clients in their aim to become more sustainable. In 2017,
ING coordinated the first syndicated sustainability-linked loan in the market for Philips. This loan was linked
to the improvement of Philips’ Sustainalytics ESG rating. In 2022, ING was the sustainability coordinator for
turning this loan into a sustainability KPI-linked loan, with KPIs aligned to Philips' sustainability goals.
Since then, the popularity of SLLs has grown, as sustainability has played an increasingly significant role in
corporate agendas. To date, syndicated SLLs valued at more than €1,000 billion have entered the market.
ING closed 202 sustainability-linked loan transactions in 2022, compared to 147 in 2021. For US-based
Compass Datacenters for example, ING structured a USD1.25 billion SLL with KPIs linked to environmental
and social targets such as the reduction of energy and water consumption, female representation in the
construction workforce and the use of low-carbon concrete. ING also structured an SLL for Compass
Datacenters in Europe.
To enable all market participants to clearly understand the characteristics of these loans, ING was part of a
financial institutions working party that established a set of sustainability-linked loan principles (SLLPs).
These are based around five components: the selection of KPIs, the calibration of sustainability performance
targets (SPTs), loan characteristics, reporting and verification. SLL spin-offs include sustainability swaps,
derivatives and sustainability-linked bonds that are related to the total sustainability profile of a company,
not just for individual projects.
We also look for other ways to support clients taking steps to achieve their sustainability ambitions and
anticipate the future economy. Many of these ambitions are based on innovative technologies, business
models or client propositions that have a higher risk profile and are not yet suitable for standard financing
solutions. ING Sustainable Investments helps clients with their sustainability goals by providing risk-bearing
capital, offering a wide range of tailor-made financial solutions, including equity (investments) and
subordinated debt.
In 2022, we invested in UK-based Econic Technologies, which develops and licenses proprietary catalyst
technology that uses CO2 as a building block in manufacturing, reducing the carbon footprint of widely used
day-to-day products. In addition, a consortium-led investment supported Singapore-based insect protein
producer Nutrition Technologies to expand production, launch new products and create strategic
partnerships. Transforming agricultural waste streams into insect-based feed products and fertiliser enables
a more circular economy, while at the same time also helping reach emissions-reduction targets and
improve food security.
In April 2022, the Dutch National Growth Fund provided a subsidy of €50 million to Zero Emissions Services
(ZES), of which ING is a founding partner, to accelerate the introduction of docking stations, ship
modifications and battery containers (ZESpacks), all of which will contribute to the electrification of inland
vessels and a transition to net zero. ING has also become a shareholder in EIT InnoEnergy, the European
innovation engine for sustainable energy that supports start-ups and commercially attractive technologies,
and provides education. EIT InnoEnergy is supported by the European Institute of Innovation & Technology
(EIT), a body of the European Union.
The Sustainable Structured Finance team supports clients by functioning as a laboratory for new sustainable
technologies and business models in need of financing within the EMEA region. The team is involved in the
origination, structuring and execution of structured finance transactions, with an emphasis on the circular
economy, bio-chemicals, waste and water or any other project supporting sustainable development. The
team also provides financing solutions to smaller-scale renewable energy projects in the Netherlands, such
as ‘ZonnepanelenDelen’, a solar financing platform that offers non-recourse project finance of between
€200,000 and €5 million to solar power projects undertaken by SMEs and project developers.
We also led a consortium of Dutch financial institutions in the construction of technology company
Avantium’s FDCA factory in Delfzijl, the Netherlands. This will be the first commercial FDCA factory in the
world. FDCA is the key building block for the 100 percent plant-based, recyclable polymer PEF, a non-fossil-
fuel-based alternative for PET.
ESG Advisory
Besides financial support, we help clients navigate the rapidly changing regulatory landscape and advise on
their net-zero strategy. Clients benefit from our deep and broad experience built up over the years helping
other companies on ESG-related journeys. Some clients are ahead of the curve and for them we frequently
act as a sounding board, alongside our financing-related role. Other clients are at the early stages of their
sustainability journey. For them, we provide guidance based on our market experience and suggest areas

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> Sustainability at the heart
ING Bank Annual Report 2022 15
where they can make impact to become aligned with climate pathways and their peers. Through teaming
up with the relevant capital structuring and advisory departments, we also advise corporates on financing
ESG-related corporates’ CAPEX and M&A transactions (selling non-sustainable assets or buying sustainable
assets).
Green bond framework
To support the strong growth of our sustainable finance portfolio, and to meet green funding needs, ING
issues green bonds, supported by our green bond framework. The framework aligns with the International
Capital Market Association’s (ICMA) Green Bond Principles (GBP). We intend to allocate the proceeds of our
green bonds to an Eligible Green Loan Portfolio of new and existing loans including renewable energy
projects and green buildings. Other categories are clean transportation, pollution prevention and control,
and sustainable water management.
Under this framework, ING Bank and its subsidiaries can issue any debt security (such as senior bonds,
subordinated bonds, covered bonds, commercial papers and medium-term notes) to finance and refinance
assets and projects which contribute to the UN's Sustainable Development Goals and our own sustainability.
ING established its sustainable debt strategy via the publication of the framework. Since then, we have
continued to take steps to enhance our sustainable debt strategy and see it as an important tool in
supporting the growth of our own sustainable finance portfolio.
In alignment with the ICMA’s 2021 GBPs, the framework is presented through four pillars: use of proceeds,
process for project evaluation and selection, management of proceeds and reporting. The framework also
follows the recommendations of the Green Bond Principles regarding external review.
Product offerings for Retail and Business Banking customers
As a retail bank, we aim to help customers transition to a low-carbon environment. While we have provided
sustainability products and services in Retail Banking since 2017, we have since introduced many more
sustainable banking products across our markets, following a sustainable alternative products roadmap, to
facilitate this transition. It is our aim to have sustainable alternatives for our main retail products in all
markets by 2025.
In 2022, we adopted a net-zero scenario for the residential real-estate sector, replacing the beyond two-
degree Celsius scenario previously used. The new scenario is guided by the EU's Carbon Risk Real Estate
Monitor (CRREM) 1.5-degree Celsius scenario, a tool that enables the alignment of real estate portfolios
against decarbonisation pathways. We use this tool for the six markets in scope. Our scenario is also
directed by data for residential real estate derived from the International Energy Agency's global net-zero
scenarios. In the new scenario, houses in our portfolio across these markets need to reach an average
energy efficiency of 0.6 kg CO2/m2 by 2050, which is more ambitious than the previous 2.6 kg CO2/m2. By
2030, they need to reach an average energy efficiency of 19.7 kg CO2/m2. The scenario currently applies to
five of the six markets in scope: the Netherlands, Germany, Poland, Spain and Australia. Belgium is excluded
from the target until the issue of data comparability with other markets can be solved.
In support of this ambition, in 2022 we further rolled out sustainable mortgage products, which stimulate
more energy-efficient homes. Sustainable mortgages are part of our sustainable lending approach that we
consider EU Taxonomy-eligible. After being introduced in Poland in 2021, sustainable mortgages are now
also available in the Netherlands, Germany, Italy and Romania. We also offer sustainable consumer loans,
with discounts related to the purpose of the loan, in Belgium, Romania, Poland, Turkey and Luxembourg.
These loans can be used for housing, to improve the energy efficiency of homes, and for other activities
such as purchasing sustainable mobility options.
In addition to lending products, we continue to provide customers with a range of tools and platforms that
can support them in their renovation efforts. These include the homeQgo platform in the Netherlands, as
well as a renovation calculator tool that ING makes available to customers in Germany in partnership with
KfW bank. For more information on our sustainable housing approach, see our 2022 Climate Report on
ing.com.
In 2022, we also launched a carbon footprint calculator in our Dutch app that enables customers to view
spending-related CO2 emissions in their bank statements. The calculator is live for 500,000 customers. In the
Netherlands, Romania and Turkey, we also provide customers with renewable, recyclable or virtual bank
cards, which help lower the impact of our banking products on plastic waste.
We are also helping Business Banking customers make their businesses future-proof by offering sustainable
financing alternatives. We now offer sustainable finance alternatives (loans and/or lease) for SMEs and mid-
sized corporates in most of the countries where we operate. We aim to reach €1 billion new production of
sustainable financing annually in the Netherlands in 2025.
In 2022, we brought four new loans to market, bringing our total offering of loans supporting customers
with sustainable activities to nine. In Poland, a sustainability improvement loan was launched after a pilot in
the Netherlands. Similar to its Wholesale Banking counterpart, this type of loan incentivises business
customers to reduce their environmental impact by improving their sustainability scores and ratings and
reducing their CO2 emissions.
Sustainability loans were launched in both Romania and Turkey. In Romania, we implemented a framework
to identify and customise sustainable transactions for customers. As a result, ING in Romania granted its
first sustainable credit for entrepreneurs, financing renewable energy and circular economy projects. One of
the most notable examples is a sustainable loan granted to Promateris, manufacturers of sustainable
products and solutions for the circular economy, to develop extra production capacity. The new facilities will
produce biodegradable and compostable raw materials with applications in the packaging, food service and
waste management sectors.

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> Sustainability at the heart
ING Bank Annual Report 2022 16
Next to our financing alternatives, we also supported Business Banking customers with a range of tools to
support their sustainability journeys. In our real-estate financing business in Netherlands, we continued to
offer access to an ESG improvement platform.
Sustainable Finance Disclosure Regulation
As of 31 December 2022, the investment funds at ING following the disclosures according to Article 8 or 9 of
the Sustainable Finance Disclosure Regulation (SFDR) accounted for 51 percent of total client assets (assets
under management and/or custody) in funds distributed in EU markets. These funds were purchased by our
customers in the Netherlands, Belgium, Luxembourg, Germany, Spain, Romania, Poland and Italy.
ING is undertaking many efforts to create transparency and facilitate the transition of products using the
SFDR framework. For example, during 2022, ING Netherlands adapted a Discretionary Portfolio Management
(DPM) strategy to be in line with Article 8 disclosure requirements. With this adaption, all four standard DPM
strategies available in the Netherlands are in line with Article 8, representing DPM products promoting,
among other characteristics, environmental or social characteristics, or a combination of those. In addition,
in Belgium, we brought three of our ING flagship funds in line with Article 8.
We disclose the ratio of client assets in SFDR Article 8 and 9 funds of total client assets in funds, to provide
insights and transparency into our clients' portfolios. According to SFDR, Article 8 refers to a fund promoting,
among other characteristics, environmental or social characteristics, or a combination of those. Article 9,
according to SFDR, refers to funds with sustainable investment, or a reduction in carbon emissions, as its
objective. For funds managed by third party asset managers, we rely on information provided by them, with
no further review of the classification by ING.
Essentially, SFDR is a disclosure regulation and does not yet reflect a level of sustainability of funds.
Leveraging on extensive data points provided through SFDR as well as complementary analyses, ING
continues to develop methodologies to present customers with an even more insightful and transparent
view on their investments, while monitoring the regulatory developments including the supervisory
authorities’ guidance. Eventually, it is through collaboration with asset managers, distributors, regulators,
and investee companies that we can achieve a transparent market standard for our retail customers.
Sustainable investing services
ING is a signatory to the UN-backed Principles for Responsible Investment and as a provider of investor
services to our Retail Banking customers we are committed to incorporating environmental, social and
governance (ESG) issues into investment decisions, policies and processes that underpin these services.
We have been reporting on sustainable investing services (SIS) for a decade. Over the past two years, new
regulations and definitions of sustainable investing have been introduced, such as the EU Taxonomy and
the Sustainable Financial Disclosure Regulation (SFDR). For this year, the reported numbers continue to be
derived from our own internal ING methodology. Our SIS are provided based on a methodology that has
been developed by ING to assess different kinds of investment instruments, from company-level equity to
funds and portfolios, using a diverse set of ESG criteria.
During 2022, ING’s SIS applied to our biggest sustainable investment markets: the Netherlands, Belgium,
Luxembourg, and Germany, with total sustainable investments valued at €14.6 billion, down from €15.7
billion in 2021. The drop was influenced by the overall market performance of equities and bonds, which
decreased by 12 percent on average. Sustainable portfolios averaged a 15 percent decrease due to the
absence of high-performing sectors such as oil and defence. However, €1.6 billion was added to the value of
sustainable investments in 2022 as one of the four main investment strategies in the Netherlands took a
more sustainable approach.
Belgium narrowed its scope on sustainable investment services, excluding the exposure on sustainable
funds that are invested via funds of funds unless those assets represented over 85 percent of the funds of
funds portfolio. As a result, numbers for 2021 and 2020 were updated for 2021 from €19.2 billion to €15.7
billion, and for 2020 from €13.2 billion to €11.2 billion. Our services cover all asset classes including
dedicated portfolios, investment funds and structured products, available in brokerage, advisory and
discretionary management propositions. Read more about our sustainable investment services on ing.com.
For investment funds, we apply quantitative and qualitative screening. The quantitative screen is conducted
to understand the ESG profile of the asset and the fund manager. It covers nine ESG categories across
policies, selection methodology and governance. The qualitative screen consists of an interview with the
fund manager focused on their assessment and ESG approach. In a final step, we validate the fund’s
investments against our sustainable investing criteria. This approach applies to funds from active managers,
but also to structured products or index funds. We understand that the policies of external investment funds
will not fully align with the ING policy, preference is given to investment funds whose sustainability policy is
most in line with that of ING.
Within discretionary management propositions, we also perform a company-level analysis, which
integrates both positive and negative ESG screening. Positive screening is based on a company score that
incorporates the company's ESG risk management, the evolution of that risk and the management of
adverse impacts on society and the environment by the company. We invest only in companies that belong
to the top 70 percent in their sector, when it comes to ESG performance. Applying negative screening
means that we exclude companies with severe negative corporate conduct. We also exclude companies
whose revenues from products or services that have a negative environmental or societal impact are higher
than five percent (for production) or 10 percent (for distribution). Excluded companies operate in the
following sectors: alcohol, coal, controversial weapons, fur, gambling, non-conventional gas, oil, tobacco,

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> Sustainability at the heart
ING Bank Annual Report 2022 17
and weapons. We aim to follow this same screening process for international financial institutions and semi-
sovereigns.
Our sovereign-level analysis integrates several sustainability factors such as social issues, environmental
performance, corruption, endorsement of international treaties and the adverse impacts of these sovereigns
on environment and society. By combining best-in-class scores with minimum requirements, we define the
eligibility of a sovereign for our sustainable investment portfolios. More detailed information on the
screening process can be found on ing.com.
As regulations and market standards constantly evolve, ING is investigating various ways of categorising
and reporting on SIS and we are monitoring regulatory developments. We believe that transparency,
uniformity and collaboration are needed from all market participants, to create a meaningful reporting
standard for customers, which can easily be benchmarked against other investments.
Integration of the EU Taxonomy regulation
The European Commission introduced the EU Taxonomy in 2021 as part of the Green Deal strategy and the
Commission's action plan on financing sustainable growth. With six environmental objectives, the
Taxonomy aims to channel capital flows to support the transition, help generate sustainable and inclusive
growth and prevent greenwashing. In 2022, we started reporting within the EU Taxonomy framework over
the financial year of 2021. An update on the 2022 financial can be found under 'Environmental, social and
governance risk' in the 'Risk management' section of this report.
ING sees the EU Taxonomy as an opportunity to re-evaluate balance sheet assets and increase
transparency on environmentally sustainable products with the aim of reaching the Paris agreement’s
target of net zero by 2050. The strategic priority, 'Putting sustainability at the heart of what we do' further
emphasises our own sustainability ambitions and we strive to continuously integrate regulatory measures
with these ambitions. It is important to recognise that our own efforts such as the Terra approach and our
sustainable finance products and services differ in scope from the EU Taxonomy. We believe that both
approaches need to be harmonised in the future.
In 2022, we categorised our lending efforts to corporate clients in different product categories. Before
financing clients, we assess them on environmental and social risk criteria as defined by our own risk
appetite statement. Our work with specific clients is based on the opportunity to develop tailored
sustainable products with them, such as sustainability-linked loans with company-specific KPIs.
We continuously explore new ways to support clients in a sustainable way and align with the principles of
the Loan Market Association, the ICMA for green, social and sustainability-linked financial products and the
EU Taxonomy. We also proactively inform clients about aligning their business activities with the Taxonomy
and have started to incorporate published technical screening criteria into our loan assessment processes.
Collaboration
No one sector, much less one bank, has the ability to solve the world’s problems. We believe that an
inclusive approach is the only way we can make any meaningful positive impact. From climate to human
rights and financial health, we seek to increase our sustainability impact through partnerships and coalition-
building.
In 2022, alongside ongoing involvements with, for example, the 2 degree Investing Initiative, the UN-led
Collective Commitment to Climate Action and the Net-Zero Banking Alliance, we collaborated with peer
banks under the UNEP-FI Principles of Responsible Banking alliance, co-leading a working group that
developed a set of standard indicators for financial health and financial inclusion for banks.
Following this, we started piloting the application of some of these indicators in the Netherlands, Spain and
Romania. In the Netherlands, this included starting a context assessment and a baseline analysis on several
of the indicators. Through these pilots, we aim to improve our customer segmentation and targeting of
financial health actions. More information about our progress towards the PRB Commitment to Financial
Health and Inclusion can be found on ing.com.
Dutch collaborations in the area of financial health also continued with Queen Máxima's work as UN
ambassador for Inclusive Finance for Development, the debt prevention organisation Schuldhulproute, the
Financial Health Index and the National Coalition for Financial Health, launched in 2022.
This report is also aligned with requirements from UNEP's FI Principles for Responsible Banking (PRB). A self
assessment disclosure on PRB can be found in the technical appendix of this report. Selected sections of our
2022 PRB reporting and self-assessment have been assured by ERM CVS, an assurance provider, to a limited
level of assurance. Full details of the scope, activities, limitations and conclusions of ERM CVS’ assurance are
included in the Assurance Statement, at the end of the technical appendix.
Managing climate-related, environmental and social risk
Assessing and managing the risks associated with a transition to net zero is critical. As climate risk becomes
increasingly relevant, many banks are evaluating the potential negative impacts it could have on their
business. Both transition risk, which can arise from changes in policy, law, technology and the market, and
event-driven or longer-term physical risk, caused by events such as drought, flooding and extreme weather,
could impact the economy, clients and therefore our business. Even after implementing measures to help
mitigate the effects of climate change, physical risks could continue to occur since climate change is actual.
Therefore, these risks need to be well understood and managed. The way we do this, as well as an
explanation of the different risks involved, our performance and results, can be found in the 'Risk
management' section.

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> Sustainability at the heart
ING Bank Annual Report 2022 18
Environmental and Social Risk (ESR) policy framework
ING’s ESR policy framework helps us make informed choices about how, where and with who we do
business. In 2022, the ESR framework was updated to reflect several minor amendments following the last
comprehensive review cycle that took place in June 2021. The new release includes, among amendments to
restrictions in the tobacco value chain, additional clarity on some of the requirements for the ESR client
assessment process concerning specific group of companies. It also includes the required ESR due diligence
for public authority entities. As well as restrictions, the ESR policy also sets guiding principles for biodiversity
and human rights.
Biodiversity
According to the Intergovernmental Science Policy Platform on Biodiversity and Ecosystem Services (IPBES),
the rate of species extinction is accelerating with grave impacts on people around the world. IPBES
estimates that around one million animal and plant species are now threatened with extinction, many
within decades. If the rapid decline of biodiversity continues, the livelihood of many businesses is at stake.
The agricultural sector, for example, depends on healthy ecosystems, and the construction and
pharmaceutical sectors both need access to natural resources to prosper. This can have an impact for
banks.
Through our ESR policy framework, ING identifies and manages risks related to biodiversity loss. Our
processes focus on avoiding a negative impact on biodiversity, where possible, and minimising impact that
cannot be avoided. We also engage with clients to find and finance opportunities to do business in a way
that respects nature.
Also through the framework, we apply strict ethical and environmental criteria to financing decisions. We
don’t finance projects that directly impact high-value ecosystems, such as UNESCO heritage sites, Ramsar
wetland sites or areas designated for protection by the International Union for the Conservation of Nature
(IUCN I and II areas). In addition, our screening criteria include enhanced due diligence for transactions that
can impact rich biodiversity areas and ecosystems. In 2022, we expanded our due diligence to include ‘key
biodiversity areas’, which are host to critical populations of the world’s most threatened species.
To ensure employees understand the impact of biodiversity loss on business, we introduced two learning
modules in 2022. The first, an internal video explaining biodiversity loss, why it is relevant to customers and
to ING, what we are doing to protect biodiversity and how employees can help. It is part of a sustainability
learning offering, available to the entire company. The second module was co-developed with the
Biodiversity Working Group of the Dutch Sustainable Finance Platform, which is hosted by De Nederlandsche
Bank. The e-learning is available on the platform's website.
Reducing deforestation is a priority for protecting biodiversity and can make major contributions to climate
mitigation. We engage with clients around the world, active in cattle, palm oil, soy, wood, cocoa and coffee,
calling on them to put in place no-deforestation and no-ecosystem conversion policies and commitments
and to work towards full traceability in their supply chains.
To restore biodiversity globally, all stakeholders need to work together. That’s why ING is an active member
of external partnerships and initiatives. We work with peers and expert organisations to further develop the
TNFD framework, which we intend to use as guidance in future reporting. ING is also a member of the
finance workstream of the EU Business@Biodiversity platform, an EU-led initiative that aims to support
financial institutions in integrating biodiversity risks and opportunities.
ING is a signatory of the Equator Principles, a financial industry benchmark for determining, assessing and
managing environmental and social risk in projects. Projects financed under the Equator Principles
framework that have an impact on natural ecosystems, are expected to carefully manage that impact. We
have strict criteria in place to apply this framework, ensuring that biodiversity impact is not only avoided
and minimised where possible in these projects, but also restored.
Human rights
We believe every person, everywhere, has the right to be treated with dignity and have their interests
considered equally. ING and our clients have the potential to impact human rights through our operations
and business relationships. Our impact is on different levels: how we do business, and with who we do
business, not only as an employer but also through our supply chains.
We work to influence and support business partners to respect human rights in multiple ways. Our ESR
policy framework includes an overarching policy on human rights to guide us when assessing clients and
the transactions we finance. We also act on a variety of environmental, climate and social topics as well as
highlighting their interconnectivity. For example, our approach acknowledges that biodiversity loss
negatively impacts people's human rights, affecting their access to food, water, sanitation, culture,
property, a healthy environment and more.
In 2022, we published a Human Rights Review 2021/2022 where we disclosed our most severe human rights
issues in Retail Banking with an emphasis on individual customers (discrimination, financial distress and
privacy abuses). We also provided updates on the management of our most severe human rights issues in
our own operations (work-related stress and discrimination). We also developed a tool for analysing the
human rights impact within our portfolio. We are currently piloting this tool and looking into ways to
implement it as part of ING's existing processes.
We continue our human rights efforts in line with the UN Guiding Principles on Business and Human Rights
(UNGP) as well as the OECD Guidelines for Multinational Enterprises. We do this by understanding regional
and portfolio risks, engaging with clients, using financial leverage when needed, and being cognisant of

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> Sustainability at the heart
ING Bank Annual Report 2022 19
human rights impacts when engaging with stakeholders. We consulted with human rights and civil society
organisations in drawing up our ESR policy review.
Via platforms that set standards on this topic, ING aims to be transparent about our progress in the hope
that others will join us and strive to be a step ahead of broader expectations. Read more in ‘Environmental,
social and governance risk’ in ‘Risk management’. To understand the link between human rights and climate
change, a section of our climate report is dedicated to human rights. The transition to a green economy
may impact people. Transitioning out of fossil fuels may result in stranded assets and consequently affect
surrounding communities. It could also increase energy poverty for vulnerable people reliant on fossil fuels.
We recognise that as the world transitions from a carbon-intensive economy into a green economy, we
must collectively acknowledge the needs of people, especially the most vulnerable.
Financial health and inclusion
Part of ING’s purpose to empower people to stay a step ahead in life and in business means helping
customers and society stay a step ahead of the challenges they’re facing. One of the ways we can make a
difference here is by aiming to advance financial health and inclusion for customers and communities.
Financially healthy people can contribute to a healthy economy and help drive social progress. At the same
time, money is a leading cause of stress for people with half of European households struggling to make
ends meet. According to the group European Pensions, one-third are unable to face unexpected financial
expenses and close to 40 percent are not saving for retirement.
ING is committed to empowering customers and the community towards improved financial health, a state
in which an individual, household, micro, small or medium-sized enterprise can manage their current
financial obligations and have confidence in their financial future. This includes managing day-to-day
finances to meet short-term needs, the capacity to absorb financial shocks (resilience), the capacity to
reach future goals, and feeling secure and in control of finances (confidence).
According to a financial health working group convened by the UN Secretary-General’s Special Advocate for
Inclusive Finance for Development, having financial health as a business purpose contributes to happier,
more engaged customers with greater financial resilience, better management of day-to-day finances, an
enhanced ability to set future goals, and improved confidence, security and control of finances. ING is part
of this working group: the Special Advocate has showcased our approach as best practice.
Financial health can also be seen from a human rights perspective. Everyone has a basic right to be a full
member of the economy and live life in a financially dignified way. ING strives to make sure it does not
discriminate by giving customers different levels of essential information. We aim for our information to be
comprehensible and accessible for all.
Advancing customers' financial health and inclusion
ING has built a financial health framework consisting of three pillars. For each pillar, best practices are
shared between business units with the goal of learning from each other. Similar projects are running in
several countries but tailored to local circumstances. Examples include a project in Spain on the avoidance
of overdraft, which is now also running in Germany.
Other examples are campaigns in Germany, the Netherlands and Romania which aim to stimulate those
with hardly any savings to adopt a savings habit and, if possible, to build a savings buffer. Tracking each
project to measure effectiveness, we introduced 15 new financial health projects in Spain, Germany,
Romania, Turkey, Australia and the Netherlands in 2022, reaching two million customers.
Financial inclusion, the first pillar, is about everyone who meets the bank's criteria having access to banking
products and digital adoption, including those with seeing or hearing difficulties - what we refer to as
'leaving no one behind'. It also means that people have effective access to all types of financial products,
not just basic ones. To achieve this, we want to create equal opportunities and make sure products, services
and facilities are accessible to everyone and we want to engage people to effectively use them. Examples of
this include voice-activated ATMs in Poland, the Netherlands and Turkey, and a bank card with a notch so
the visually impaired can insert them correctly, in the Netherlands and Belgium. The card is also designed to
support customers with limited hand functionality. In Australia, we provide phone banking for customers
with speech or hearing impairments via the government’s National Relay Service. Sign language services are
available in some bank branches in Poland.
ING also started a programme to align digital channels in all EU Retail Banking countries with the EU’s Web
Content Accessibility Guidelines standard (WCAG 2.1). For example, in the Netherlands, the ‘MijnING’ app is
accessible with a voice-over to transfer money or to get current account insights. Examples of improving
digital inclusion include ING in Belgium partnering with Beego to help customers become digital by providing
‘digibuddies’ (computer science students) to assist them. And in Australia, more than 100,000 customers
over 55 have received information to improve their digital awareness and skills. Financial inclusion will be
included in the ING Compliance framework under the Client Protection Framework we are developing, as we
want to uphold the same standards across the globe.
The second pillar of our financial health framework is about making sure that people’s monthly expenses
don't exceed their income, and having healthy levels of debt and financial resilience. Everyday Round Up for
example encourages customers in Poland, Australia, Turkey, Germany, Spain and Romania to build savings.
We continue to partner with apps like Minna, which displays customer subscriptions in one place, and
Dealwise, a shopping platform that gathers cashback deals and discounts in one place.

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> Sustainability at the heart
ING Bank Annual Report 2022 20
In 2022, ING in Spain introduced Money Up!, which aims to provide financial peace of mind by giving
customers a clearer view of their income and expenses, with intuitive, customisable tools to improve their
finances and make better informed decisions.
Skyrocketing energy costs and inflation, partly stemming from the war in Ukraine, had a significant effect
on families across Europe and beyond. The cost-of-living crisis meant that many people struggled to pay
their bills. ING assisted impacted Dutch customers (and non-customers), via a campaign directing them to
www.geldfit.nl/energie to help manage their situation. In September 2022, more people were referred to
Geldfit than in the whole of 2020 and 2021 combined.
The third pillar of our financial health framework is helping customers with their financial planning. In
Germany, a personal budget tool is available for customers to plan and control expenses as well as discover
potential savings. In Belgium, Easy self-invest gives customers access to information from ING investment
experts and allows them to start investing with only small amounts of money.
Supporting financial health in the community
In 2022, the war in Ukraine resulted in months of escalating devastation and displacement for children and
their families. Not only were children among the many killed, wounded or deeply traumatised, but their
access to school, healthcare and other basic services was severely interrupted. In response to the crisis, ING,
together with colleagues and clients, donated more than €6.5 million to UNICEF's emergency response and
more than €7.5 million to local charities supporting people impacted by the war in Ukraine and in countries
receiving refugees.
Both the Covid-19 pandemic and the war in Ukraine exposed and deepened existing inequalities. As a result
of the war and soaring food and energy prices, the UN Development Programme noted that a staggering 71
million more people around the world experienced poverty in 2022. According to Ipsos research carried out
in December 2022, people not just in the EU, but globally, listed cost-of-living as their biggest concern.
Our approach to community investment adapts to these changing needs. Through a combination of global
and local funding, we support programmes that contribute to an inclusive economy, one where everyone
can participate. In 2022, ING, together with colleagues and clients, donated an additional €13 million to a
range of social programmes, €9 million of which was specifically focused on building financial health in
communities, covering the areas of future-proof employment, financial capabilities and social enterprises.
As examples of supporting employment, in 2022 the ING Netherlands Foundation partnered with Hack your
Future to train former refugees to become IT professionals and help them find jobs. It worked with Jong
Ondernemen to increase opportunities for students to enter employment, and Springplank, which was set
up to guide homeless people towards employment, housing, and financial capability. In Italy, we continued
to partner with Fondazione Mondo Digitale to provide training for around 6,000 people, especially women, in
digital and job-orientation skills. In Germany we partnered with MentorMe, a mentoring programme that
supports vulnerable women in the job market. Mentees are matched with ING mentors for one year. In
Belgium, we worked with the King Baudouin Foundation to fund projects that strengthen digital inclusion,
helping people develop digital skills and ensuring that digital products and services are accessible to all. ING
customers get involved by helping to choose which projects receive additional funding.
ING also initiated projects that assist with financial capabilities. In the Netherlands for example, the ING
Netherlands Foundation supported Money Start to provide education on debt prevention while the Youth
Perspective Fund helps young people to become debt-free. In Spain, together with Nantik Lum, we
supported the CREA Salud Financiera programme to improve the financial health of women that are, or are
at potential risk of, socio-economic exclusion. In Luxembourg, we worked with Jonk Entrepreneuren to
inspire and prepare young people aged nine to 25 for entrepreneurship and employment. Twelve
programmes provided hands-on learning in entrepreneurship, work readiness and financial literacy.
As examples of projects focused on social enterprise, in Romania, together with Impact Hub, we empower
charitable associations with entrepreneurial education and guidance to help them improve interventions,
generate alternative sources of funding and develop scalable solutions that increase their social impact.
Next to these examples, we also provided funding to projects in Australia, the Czech Republic, France, Poland
and the United States.
Empowering employees on sustainability
Putting sustainability at the heart of what we do means making sure employees are fully engaged on this
topic. We aim to give them the relevant knowledge, skills, and mindset to put sustainability into practice
both inside and outside the workplace.
In 2022, to further develop awareness around sustainability, we hosted global and national webinars and
townhalls addressing sustainability topics such as climate action, climate risk, human rights and
biodiversity. In the Netherlands, we held 'Let’s talk sustainability' events, where ING experts, partners and
employees came together to discuss relevant sustainability topics. In addition, a global sustainability
e-learning was made available to empower employees with sustainability-related knowledge and skills. It
included foundational and advanced learning modules. Some of these were developed specifically for ING,
while others were provided by partners. Additional learnings on climate risk and biodiversity were included,
in cooperation with the Dutch Banking Association (NVB). On an expert level, where employees required
further skills, we provided online and offline training on sustainable finance, as well as environmental and
social risk.

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> Sustainability at the heart
ING Bank Annual Report 2022 21
ESG governance
In March 2022, we updated our ESG governance approach, integrating and aligning ESG governance with
existing business-as-usual governance of the bank. This allows us to steer holistically across ESG on themes
like climate, biodiversity, human rights and financial health. As a result, ESG is now a regular topic on the
MBB agenda. Our global head of Sustainability reports directly to ING’s CEO. Sustainability/ESG leads in major
countries have a functional line to the global head of Sustainability to create a stronger connection between
global and local actions.
The ESG Committee, set up in 2022, assists the SB with matters relating to ESG, including, but not limited to,
the development and integration of ESG across the company and its strategy. The ESG Committee also
assists the SB by monitoring and advising on relevant ESG developments. In addition, we have created an
ESG Sounding Board comprised of senior leaders from across the organisation and including representatives
from Legal, Investor Relations and Corporate Strategy. The Sounding Board helps guide the development
and implementation of our strategy for ESG topics as well as monitoring and reporting on our progress. We
follow the recommendations of the Taskforce for Climate-related Financial Disclosure in our governance and
reporting. We believe this new approach increases our effectiveness, efficiency and accountability as we
strive to be a banking leader in building a sustainable future for customers, our company, society, and the
environment.
Taxation
Our taxation policies and performance are key elements under the governance pillar of our ESG framework.
We are mindful that every aspect of our business, including our approach to tax, has an impact on society.
We have therefore chosen to formalise our approach to clarify our views on responsible tax behaviour and
tax governance.
Our tax principles, which are applicable worldwide, mirror ING’s values of integrity, honesty, prudence and
responsibility. These values are the main drivers for our relationship with tax authorities and for the
adoption of tax transparency as standard practice.
As a global bank, we play a crucial role in fighting financial crime and protecting the financial system from
harmful behaviour. This includes criminal activities such as tax evasion, but also aggressive tax avoidance,
which although not illegal can be damaging to the communities in which we operate. We aim not to
facilitate such activities. We also believe in the principle that tax should follow business, so profits are
allocated to the countries where business value is created. It is our policy to comply with domestic and
international laws and regulations, taking account of both the letter and the spirit of the law, as well as
standards such as the OECD guidelines for multinational enterprises, and we apply the arm's length
principle.
Wherever we operate, we seek to establish and maintain an open and constructive dialogue with local tax
authorities and other government bodies, based on the disclosure of all relevant facts and circumstances. In
this dialogue we seek to provide clarity and establish certainty on all relevant local tax components in
advance. We are transparent about our approach to tax and our tax position. In formulating this approach,
we have taken account of the interests of our stakeholders, including (tax) authorities, non-governmental
organisations, customers, shareholders and society in general.
Disclosures are made in accordance with relevant domestic regulations, as well as applicable reporting
requirements and standards such as the International Financial Reporting Standards. Since 2015, each ING
annual report has contained a country-by-country overview of the result (before tax) and the total
corporate income tax charge per tax jurisdiction. ING also submits, annually, a similar type of overview to
tax authorities which enhances their insight into our tax position. In 2022, ING was ranked third in the
Association of Investors for Sustainable Development (VBDO’s) yearly Tax Transparency Benchmark.
It is our policy not to advise clients on taxation matters. Clients remain responsible for their own tax position.
ING joined the Dutch Tax Governance Code developed by the Confederation of Netherlands Industry and
Employers (known as VNO-NCW). ING embraces the principles of the code and will work consciously to
comply with the targets set, as laid out in our Tax Governance Code. This is available on ing.com in the
Compliance section under About Us. The financial information in the Tax Governance Code is recorded under
notes to the consolidated financial statements in this annual report (see note 32, Information on
geographical areas and note 34).
Tax policies, procedures and a tax control framework have been implemented to support management in
mitigating potential tax risks in a prudent manner. Internal monitoring, control and reporting of tax-related
risks takes place on a continuous basis with annual reporting to the board and various other stakeholders.
For SOx 404 purposes (section 404 of the Sarbanes-Oxley Act), an ‘effectiveness of internal control
statement’ with respect to tax controls has been provided. Tax risk management is subject to Corporate
Audit testing and evaluation. As part of the tax risk assessment, if applicable, the potential use of (tax)
incentives and/or subsidies is considered acceptable to the extent explicitly intended by the authorities.
In all countries in which ING is present, it is ING’s position to be cooperatively tax compliant. This implies
being transparent about, and disclosing, relevant tax risks towards tax authorities. Tax risks not only refer to
ING’s own tax position, but also our role as gatekeeper for the financial system as well risks in relation to our
customers. In this respect, we have integrated a tax integrity assessment in our overall customer risk
assessment process.

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> Sustainability at the heart
ING Bank Annual Report 2022 22
How we are making the difference
ING is making the difference by concentrating on two overarching
strategic priorities: giving customers a superior experience and putting
sustainability at the heart of what we do. To put these into practice,
and to make that difference for all customers, we have defined four
enablers: providing seamless digital services, using scalable technology
and operations, staying safe and secure, and unlocking our people's
full potential.

1 For details regarding the measurement of this KPI, we refer to paragraph "Digital access" on page 25
2 Weighted average availability during prime time (6:30 - 01:00); based on number of primary customers per country for channels: Internet banking Private
Individual, Internet Business Banking and Mobile Banking App.
3 and 4 Average availability 24x7, measured frequently per hour, excluding planned changes.
Providing seamless digital services
In a world where accelerating digitalisation is one of the main global trends impacting banking, customers
are spending more and more time online. That's why we want to make their lives easier by giving them a
seamless digital service. Putting the customer at the centre remains our core strategy.
Customers deserve a personal, easy, relevant and instant experience at every touchpoint, from the way we
communicate and onboard them to how we provide products and handle customer requests. ING facilitates
this by developing, maintaining and enhancing personalised, reliable digital services that are available 24/7.
Developing, maintaining and enhancing these basics provides the foundation for providing a superior
customer experience, and in turn this will help us achieve our ambition of becoming the number-one bank
for NPS in all ING countries.
Our emphasis continues to be on mobile and we are further improving our mobile capabilities. In 2022, 71
percent of our communication was personalised. As well as helping customers to make more informed
financial decisions, personalising customer interactions helps boost mobile sales. In 2022, 58 percent of
customers only engaged with us via mobile apps, up from 51 percent in 2021.
We use data analytics and machine learning to personalise digital services for customers. Given the
importance of data for offering personal and relevant services, data security and privacy protection are
crucial.
By digitalising key customer journeys we are enabling a superior customer experience at a reduced cost-to-
serve, while measuring impact through NPS and cost efficiency. In 2022, our Digi Index Score was 64
percent, a figure that reflects the average of straight through processing (STP) rates of key customer
journeys i.e. those that are handled without manual intervention. By 2025, we aim to reach a Digi Index
Score of over 75 percent.
Data analytics
We use advanced analytics and machine learning to extract insights from data to personalise customer
experiences, making the difference for both customers and colleagues. Our ambition as part of our strategy
of seamless, digital/scalable operations is to increase our STP rate to facilitate a smoother customer
experience. Call reduction and further digitalisation of our processes are a part of this. We have further
invested in our chatbot, callbot and virtual assistant capabilities and now have active chatbots in Belgium,
Italy, the Netherlands, Poland, Spain and Turkey, deflecting up to 40 percent of incoming chat volume
automatically. Guided by chat and callbots, customers can now learn how to resolve issues themselves
using the ING mobile app. Other benefits for customers include less waiting time if they want to speak to an
agent because more chats and calls are handled through digital solutions, and it is easier for them to find
quick answers to simple questions, even outside regular business hours. ING uses machine learning

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> How we are making the difference
ING Bank Annual Report 2022 23
techniques to understand a customer's intent and thereby make it possible to respond in a more personal
way to the customer request.
Analytics is also used to help create a safe and secure environment within the bank. Analytics has
contributed to a bank-wide anti-fraud programme, supporting the reduction of fraud damage for both
customers and ING. This was realised through machine learning models for certain fraud 'modus operandi'.
We also use our AI insights and expertise to fight financial and economic crime. Our advanced AI model
allows us to detect financial and economic crime better and earlier.
In addition, ING is a partner of the Kickstart AI initiative in the Netherlands, which aims to solve real business
problems with the use of AI. This year, we joined other member companies in tackling the food waste
challenge and improving the demand forecasting model at Delhaize Belgium that helps balance product
availability and waste.
Scalable technology and operations
Reflecting our role as a digital first bank and to enable a superior customer experience, ING believes that
scalable technology and operations are the foundation for becoming a successful digital bank and therefore
have made this an integral part of our strategy. Standardisation and automation give us a shorter time to
market, quicker time to volume, consistently high quality and improved productivity. Scalable technology
and operations also help 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. By creating
foundational and scalable capabilities and services, we allow the business to grow at marginal costs.
Scalable technology
Our scalable technology strategy provides a foundation for the modular components we use to build and
operate propositions. It allows ING countries to introduce propositions more quickly and easily, while
providing the opportunity to add local flavour.
The technology is divided into three parts: ING's private cloud infrastructure (IPC), our engineering pipeline
(OnePipeline) and our banking technology platform, with its extendable and reusable services and
components. Given its flexibility and scalability, ING has chosen for a hybrid cloud strategy, i.e. using public
cloud providers in addition to IPC. Cloud computing is an important component for scaling our digital
capabilities. IPC is where we store and manage applications and data such as channel applications, core
bank systems and other banking applications. We measure IPC adoption by the percentage of physical
cores in IPC compared to the total number of physical cores in data centres globally. By the end of 2022, we
ran 52 percent of our workloads on (private) cloud. By 2025, we expect that figure to have risen to at least
70 percent.
OnePipeline, our continuous integration and delivery pipeline, provides engineers with a consistent and
secure global capability to develop, test and deploy software. We invest heavily in infrastructure, test and
risk automation. Today, about 48 percent of applications are maintained through the pipeline. We measure
the pipeline's adoption by the numbers of applications onboarded to the pipeline (used to develop and
deploy to production), compared to the total number of applications registered in our IT management
platform across all ING entities. We exclude those applications where a pipeline is not applicable, such as no-
code or SaaS applications. Our ambition is to have 90 percent of applications on OnePipeline by 2025.
Touchpoint is part of our banking technology platform. In 2022, approximately 60 percent of customer
logins used Touchpoint. By 2025, we expect that figure to be over 90 percent. By using common
architecture and shared services, engineers can create propositions without the ‘heavy lifting’. Touchpoint
provides modularity and a set of reusable shared services, freeing up capacity for engineers to create more
value for customers and employees. We measure customer online traffic on the platform through the
consumption of Touchpoint authentication services, represented by the number of Touchpoint-enabled
unique customer authentications against the total number of unique customer authentications (Retail
countries/Wholesale Bank).
Payment & Settlement Services
In 2022, as part of our strategy, we have bundled our strategic payments and settlement services (PSS) into
a new unit under CTO (Chief Technology Office). This unit covers the full scope of payment and settlement
services for Retail and Wholesale Banking and benefit from our scalable tech and ops. It provides high
quality and efficient payment, settlement, and open banking services, leveraging our scalable payment and
settlement solutions.
Through an increased focus on these payment and settlement services, we allow our business to provide a
superior customer experience. We aim to further consolidate most of our payment services on this platform,
improving quality and reducing price per transaction. As of 2022, PSS processed well over three billion
transaction (65 percent of total volume) through our central payment engines.
Scalable operations
Our scalable operations are driven by digitalisation and capability hubs. These focus on becoming fully STP,
leveraging expertise and using scale and sharing productive, quality services across the ING network.
Capability hubs provide shared solutions to ING Bank worldwide. The hubs are mainly located in the
Netherlands, Poland, Romania, Slovakia and the Philippines. In 2022, 32 percent of operations were carried
out with the support of these hubs, compared to 23 percent in 2021. Our aim for 2025, is to have at least 50
percent of operational work carried out by the hubs.

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> How we are making the difference
ING Bank Annual Report 2022 24
By digitalising client contacts, accelerating remote advice and increasing the use of chatbots, inbound calls
to contact centres were reduced by 12 percent in 2022. We aim for 30 percent in 2025, which we expect will
represent an annual gross cost saving of around €50 million. Similarly, by automating and centralising our
KYC activities this year, we reached 49 percent of know your customer ( KYC) in our hubs and expect to
increase that to 60 percent by 2025 through more consolidation, automation and straight-through
processing.
Staying safe and secure
Trust is the starting point, the most basic requirement, for all stakeholders. That’s especially true for a
digital-first bank like ING. People trust us with their money and with their data. Keeping it safe, and
maintaining this trust is crucial (see also 'Risk management').
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. In Retail Banking in 2022, our digital channel availability for the Netherlands and Belgium was
99.38%. For Wholesale Banking clients worldwide, the availability for our Inside Business payments channel
was 99.97%, and for our Inside Business Connect channel (file transfer) the availability was 99.99%. These
figures are based on outputs of availability monitoring processes, which are run with a high frequency per
hour. The 2022 results are in line with the 2021 channel availability results.
Anti-money laundering and KYC
Knowing who we do business with helps to protect our clients, ING and the financial system against financial
economic crimes. As part of our continuing anti-money laundering (AML) efforts, we carry out customer
due-diligence checks and monitoring transactions for unusual or suspicious activities. We also assess the
projects and companies we finance for environmental and social risks and aim to steer clear of activities in
certain sectors or industries that could be harmful to people or the environment. In 2022, we strengthened
our KYC with, for example, increased staff, upscaled skills and additional local requirements where needed.
Read more about KYC and AML in 'Compliance risk' in 'Risk management'.
Cyberthreat landscape
As a gatekeeper to the financial system, we have an important role in protecting society against crime.
Cybercrime remains a continuous threat to companies in general and to financial institutions in particular.
Ransomware is still one of the prime threats, with phishing the most common way that attackers gain
access to a company’s system or network. Other high-ranking threats are attacks against availability, or
Distributed Denial of Service (DDoS) attacks. However, the geopolitical situation resulted in increased
awareness of cybersecurity threats, resulting in more attention for the global cybersecurity domain. While
we still observe an increase in the number of threats, we also see a wider range of ways that attackers
infiltrate company systems, such as exploiting unresolved vulnerabilities, notably 'zero-day exploits', i.e.
vulnerabilities that are exploited before a patch is available.
Cybersecurity incidents
During 2022, one attack impacted our availability of digital services in Germany. Channels were unavailable
for less than two hours. No other cybersecurity incidents were identified in 2022 that resulted in significant
operational downtime, data theft or financial loss.
Different types of cyberthreats are not only relevant for the financial industry, but are increasingly hitting
their supply chains. ING continues to invest in cybersecurity capabilities in all domains (prevention,
detection, response and recovery).
Preventative measures
Being cybercrime resilient is a high priority. We continuously test our IT and organisational resilience, and
perform crisis management and red-team exercises to improve our response to DDoS and targeted attacks.
Cybersecurity risks from supplier’s monitored and mitigation is initiated where needed. ING maintains a
strong global cybercrime alliance within the financial industry and government institutions to monitor
trends.
ING recognises the value of an effective regulatory framework and is in favour of cybersecurity being led
more by actual cyberthreats and principles and less by prescriptive rule-based compliance. The adoption of
threat-led penetration testing in the EU’s new Digital Operational Resilience Act, which also ensures
continuity of business, is a good example. Testing critical systems on real-life threats helps entities to gain
insights. Our staff awareness and training programme is regularly updated with the latest cybercrime
trends and prevention measures.
We have a responsible disclosure procedure for security researchers that may find issues in our business
applications or infrastructure.

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> How we are making the difference
ING Bank Annual Report 2022 25
Identity and access management (IAM)
Identity and access management (IAM) is an important element in our control framework to prevent and
mitigate the risk of unauthorised access to IT systems and the data processed and stored therein. ING has
IAM global processes and controls in place which are periodically reviewed and tested. For more information
go to 'Non-financial risk section' in 'Risk management'.
Fraud landscape
Types of fraud are also evolving. As the digital world continuously changes, fraudsters have become more
international and their modus operandi more complex. Customers are being deceived in increasingly
sophisticated ways. Online fraud has become a societal problem and in several countries banks have
collaborated with governments, law enforcement entities and other sectors to find innovative ways to
prevent and detect fraud. ING has an important role to play in preventing and detecting fraud in the digital
world and wants to minimise the impact of fraud losses and the number of fraud victims.
We recognise this transformation in the fraud landscape with developments high on our agenda. We
changed our fraud programme to improve its ability to monitor and react to fraud incidents and to adapt
quickly to new fraud methods in a cost-efficient organisation. The global head of Fraud now reports directly
to the global COO, and we have implemented a global delivery organisation (tribe) that brings detection and
response services to all countries. This tribe uses several sources of information, and is able to assess
whether a payment is done by a customer or by a fraudster. Also, we appointed a global head of fraud
investigations and introduced innovative ways to share best practices across domains and countries.
Over 2022, we experienced an increase in the number of fraud incidents, but were able to respond quickly
and adequately, resulting in a reduction of fraud losses compared to last year. The main modus operandi
continues to be the phishing of customer credentials and fraudulent credit card transactions. We also see
that authorised push payment fraud (e.g. impersonation of a bank employee) has become an important
category to focus on. We are increasingly collaborating with peers and other relevant sectors, such as
telecoms companies. More information can be found in the Risk management chapter.
Data privacy, protection and ethics
Customers trust us with confidential information and their personal data. It’s important that we maintain
that trust and keep their data safe from loss or misuse. In an environment that’s increasingly open and
connected, we must be ever more vigilant. ING is bound by global and local data protection laws, which can
differ from country to country. We are transparent about what we do with the personal data of customers,
employees, suppliers and business partners.
Our approach can be summarised as ‘the right people use the right data for the right purpose’. In line with
the EU’s general data protection regulation (GDPR), we aim to only process personal data to support our
business and in line with applicable legislation. Data controllers or processors who want to transfer personal
data outside of the European Economic Area (EEA) must ensure that the data subject is granted a level of
protection equivalent to that guaranteed by GDPR. More information can be found in the Privacy Statement
on our website.
In 2021, following the Schrems II ruling by the EU's Court of Justice in 2020 on the lawfulness of Privacy
Shield, the EU-US personal data transfer mechanism, ING launched its own transfer impact assessment with
necessary updates made to standard contractual clauses: contracts in scope were completed by the end of
2022. Financial institutions need to walk the fine line between privacy protection and fostering data sharing.
Again, countries differ in their approach. At EU level, there is a clear regulatory trend towards more data
portability and more data sharing. Under the Digital Markets Act, Big Tech will be required to facilitate data
portability and we expect a future proposal to establish PSD2-like data portability for finance.
In addition to complying with regulatory requirements around data use, ING assesses potential ethical
questions, taking into account the rights and interests of our stakeholders, to verify whether we use data in
a responsible way. Global and local data ethics councils guide our ethical decision-making and help to apply
data ethics consistently.
As ethical standards can evolve over time, we closely monitor regulatory compliance, societal developments
and potential new requirements to gain an ‘outside-in’ view on data ethics. We have assessed the impact of
the EU's upcoming artificial intelligence legislation related to ethics and established an appropriate
implementation plan. Everything we do is guided by ING’s Orange Code, which describes the values and
behaviours that underpin our way of working, and which puts integrity above all. Read more in 'Compliance
risk', in the Risk management chapter. Building on the Orange Code is ING’s Global Code of Conduct. We
encourage employees to speak up when they are confronted with unethical or illegal behaviour and provide
a variety of reporting channels, including via their manager, local compliance officer or an ING whistleblower
reporting officer. ING also has external and anonymous whistleblower channels. We take great care to
protect the identity of whistleblowers and the confidentiality of their reports to protect them against
potential retaliation. We believe that trust, integrity and ethical behaviour are at the core of any reliable
business. They go hand in hand with satisfied customers.

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> How we are making the difference
ING Bank Annual Report 2022 26
Unlocking our people's full potential
Ultimately, we are making the difference through the activities and actions of our people. We seek to
attract, develop and retain the best people by creating an environment where they can unlock their full
potential. ING's sustained success is founded on the continued commitment of our talented people. We
unlock our people's full potential by ensuring all employees have skills and capabilities that equip them for
the future, by promoting a diverse, inclusive and vitalised culture, where everyone feels they belong, and by
providing an excellent employee experience.
In the past few years, our people have faced unprecedented challenges during the global pandemic. It has
fundamentally changed the way people view their lives and has shifted employee expectations significantly.
The hybrid way of working has worked well for ING. The pandemic allowed us to accelerate our
digitalisation, we collectively pulled together and employees continued to deliver for our customers.
We continue to support our people by offering hybrid working to make sure they have the autonomy to
better balance their professional and personal lives. Eighty-five percent of our people strongly endorse
hybrid working.
We care about giving our people this flexibility, especially since the changing dynamics following the
pandemic has led to a change in employee expectations. It is important that our people feel supported and
that, as well as a competitive total reward package, they receive good development opportunities and
autonomy. This is reflected in our people offer, which is intended to create clarity on what we offer, and
what we ask in return.
It matters to us that our people are engaged and that we have an open dialogue with them. We use a
continuous listening approach, our Organisational Health Index (OHI), to get an ongoing sense of how our
people are doing and how they feel and we make sure we act on that feedback. A full OHI was held in
October, with a record number of participants: over 41,000 people, or 69% of our total workforce. On a
global level, more colleagues indicated that they had clarity on our strategy, shared ING's vision and felt
included in decision-making. Risk management remained one of our strongest practices and saw further
improvement since 2021. We will use the outcomes of this survey to define action plans and priorities for
2023.
As well as making sure our people are engaged, we aim to unlock our people’s full potential by focusing on
three elements: 'skills and learning', 'diversity, inclusion and vitality', and 'employee experience'.
Skills and learning
We want to attract, develop and retain the skills we need to deliver great performance. In 2022, we provided
new tools to upskill and reskill our people, built the capabilities of our leaders and developed the pipeline of
leaders for the future.
Upskilling our workforce
We want to equip our people to grow, upskill and reskill themselves, so that both our people and our
business have the capabilities that are needed now and in the future. Together with an external partner, we
launched a programme to boost learning content to 30 ING countries and the four ING Hubs (Philippines,
Poland, Romania, Slovakia). It offers a wide range of learning courses in My Learning – ING’s open, digital
learning platform that gives employees access to our complete learning offering in one location.
ING wants to be an organisation where learning and development play a major role and where our people
feel supported in developing themselves. This is part of our culture. Development increased by 13%, with
1,317,760 courses completed and 1,509,938 learning hours undertaken. Over 44% of all learning completed
was not mandatory, with more people than ever electing to learn new skills and build capabilities relevant to
their job roles and functions.
At ING, we care about everyone being able to unlock their full potential and want to make sure all our
people can access learning and development. We made learning solutions more accessible by
implementing new guidelines for all required learning. We seek to provide digital services and workplace
tools that promote disability inclusion and meet accessibility requirements set out in the Web Content
Accessibility Guidelines (WCAG) 2.1. The WCAG is now our reference standard for all mandatory learning. We
continued to embed this further into all content created for ING.
Building leaders for the future
To have strong leaders and an equally strong pipeline, we completed our annual succession review of the
top 400 roles in the bank. We launched a new programme to accelerate leaders' readiness for bigger, global
roles. Fifty-four percent of the talented participants in this programme were women and 10 countries were
represented. We continued to build our internal talent pipeline through our early careers approach. We
hired 81 trainees under our International Talent Programme under eight tracks: WB, Retail Banking, IT,
Finance, Risk, HR, Operations & Change and Analytics.
We continued to strengthen our leadership offering through our Leadership Experience, which aims to
develop greater leaders and better managers who can engage and grow talent and enhance team
performance, and the Leadership Fundamentals programme, which aims to develop the foundational skills
managers need to help themselves and their teams to be successful. Some 840 managers joined the

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> How we are making the difference
ING Bank Annual Report 2022 27
Leadership Experience and over 390 colleagues from 25 countries participated in the fully digital
programme of our Leadership Fundamentals.
Diversity, inclusion and vitality
ING is committed to attracting, developing and retaining a workforce that reflects the customers and
communities we serve. We believe that a diverse, inclusive and thriving culture makes people want to join
and stay, and helps create an atmosphere where people can speak up, making us safer and more secure as
a bank.
We introduced a 70% principle in 2018, which means we strive for no group or level to be comprised of more
than 70% of the same gender, nationality or age group.
In addition to the broader benefits of a more gender-diverse senior management team - for our business,
employees and customers - increasing representation of women in senior management is foundational to
addressing our gender pay gap (i.e. the difference between the average remuneration of men and women),
something ING committed itself to in 2022.
We deepened our focus on gender diversity by introducing a new target of at least 30% female
representation in our senior management by 2025 and 35% in 2028. In 2022, that figure was 29%. The
variable pay of our MBB is linked to delivery of these internal targets on gender diversity. We also defined
'senior management' consistently, in line with our Global Job Architecture (GJA, ING's global job catalogue).
To make sustainable improvements in gender diversity in senior management, we are changing how we
hire, progress and retain talented women, with a bank-wide action plan introduced in 2022. For instance, by
the end of 2022, we put a requirement in place with external recruitment firms to provide gender diverse
candidate lists. We also use a structured and objective hiring process and aim to ensure our talent
identification, succession, performance and reward processes are equitable and mitigate the risk of gender
bias. We also created a more gender-inclusive and family-friendly workplace. We promote support for
parental leave and flexible working to make sure all parents have the chance to be successful professionally
while managing their family lives. The pandemic has showed us that our people continued to deliver for our
customers and that flexible working enhances the lives of employees – especially those with care-giving
responsibilities – and this matters to us. This is why we remain an advocate of hybrid working and give our
people that flexibility.
To build a strong internal pipeline of talented women into leadership roles, we support and nurture top
talent. We introduced a new leadership acceleration programme, with a 54 (female)/46 (male) percent
gender split in the participant group and content that addresses gender-specific barriers to progression. We
monitor the gender balance in our succession pipelines. We also extended targets to increase gender
representation from our current top senior management roles to the leadership pipeline below. To
understand women’s experiences of ING, we launched a new, globally consistent exit survey, which will be
analysed by gender, to identify the reasons for leaving and to make sure we take action to prevent
regrettable loss of female talent.
To understand the experiences of all our employees, we use the OHI survey and psychological safety index.
We identify different experiences based on gender and other organisational and personal demographics
and then delve deeper to determine further actions. One of the ways we create a more equal and inclusive
workplace is through external and independent review. ING is one of the 418 firms recognised in the 2022
Bloomberg Gender Equality Index (GEI). The Index offers public companies the opportunity to disclose
information on how they promote gender equality across five separate areas: female leadership and talent
pipeline, equal pay and gender pay parity, inclusive culture, sexual harassment policies, and pro-women
brand. In 2022, ING scored 70.35%, a small improvement on the 70.26% score from 2021. This is the seventh
year we have been included in the listing with feedback guiding our future actions.
In addition to our action on gender diversity, 32 thriving employee networks help us advance our diversity
and inclusion efforts. These networks raise awareness and create connection, focusing on gender, LGBTIQ+,
race and ethnicity, cultural diversity, accessibility and age. To celebrate the diversity of our global workforce,
we held our fourth consecutive Global D&I Day, with 26 countries participating in over 120 events.
ING is a founding partner of Workplace Pride, dedicated to improving the lives of lesbian, gay, bisexual,
transgender, intersex, and queer (LGBTIQ+) people in workplaces worldwide. Its activities include the
Workplace Pride Global Benchmark. In 2022, ING scored 78.8% and was recognised as a Workplace Pride
Ambassador.
Vitality
We care about our people. We seek to encourage and support healthy and effective working, so they can
deliver on ING’s strategic priorities and thrive in life. Our approach to this has developed since the pandemic
as our way of working has evolved.
We seek to we embed vitality in our working culture and promote healthy working habits. We offer
employee assistance programmes, toolkits for managers and employees, and various locally tailored
programmes to support the physical and mental vitality of our people. We also promote learning content on
vitality topics on our My Learning platform. To reinforce this priority, we have also created a new leadership
position. Our global head of Vitality works across our bank-wide network to enhance the vitality and
resilience of our people.
Many vitality initiatives are locally driven and specifically tailored to local needs. For instance, the My vitality
platform, launched in the Netherlands, Belgium and Luxembourg in 2020. It inspires and supports over 7,500

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> How we are making the difference
ING Bank Annual Report 2022 28
registered users with high-impact programmes on physical, mental, emotional energy and purpose. In total,
My vitality users registered over 4.8 million km via smart devices in walking, running, cycling, swimming and
any other way to move forward.
In Germany, Turkey, the UK and the US, local initiatives were introduced including workshops on physical
and mental vitality, sport events and health check-ups.
The situation in Ukraine required support for many colleagues, especially those in Eastern European
countries. Since the war started, ING has organised fundraising, arranged support for employees and offered
assistance programmes to employees and their families. Additionally, employees in the countries
neighbouring Ukraine voluntarily hosted colleagues and their family members.
Employee experience
Providing a superior customer experience is a strategic priority. This matters just as much for employees
and we are therefore focused on continuing to improve our employee experience. We aim to provide
personal, easy, and efficient services that encourage our people to unlock their full potential and be the best
they can be. In 2022, we continued to digitalise our people services with a new virtual assistant (available for
employees 24/7 in the Netherlands, Poland hubs and Manila hubs) and the introduction of our HR system
Workday to 60% of all employees. We also continued to review and improve critical moments in the
employee journey such as onboarding and international assignments. We started to focus on high-volume
services such as expense reimbursements, job changes and people recruitment, which are major
contributors to a superior employee experience. Finally, we continued to safely manage our HR operations
to protect employee data and keep people processes compliant.

Contents |  | Introduction |  | Strategy and performance |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> How we are making the difference
ING Bank Annual Report 2022 29
Our performance
Financial developments
In 2022, ING Bank performed well, despite challenging operating conditions which had a far-reaching impact
on people’s lives, on societies and on economies, causing energy and price shocks and driving up inflation
and interest rates. ING Bank’s net result declined to €3,667 million from €4,770 million in 2021, fully due to
higher net additions to loan loss provisions, which had been at a very low level in 2021. The effective tax rate
in 2022 was 31.4%, up from 27.7% in 2021. The higher effective tax rate was caused by the impact of the
following non-deductible items for corporate income tax purposes in 2022: hyperinflation accounting loss in
Turkey, impairments on TTB and interest expenses in various countries.
Income was supported by a growing primary customer base and an increase in lending and deposits. Our
global retail customer base (excluding France, after the announced exit from the retail market) remained
flat at 37.2 million, but even more customers chose ING as their primary bank. In 2022, we gained 585,000
primary customers, bringing the total number to 14.6 million, which was 4% higher than at year-end 2021
(excluding France). Net core lending growth (adjusted for currency impacts and excluding Treasury and the
run-off portfolios) was €18.2 billion in 2022, and net core deposits growth was €25.1 billion.
In our P&L, we saw the benefits of the rising rate environment, which boosted net interest income. This was
on top of the structurally higher fee base, resulting from our efforts to diversify income. All these positive
developments were largely offset, however, by several exceptional income items in 2022 (including the
impact of Turkey hyperinflation, a mortgage moratorium in Poland and the unwinding of a deposits hedge
in Belgium and our TLTRO-related derivative position), resulting in an income growth of 0.3% to €18,546
million.
Net interest income rose 1.0% to €13,745 million. The increase was driven by higher margins on liabilities,
following the return of positive interest rates in 2022. This was only partly offset by lower margins on
mortgages and other lending, as client rates generally track the higher cost of funds with a delay and
prepayments on mortgages declined. After ECB’s decision to change the conditions for the TLTRO
programme, we had to unwind our TLTRO-related derivative position. Combined with the remaining TLTRO
benefit until 23 November 2022, this led to a net TLTRO impact of €-87 million compared to a net benefit of
€483 million in 2021. Net interest income in 2022 also included a €-343 million impact from new regulation
in Poland for mortgages. ING Bank’s full year net interest margin declined to 1.34% from 1.39% in 2021.
Excluding TLTRO in both years and the impact of the Polish moratorium, the net interest margin showed an
increase of 4 basis points year-on-year.
Net fee and commission income rose 2.0% to €3,586 million. Fee income for daily banking products strongly
increased, reflecting growth in primary customers, an increase in payment package fees and new service
fees. Lending fees also increased, driven by lending growth in Wholesale Banking. This was partly offset by
lower fees from investment products and from Global Capital Markets, reflecting adverse market conditions.
Total investment and other income decreased to €1,215 million in 2022 from €1,354 million in 2021. This
included the largest part of the impact of Turkey hyperinflation, €-288 million to unwind a macro fair value
hedge of deposits in Belgium (of which €-247 million in Retail Banking and €-41 million in Wholesale
Banking) and €165 million of impairments on our stake in TTB, while 2021 had included a €72 million
recognition of a receivable recorded in Corporate Line. Other income in 2022 was supported by a €125
million gain from the transfer of our investment business in France, a €67 million gain from a legacy entity
in Belgium and income from the sale of a non-performing loan portfolio in Spain.
Operating expenses decreased by €2 million to €11,193 million. Expenses in 2022 included €1,250 million of
regulatory costs, slightly lower than in the previous year. Expenses in 2022 furthermore included €325
million of incidental items, largely related to restructuring provisions and impairments and also including
€75 million for adding the interest-on-interest effect to the compensation for customers on certain Dutch
consumer credit products. Incidental items in 2021 had amounted to €522 million, mainly reflecting a €180
million provision for the compensation to Dutch customers with certain consumer credit products and
redundancy provisions and impairments related to the announced exit of the retail banking markets in
France and the Czech Republic. Excluding regulatory costs and incidental items, expenses were up 2.2%,
impacted by high inflation, which was mainly visible in staff costs. This was partly offset by continued cost-
efficiency measures and earlier actions taken to change the footprint. The cost/income ratio was 60.4%
versus 60.6% in 2021.
Net additions to loan loss provisions increased to €1,861 million, or 29 basis points of average customer
lending, compared with only €516 million, or 8 basis points, in 2021. Risk costs in 2022 were heavily
impacted by the Russian invasion in Ukraine, which led to a net addition of €533 million on our Russia-
related exposure. The remainder was mainly due to an increase in Stage 3 individual risk costs, particularly
in Wholesale Banking, and new overlays to reflect the risks from secondary impacts, such as an increase in
energy prices, higher interest rates and inflation, as well as supply chain disruptions.
The return on IFRS-EU equity of ING Bank decreased to 8.2% in 2022 from 10.1% in 2021.

Contents |  | Introduction |  | Strategy and performance |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> Our performance
ING Bank Annual Report 2022 30
Retail Banking
Total Retail Banking
In 2022, Retail Banking showed a good commercial performance. However, net result declined 5.9% to
€2,862 million due to the impact of exceptional items in income and higher risk costs in 2022. The result
before tax decreased 6.3% to €3,983 million.
Income decreased by €171 million, or 1.4%, and this included the negative impact of unwinding our TLTRO-
related derivative position in 4Q2022, as a result of ECB’s decision to change the conditions for the TLTRO
programme. The net TLTRO impact in 2022 was €-123 million compared to a €152 million benefit in 2021.
Income in 2022 was also impacted by €-563 million of exceptional items, consisting of €-343 million impact
from the introduction of the Polish mortgage moratorium, €-247 million to unwind a macro fair value hedge
in Belgium and €-165 million for impairments on our stake in TTB, only partly offset by €125 million income
from the transfer of our investment business in France and a €67 million gain from a legacy entity in
Belgium. Excluding TLTRO and those exceptional items, income rose 5.5%. The increase was mainly in net
interest income on liabilities following central bank rate increases while deposit tracking was still limited. Net
interest income on lending products declined, reflecting delayed tracking of higher cost of funds in client
rates as well as reduced levels of prepayments on mortgages. Net core lending growth, which excludes
currency impacts, Treasury and the run-off in Westland Utrecht Bank and France (as from the second
quarter of 2022), was €15.8 billion, of which €11.2 billion was in residential mortgages, largely in Germany.
Net core deposits growth (also adjusted for the run-off in France) was €18.9 billion in 2022, primarily in the
Netherlands. Net fee and commission income rose 2.5%, driven by a strong increase in daily banking
products, reflecting higher package fees, recovery of international payments and the introduction of new
fees. This compensated for lower fees from investment products due to a decline in stock markets and
subdued trading activity.
Operating expenses declined by €140 million, or 1.8%, compared with 2021. Expenses in 2022 included €233
million of incidental items, largely related to restructuring provisions (mainly in Belgium and France) and the
addition of the interest-on-interest effect to the compensation for customers of certain Dutch consumer
credit products. In 2021, incidental items had amounted to €455 million, primarily reflecting redundancy
provisions and impairments related to the decision to exit the retail banking markets in France and the
Czech Republic and provisions in the Netherlands for the closure of branches and the compensation for
certain consumer credit products. Expenses excluding regulatory costs and incidental items were well-
contained, despite inflationary pressure, and increased 0.8%. The cost/income ratio was 62.0% in 2022
compared with 62.3% in 2021.
Net additions to loan loss provisions for Retail Banking increased to €639 million, from €399 million in 2021,
but with 14 basis points of average customer lending remained well below the through-the-cycle average.
Risk costs in 2022 included €431 million of Stage 3 provisioning and €208 million of net additions in Stage 1
and 2, and were mainly recorded in Poland, Belgium and Germany.
Market Leaders
Retail Netherlands
The result before tax of Retail Netherlands increased 4.0% to €2,014 million from €1,936 million in 2021. This
increase was attributable to lower expenses, mainly due to lower incidental cost items, partly offset by
lower income and limited risk costs, after a net release in 2021.
Total income declined by €66 million to €4,196 million, fully due to a net TLTRO impact of €-78 million
compared to a €53 million benefit in 2021. Excluding TLTRO, income rose 1.5%. Net interest income
excluding TLTRO declined 8.4% due to lower margins on lending products, reflecting the lengthening of the
duration of the book and lower prepayment penalties. This was partly offset by higher liabilities income as
margins improved and volumes increased. Net core lending (which excludes Treasury products and a €0.8
billion decline in the Westland Utrecht Bank run-off portfolio) grew by €3.0 billion in 2022, of which €2.2
billion was in residential mortgages and €0.8 billion in other lending. Net core deposits growth (excluding
Treasury) was €12.9 billion, mainly in savings accounts. Net fee and commission income strongly increased
by €121 million, or 15.7%, mainly due to higher fee income from daily banking products, supported by
increased fees for payment packages and new service fees for business banking. Investment and other
income rose by €216 million, mainly attributable to higher results from Treasury-related products.
Operating expenses declined to €2,115 million from €2,403 million in 2021, mainly due to a drop in
incidental cost items. 2022 included a €75 million provision for adding the interest-on-interest effect to the
compensation for customers on certain Dutch consumer credit products, while 2021 had contained €289
million of incidental costs. Excluding these incidental items, expenses declined by €73 million, or 3.5%,
mainly driven by lower staff and office-space-related expenses, as well as lower regulatory costs.
The net addition to loan loss provisions was €67 million, or 4 basis points of average customer lending,
compared to a net release of €76 million, or -5 basis points, in the previous year. The limited net additions in
2022 were mainly related to business lending and consumer lending, while risk costs for the mortgage
portfolio were negligible.

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> Our performance
ING Bank Annual Report 2022 31
Retail Belgium
Retail Belgium includes ING's retail operations in Luxembourg.
The result before tax of Retail Belgium declined to €223 million compared with €583 million in 2021. The
decline was almost fully due to an impact of €-247 million to unwind a macro fair value hedge and €97
million of incidental expenses in 2022.
Income fell by €328 million to €2,147 million from €2,475 million in 2021. Net interest income was 4.5%
lower at €1,668 million, including a net TLTRO impact of €-29 million compared to a €76 million benefit in
2021. Excluding TLTRO, interest result rose 1.6%, driven by higher liabilities income as margins improved,
partly offset by margin compression on lending products due to higher funding costs. Net core lending
(excluding Treasury) increased by €3.6 billion in 2022, of which €1.4 billion was in mortgages, and €2.2
billion in other lending. Net core deposits (excluding Treasury) were flat on 2021, as an increase in savings
and deposits was offset by a decline in current accounts. Net fee and commission income decreased by €8
million, or 1.5%, as lower fees on investment products were only partly compensated by price increases for
payment packages. Investment and other income dropped by €241 million, due to the €-247 million impact
of the hedge unwinding in 2022 and a €25 million capital gain on the sale of an associate in the prior year,
partly offset by a €67 million gain from a legacy entity in 2022.
Operating expenses increased by €119 million and included €97 million of incidental costs which were
mostly restructuring costs related to the optimization of the branch network. Excluding these incidental
items, cost growth was limited to 1.3% as the impact of automatic salary indexation could largely be
compensated by FTE reductions and lower IT expenses.
The net addition to the provision for loan losses decreased to €139 million, or 15 basis points of average
customer lending. In 2021, the net addition had been €225 million, equivalent to 25 basis points. The decline
year-on-year was driven by lower risk costs in the mortgage and consumer lending portfolios.
Challengers & Growth Markets
Retail Germany
Retail Germany included ING's retail operations in Austria until the sale in December 2021.
The result before tax increased 14.6% to €901 million compared with €786 million in 2021, driven by higher
income and lower expenses, partly offset by increased risk costs.
Total income rose 8.1% to €2,172 million from €2,009 million in 2021. Net interest income increased 15.1%,
supported by significantly higher margins on liabilities. The increase was only partly offset by lending
margin pressure, a €35 million lower net TLTRO impact (€-19 million in 2022 compared to a €16 million
benefit in 2021) and the impact of the discontinuation of ING’s Retail Banking activities in Austria in the
previous year. In 2022, net core lending growth (which excludes Treasury products and the Austrian run-off
portfolio as from the second quarter of 2021) was €6.1 billion, almost entirely in residential mortgages. Net
core deposits rose by €0.8 billion as a net outflow in the first half of the year was followed by a strong inflow
in the second half of the year. Net fee income declined by €60 million, or 12.1%, mainly in investment
products after a record-high level in 2021, partly compensated by higher fees from daily banking.
Investment and other income increased by €4 million, as a €26 million one-off loss related to the transfer of
our retail operations in Austria recorded in 2021 was partly offset by lower Treasury-related revenues in
2022.
Operating expenses decreased by €34 million, or 2.9%, to €1,140 million in 2022, reflecting savings following
the discontinuation of the Austrian retail banking activities as well as lower regulatory costs due to an
adjustment of the deposit guarantee contributions in 2022. These decreases were partly offset by higher
staff costs and an increase in marketing expenses to support customer growth, as well as €10 million of
incidental items for staff allowances and restructuring costs.
Net additions to loan loss provisions increased to €131 million (13 basis points of average customer lending)
compared with only €49 million (5 basis points) in 2021. Risk costs in 2022 were primarily related to
consumer lending.
Retail Other
Retail Other consists of the Other Challengers & Growth Markets, including our bank stakes in Asia.
Retail Other’s result before tax declined to €845 million, from €949 million in 2021, mainly due to higher
regulatory costs in Poland and higher risk costs.
Total income rose by €61 million to €3,663 million. Net interest income was up 0.5% to €2,726 million,
despite a €-343 million impact from new mortgage moratorium regulation imposed by the Polish
government. Excluding this impact, net interest income increased 13.2%. This increase mainly reflected
higher margins on liabilities, notably in Poland, Australia and Spain, following increases in central bank
interest rates. Interest income on lending products declined in most of the countries due to tighter lending
margins. Net customer lending (adjusted for currency effects, Treasury and the run-off portfolio in France as
from the second quarter of 2022) grew by €3.2 billion in 2022, with growth in all countries. Net core deposits
growth (also adjusted for currency impacts and Treasury as well as the France run-off portfolio) was €5.2
billion, primarily driven by net inflows in Spain, Australia and Poland. Net fee and commission income rose
by €5 million to €535 million, supported by higher daily banking and insurance fees. These increases were
largely offset by lower fees from investment products, reflecting low stock markets and subdued trading
activity and the impact of ING’s exit from the French retail market. Investment and other income rose to
€402 million and included €125 million income from the transfer of our investment business in France and

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> Our performance
ING Bank Annual Report 2022 32
€-165 million for impairments on ING’s equity stake in TTB. Excluding these exceptional income items,
investment and other income increased by €81 million, mainly due to higher Treasury-related income and
the proceeds from the sale of a non-performing loan portfolio in Spain.
Operating expenses rose by €64 million, or 2.6%, to €2,516 million. In 2022, expenses included €51 million of
incidental items, mainly consisting of restructuring provisions related to the discontinuation of our retail
banking activities in France and the Philippines and the refocusing of our partnership for insurance
propositions. 2021 had included €166 million of incidental costs, mainly consisting of restructuring
provisions and impairments related to ING’s decision to exit the retail banking markets in France and the
Czech Republic. Regulatory costs increased by €100 million as 2022 contained a €99 million contribution to
the new Institutional Protection Scheme in Poland. Excluding incidental items and regulatory costs,
expenses increased by €79 million, primarily attributable to inflationary pressure across all markets,
investments in operational process improvements in Australia and €21 million for a litigation provision in
Spain.
The net addition to loan loss provisions amounted to €302 million, or 28 basis points of average customer
lending, in 2022. In the previous year this had been €202 million, or 20 basis points. Risk costs in 2022 were
primarily attributable to net additions in Poland and Spain.
Wholesale Banking
In 2022, Wholesale Banking turned in a strong commercial performance. This was fully offset, however, by a
sharp increase in risk costs, partly due to the Russian invasion in the Ukraine and compared with an
exceptionally low level in 2021. Therefore the net result was 36.7% lower at €1,358 million. The result before
tax decreased 30.7% to €1,991 million from €2,874 million in 2021.
Total income rose 6.9% to €6,325 million in 2022 compared with €5,916 million in 2021, primarily reflecting
income growth in Daily Banking & Trade Finance and Financial Markets. Net interest income increased by
€109 million, or 2.6%, driven by Payments & Cash Management which benefited strongly from higher
interest rates. The increase was largely offset by a €168 million lower net TLTRO impact (which was €20
million in 2022 compared with €188 million in the previous year) and lower interest income in Financial
Markets. The net core lending book (adjusted for currency impacts and excluding Treasury and the Lease
run-off portfolio) grew by €2.4 billion in 2022. Strong growth in Lending was largely offset by a net outflow
in Daily Banking & Trade Finance and in Financial Markets. Net core deposits (excluding currency impacts
and Treasury) increased by €6.2 billion, primarily in Payments & Cash Management. Net fee and
commission income rose by €20 million, or 1.7%, supported by strong fee growth in Lending, which was
largely offset by the impact of a lower deal flow in Global Capital Markets due to adverse market conditions.
Investment and other income surged by €281 million, mainly driven by higher trading results in Financial
Markets, only partly offset by Treasury & Other which included a €-41 million hedge accounting impact in
Belgium.
Operating expenses increased 6.4% to €3,114 million from €2,926 million in 2021. Expenses in 2022 included
€38 million higher regulatory costs and €10 million of incidental items mainly related to restructuring costs,
while 2021 had included a €44 million impairment on Payvision. Excluding these incidental items and
regulatory costs, expenses increased 7.0%, of which 2.8% was FX impacts, reflecting the weakening of the
euro relative to other currencies. The remaining increase was mainly attributable to higher staff costs (due
to CLA increases and indexation), partly mitigated by continued cost-efficiency measures.
The addition to loan loss provisions was €1,220 million, or 65 basis points of average customer lending, while
in 2021 risk costs had been exceptionally low at €117 million, or 7 basis points of average customer lending.
Risk costs in 2022 were significantly impacted by the Russian invasion in Ukraine, which led to a net addition
of €533 million on our Russia-related exposure. The remainder was mainly due to an increase in Stage 3
individual risk costs, partly as a result of a more negative macroeconomic outlook.
Lending income increased slightly to €3,157 million. Net interest income declined by €17 million fully due to
a €57 million lower net TLTRO impact. Excluding TLTRO, interest result increased 1.6% as higher average
volumes more than compensated for lower interest margins. Net fee and commission income increased by
€88 million or 19.3%, reflecting significantly higher fee income from several sectors. Investment and other
income declined by €42 million, mainly due to negative fair value adjustments and secondary sales
discounts.
Income from Daily Banking & Trade Finance increased by €352 million to €1,662 million, predominantly
driven by Payments & Cash Management, which benefited strongly from higher interest rates, and
furthermore supported by Bank Mendes Gans.
Income for Financial Markets increased by €122 million to €1,226 million, supported by higher trading
results, especially in forex and money markets which benefited from volatility on the markets following
interest rate hikes, the strengthening of the US dollar and inflationary pressure. Commission income
declined due to a lower deal flow in Global Capital Markets, reflecting a slowdown in the market.
Income for Treasury & Other decreased by €94 million due to a net TLTRO impact of €-51 million in 2022
(compared to a benefit of €4 million in the previous year), a €-41 million hedge accounting impact to
unwind a macro fair value hedge in Belgium and a €28 million gain on an investment in an associate
recorded in 2021. This was partly offset by mark-to-market gains from credit default positions in 2022.

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> Our performance
ING Bank Annual Report 2022 33
Our leadership - members of the Management Board Banking

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> Our leadership
ING Bank Annual Report 2022 34
Our leadership - members of the Supervisory Board

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> Our leadership
ING Bank Annual Report 2022 35
Supervisory Board report
In 2022, the Supervisory Board (SB) and its committees focused on
overseeing and constructively challenging management on the update
of ING's global strategy. The updated strategy is built around ING's
purpose of ‘empowering people to stay a step ahead in life and in
business’. The war in Ukraine and the ongoing geopolitical uncertainty
and pressure on the global economy were closely monitored, managing
and controlling risks, while assisting our employees and customers
wherever possible. Emphasis continued to be placed on ING’s risk
culture and further strengthening our global anti-money laundering
(AML) and know your customer (KYC) activities. Sustainability was also a
priority for the SB. To assist with performing its ESG-related duties, the
Supervisory Board appointed an ESG committee.
In 2022, the Supervisory Board maintained a regular dialogue with the Management Board Banking (MBB)
on ING's strategic priorities. Two overarching strategic priorities were defined: giving customers a superior
experience and putting sustainability at the heart of what we do. For more information see the 'Our
strategy' chapter. At the request of the Supervisory Board, deep dives were organised on various topics
relating to strategy. This was the result of one of the priorities agreed by the Supervisory Board for 2022 to
ensure time is spent in meetings on strategy and sustainability, business and financial performance, risk
management and regulatory requirements. The Supervisory Board also monitored the execution of the
strategy by discussing the challenges and opportunities of the strategic priorities, countries, business and
projects on a quarterly basis with the MBB.
The year 2022 was marked by the war in Ukraine, which is having a devastating impact on people’s lives and
is threatening international stability and security. The Supervisory Board and its committees closely
monitored the ongoing geopolitical uncertainty and pressure on the global economy and its impact on ING
and its stakeholders. Lower economic growth, exceptionally high inflation and high energy prices have
severely impacted consumers and companies. The MBB provided the Supervisory Board and its committees
with frequent updates on developments in Russia and Ukraine. This included how ING safeguards the safety
and well-being of impacted employees, business continuity and operational resilience, how ING manages IT
and cybersecurity risks, our exposure to Russia and Ukraine and complying with sanctions.
The Supervisory Board is committed to continue working with the MBB on further enhancing and embedding
‘environmental, social & governance’ (ESG) principles into ING’s internal processes and business activities. In
this respect, the Supervisory Board appointed an ad-hoc ESG Committee from among its members to assist
with overseeing ESG-related topics. See 'ESG Committee' for further details.
The Supervisory Board met 15 times in 2022 for its regular meetings. On average, 99% of the Supervisory
Board members participated in the meetings. See the attendance matrix for the Supervisory Board
meetings and committee meetings for more details. The continued high attendance demonstrates that
Supervisory Board members are engaged with ING and are able to devote sufficient time and attention to
overseeing its affairs.

SB Attendance 2022 1 |  |  |  |  |  |
| SB | RiCo 2 | AC | NCGcom 3 | RemCo | ESGcom 4
Hans Wijers (chair) | 15/15 | 10/10 | 7/7 | 12/12 | 7/7 | 3/3
Mike Rees (vice-chair) | 14/15 | 10/10 | 7/7 |  |  |
Juan Colombás | 14/15 | 10/10 | 7/7 |  |  |
Mariana Gheorghe | 15/15 | 10/10 |  | 12/12 | 7/7 | 3/3
Margarete Haase | 15/15 | 10/10 | 7/7 |  |  |
Lodewijk Hijmans van den Bergh | 15/15 | 10/10 |  |  |  | 3/3
Herman Hulst | 15/15 | 10/10 | 7/7 |  |  | 3/3
Harold Naus | 15/15 | 10/10 |  | 1/1 | 6/7 |
Herna Verhagen 5 | 15/15 | 2/2 |  | 11/12 | 7/7 |
Total attendance 6 | 99% | 100% | 100% | 97% | 96% | 100%

1 This SB attendance overview shows the SB (committee) meetings that took place during the year. In addition to these meetings,
there were 12 internal SB meetings in 2022 in view of nomination and remuneration matters, with a total attendance rate of 99%.
These are not shown separately in the overview for year-on-year, like-for-like comparison purposes.
2 In 2022, two RiCo meetings were held in combination with the RemCo on remuneration matters that also required a risk view.
3 In 2022, one NCGcom meeting was held in combination with the RemCo in view of changes to the management structure of ING Bank
N.V. including the amended constellation of the Management Board Banking.
4 Attendance is shown as of the initiation of the ESGcom in the second quarter of 2022.
5 Harold Naus participated once in a NCGcom meeting in combination with the RemCo. Herna Verhagen participated twice in a RiCo
meeting in combination with the RemCo.
6 The numbers exclude SB observers, if any. If SB members cannot join a meeting they will always receive the meeting materials to
allow them to provide feedback prior to the meetings.
Abbreviations used: SB = Supervisory Board, RiCo = Risk Committee, AC = Audit Committee, NCGcom = Nomination and Corporate
Governance Committee, RemCo = Remuneration Committee; ESGcom = ESG Committee

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> Supervisory Board report
ING Bank Annual Report 2022 36
The Supervisory Board discusses and reconfirms all of its members’ outside positions on an annual basis. It
approves among others, any intended outside positions as and when they occur, to safeguard this level of
engagement.
In addition to the information included in this Supervisory Board report, information on the Supervisory
Board can be found in ‘Our leadership’ and ‘Corporate governance’, which information is deemed to be
incorporated, by reference, herein.
Supervisory Board meetings
The Supervisory Board discussed a wide range of topics during the year. In its deliberations on the various
topics the Supervisory Board considers the customers’ and other stakeholders’ interests in view of ING’s
function in society.
In addition to the topics mentioned in the introduction, the Supervisory Board discussed, among others:
•The economic and political developments and their effects, such as the energy crisis, inflation, shortages
in the economy and the rapidly slowing economy.
•Progress of ING’s performance in the various business lines on key financial and non-financial metrics.
•Diversity and inclusion, including, e.g. the bankwide diversity & inclusion approach and specifically
gender diversity in senior management.
•ESG related matters in relation to strategy, including, among others, sustainability, climate risk and
energy transition.
•The continued impact of Covid-19 on ING’s performance and its stakeholders (e.g. how to empower
customers to remain in charge of their banking and their finances, how to equip employees for a hybrid
way of working in which flexibility is central, and how to help communities to build back better).
•Ongoing supervisory developments, such as the European Central Bank’s Supervisory Review and
Evaluation Process (SREP) and related matters such as the internal capital adequacy assessment process
(ICAAP), the internal liquidity adequacy assessment process (ILAAP) and (climate risk related) stress
testing.
•ING’s financial, non-financial and compliance risks, and in this respect, among other things, ING’s
gatekeeper role and ensuring the security and compliance of the bank through enhancing and maturing
ING’s KYC priorities, supported by structural solutions (see 'Strengthening ING’s global AML/KYC
capabilities' for further details on ING’s AML/KYC measures); and strengthening ING’s risk culture.
•Several topical regulatory themes with a global ING scope such as data strategy and management, IT
and cybersecurity, sourcing, developments in Russia and Ukraine, compliance with sanctions, the KYC
enhancement programme and leveraged transactions.
•The financing of the company in accordance with ING’s capital and liquidity adequacy, ING’s capital plan
and ING’s dividend and distribution policy.
•The audit plans of the internal and external auditor.
•Various nomination and succession planning related matters for the MBB and the Supervisory Board.
•Various remuneration-related matters, such as the annual review of the Reward and Appointment
Framework and the ING Remuneration and Regulations Framework.
•The functioning of the Supervisory Board and its committees and the MBB, supported by annual
collective self-evaluations, and the functioning of their individual members.
The MBB was present at each regular Supervisory Board meeting. For some parts of these meetings,
depending on the nature of the topics discussed, only the chief executive officer (CEO) was present. The
Supervisory Board also had sessions without the MBB prior to its regular meetings when this was justified by
the nature of the topics on the agenda. The purpose of these so-called pre-meetings and Supervisory Board-
only meetings is to allow the Supervisory Board to reflect independently on and consider important matters
in the absence of the MBB.
Outside of the collective meetings, there was frequent interaction between the chairs of the relevant SB
committees and the members of the MBB to ensure that – at all times – everyone was up-to-date on the
most recent developments. Furthermore, the chairs of the Risk Committee and the Audit Committee agreed
that they will continue informal interaction with the chairs of local risk and audit committees of ING’s five
largest subsidiaries to enrich the Supervisory Board dialogue. Also, Supervisory Board members who do not
chair committees were assigned specific focus areas that best fit their skills, knowledge and experience to
further enhance well-informed Supervisory Board decision-making and challenge. The 2022 focus areas
were risk culture, models and stress testing, operational resilience, KYC, ESG (including sustainability and
governance) and IT (including digital and cybersecurity).
Continuous dialogue with stakeholders
ING maintains continuous interaction with stakeholders, and aims to strike a balance between the interests
of all stakeholders, including customers, shareholders, employees, regulators, supervisors and society at
large. In 2022, the Supervisory Board had periodic conversations with various stakeholders. It exercised its
oversight role, which aimed to ensure that, actions resulting from this, were embedded in the organisation
and followed up, including actions related to strategy. The dialogue between ING and external supervisors
and regulators was a standard agenda item for the Supervisory Board throughout the year. This included
several discussions on the results of and follow-up to the annual SREP, through which the ECB aims to
promote a resilient banking system as a prerequisite for a sustainable and sound financing of the economy.
The SREP involves, among others, a comprehensive assessment of banks’ strategies, processes and risks,
and takes a forward-looking view to determine how much capital each bank needs to cover its risks.

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ING Bank Annual Report 2022 37
Strengthening ING’s global AML/KYC capabilities
Keeping ING safe, secure and compliant remains one of ING's top priorities. Since 2017, ING has been
working to strengthen customer due diligence, transaction monitoring and screening in a sustainable way
for the longer term and to better contribute to the fight against financial economic crime through the global
KYC enhancement Programme. Various initiatives have been implemented to further enhance AML/KYC
activity throughout the bank. Among other things, this has led to standardised KYC policies, global KYC
governance and harmonisation of processes, tooling and training. Further developments are captured in the
Financial Economic Crime (FEC) Controls Maturity Programme, which defines and further enhances ING’s
operational long-term FEC control framework to manage and mitigate financial and economic crime risks in
a sustainable, risk-based way. Progress is monitored by and discussed between the SB, management and
the relevant supervisors.
In 2022, the Supervisory Board was updated at least quarterly on developments regarding KYC and relevant
specifics were discussed in more detail. This was facilitated through thematic sessions on various topics such
as, among others, the KYC enhancement programme as agreed with DNB. These sessions also contributed
to the Supervisory Board’s continuous learning.
Permanent education including exchange with the business
It is important for the members of the Supervisory Board, as part of their continuous learning, to participate
in the permanent education and exchange with ING’s business on a regular basis. The latter is aimed at
keeping the SB up-to-date on ING-relevant knowledge, skills and expertise and expanding these where
necessary. It is meant to increase the Supervisory Board’s understanding of and engagement with ING’s
business operations and stakeholders.
The annual knowledge days, which were held on 13 and 14 January 2022, were combined with regular
Supervisory Board meetings and focused on ESG.
As part of the annual business visit, the entire Supervisory Board, together with the MBB, visited ING in
Germany in September 2022. This allowed the Supervisory Board to get a better understanding of local
business challenges and the market opportunities of ING in Germany.
Throughout the year, a number of other educational sessions on specific topics facilitated by relevant
experts were organised for the Supervisory Board. For 2022, a balance was sought between sessions
focused on compliance, ESG, operational resilience and sessions focused on strategic business topics. The
latter included in-depth sessions on (1) ING’s Wholesale Banking business and Retail Banking business,
including Business Banking, (2) technology and IT platforms, (3) digital services and assets and (4) several
country updates. Additionally, thematic sessions were organised to focus specifically on certain themes that
needed further attention and/or to look forward at emerging risks and developments. Furthermore, several
deep dive sessions were organised on selected key topics. Both these thematic and deep dive sessions had a
substantial risk management component and contributed to a more in-depth understanding of the matters
discussed. For more information, see ‘Risk Committee’.
The various educational sessions provided opportunities for Supervisory Board members to interact with
senior management and subject-matter experts. They also interacted in speed-meet sessions. These
meetings were held in person, virtually and in hybrid mode. Such interaction contributes to a better mutual
understanding and alignment on what matters most to ING, its employees and the Supervisory Board. As in
previous years, the Supervisory Board will continue this practice.
Strategy based on long-term value creation
In 2022, ING introduced its updated strategy. The Supervisory Board had an active and continuous dialogue
with the MBB on the strategy update. To successfully serve its purpose and make the difference for people
and the planet, ING will focus on two overarching strategic priorities: giving its customers a superior
experience and putting sustainability at the heart of what it does. ING has also defined four enabling
priorities. ING will focus on (1) providing seamless, digital experience, (2) using its scalable technology and
operations, (3) staying safe and secure and (4) unlocking the full potential of everyone working for ING.
By updating its strategy, ING is constantly adapting to the trends shaping the world around us and
impacting customers, ING and the industry, with the aim of ensuring it seizes the opportunities flowing from
today’s reality and big trends to create long-term value.
The Supervisory Board acknowledges the responsibility it has to consider and balance the interests of all
stakeholders of ING and makes sure to take this into account while delivery on the strategic priorities is
being executed.
Financial and risk reporting
The MBB prepared the financial statements and discussed these with the Supervisory Board. The quarterly
results, including the relevant press releases, were discussed and approved in February, May, August and
November 2022. The full-year 2021 financial results were discussed and approved in March 2022. The
financial statements will be submitted for adoption at the 2023 Annual General Meeting as part of the 2022
Annual Report. KPMG, in its role as ING’s external auditor, audited ING’s 2022 financial statements. As part of
the standard procedures, KPMG declared itself independent from ING, in compliance with applicable rules
and regulations. Read more in ‘Audit Committee’ below.

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The Supervisory Board was also informed in detail throughout the year of potential financial, non-financial
and compliance risks for ING, including, the crisis with regard to the war in Ukraine, subsequent political and
economic developments in various countries and regions, climate- and ESG related risks, the continued
implications of Covid-19 and updates on (upcoming) regulatory changes. The Supervisory Board discussed
how these and other risks could best be mitigated, which included reviewing stress test results performed by
ING. In addition to internal stress tests and programmes related to known and anticipated risks, ING
released its second integrated climate report in September 2022. It details ING’s progress and targets on
climate alignment in the nine sectors in ING’s loan book most responsible for climate change. This progress
and progress on other ESG related matters were monitored by the newly appointed ESG Committee.
Read more on risk management in ‘Risk Committee’ below.
Internal Supervisory Board meetings
During the 2022 internal meetings of the Supervisory Board (with the CEO attending, except when matters
concerning him were discussed), among others, the following recurring topics were addressed:
•The annual targets and periodic performance assessments of the MBB and its individual members. The
Supervisory Board evaluates and assesses the functioning of the MBB, including questions of succession
and remuneration, at least annually, in an internal meeting.
•The composition of the MBB.
•The composition of the Supervisory Board including its committee composition (this year including the
appointment of the ESG Committee).
•ING’s broader talent and succession planning in view of bench strength, including the outcome of ING’s
annual talent review.
•Remuneration related matters, including, but not limited to (1) the appointment/compensation/
severance proposals of high earners and senior management in control functions and (2) the Variable
Remuneration Accrual Model (VRAM) process.
•The annual collective self-evaluation of the MBB and the Supervisory Board.
Supervisory Board annual collective self-evaluation
As in previous years, the Supervisory Board conducted an annual collective self-evaluation of the reporting
year. This was facilitated by an independent external party and with input from several executives and
senior managers who regularly interact with the Supervisory Board and attend its meetings. The self-
evaluation addressed the ‘what’ (roles and responsibilities) and the ‘how’ (culture and behaviour) of the
Supervisory Board. In addition to the traditional themes, the self-evaluation over 2022 also reflected on
ING’s strategy, digital and data developments, ESG, and geopolitical events.
Approach
During the November 2022 Supervisory Board meeting, the Supervisory Board discussed and approved the
annual collective self-evaluation process and design for the year 2022. In December 2022, input was
gathered from the Supervisory Board members and frequent attendees. This, together with the outcome of
the 2022 mid-year review and of the bilateral interactions between the chairman and each individual
Supervisory Board member in January 2023, formed the basis for the collective Supervisory Board self-
evaluation dialogue in February 2023. During this dialogue the Supervisory Board determined its collective
positive points to maintain and its 2023 priorities for further improvement. This forms part of the
Supervisory Board’s practice to regularly deliberate on its collective performance i.e. towards year-end (to
determine the next year’s approach and potential specific themes to address), halfway through the year (to
reflect on status and progress) and at the start of the year (to discuss the outcome of the previous year and
agree on positive points to keep and points for further improvement).
Results
The Supervisory Board’s collective dialogue on 1 February 2023 centred around the following questions: (1)
Positive points: are the positive points previously identified still valid? Where has the Supervisory Board
further improved, taking into account the continued focus on ESG and ongoing macroeconomic &
geopolitical events? and (2) Priorities for further improvement: Did the Supervisory Board sufficiently
progress in 2022 on the improvement areas previously defined? What are the priority areas to further
improve in 2023?
The Supervisory Board's agreed priorities for 2022 included:
1.Regarding the ‘what’: (1) safeguarding balance in open, constructive dialogue with the Executive Board
and the Management Board Banking on business/market developments, including emerging risks, and
time spent on shareholders’ and other stakeholders’ views on performance of the company, and (2)
continue to be provided with fit-for-purpose supporting materials for board meetings.
2.Regarding the ‘how’: (1) Covid-19 permitting, the importance of returning to physical meetings with the
Executive Board, the Management Board Banking and other ING representatives, and (ii) continue
investing in access to and leveraging on knowledge, skills and experiences relevant to the Supervisory
Board in the context of ING.
During 2022, the Supervisory Board addressed all of the above and, where applicable, embedded
enhancements in its standard working practice: With regard to the ‘what’, items (1) and (2) form part of the
regular meetings of the Supervisory Board and its committees, with a view to the Supervisory Board’s role
and responsibilities, supported by its comprehensive annual cycle of work. With regard to the ‘how’, item (1)
was completed by the implementation of the Hybrid Mode as the Supervisory Board’s new way of working,

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and item (2) was addressed by broadening the focus areas of the non-chair Supervisory Board members
including the interactions within the organisation on these.
Looking back on 2022, and compared to previous years, the Supervisory Board concluded that several
positive points continued to be valid and had also further improved during 2022:
•Regarding the ‘what’, the following Supervisory Board strengths were recognised: (1) its effectiveness at
overseeing, supervising, challenging and advising the Executive Board and Management Board Banking,
(2) its understanding of the organisation’s strategic priorities and relevant digital & data developments,
the effectiveness with which ESG considerations are integrated into discussions and the monitoring of
macroeconomic & geopolitical events, (3) its composition and the interface / working balance between
the Committees and the Supervisory Board, and (4) its meeting management, meeting materials and the
support available.
•Regarding the ‘how’, the following positives were recognised: (1) the relationships between the
Supervisory Board members and with the Executive Board and Management Board Banking, and (2) the
understanding of the views and requirements of key stakeholders.
Looking ahead, the Supervisory Board concluded that several priorities for further improvement are still
relevant and the following areas require further attention during 2023:
•Regarding the ‘what’ it identified: (1) safeguarding balance in open, constructive dialogue with the
Executive Board and the Management Board Banking on strategy/business/market developments,
including emerging risks, and time spent on shareholders’ and other stakeholders’ views on performance
of the company, and (2) continue to be provided with fit-for-purpose supporting materials for board
meetings.
•Regarding the ‘how’ these attention points were identified: (1) Managing the change in composition of
the Supervisory Board, and (2) Enhancing insight into people and talent processes.
Looking ahead, the Supervisory Board concluded that several priorities are still relevant and the following
areas require further attention during 2023:
1.Further establish the Supervisory Board’s oversight and governance on ESG through its dedicated ad-hoc
Supervisory Board committee with a focus on further maturing the Social and Governance components.
2.On people related matters, ensure continued attention for diversity & inclusion and enhance the
Supervisory Board’s view of the broader talent pipeline.
3.Ensure continued focus is given to key topics, in addition to the aforementioned, such as ING’s strategic
priorities, digital & data, (non-financial) risk and geopolitical & macroeconomic developments, including
the accessing of outside-in views of stakeholders.
4.Enhance the quality of board meeting materials by highlighting the topic’s most significant challenges &
dilemmas and by being mindful of the length of materials.
5.Maintain the effectiveness of the Supervisory Board throughout the imminent changes in its composition
through continued team building events and attention for the individual members’ areas of expertise.
6.Support the CEO throughout the imminent organisational and composition changes of the Management
Board Banking.
The Supervisory Board is of the opinion that the above contributes to overseeing and constructively
challenging ING in its ambition to keep transforming into a data-driven digital bank in line with the strategy.
Committee meetings
To manage each of the committees’ annual cycle of work and potential committee interdependencies, each
committee has drawn up an annual work plan that is being kept up to date throughout the year for priority
setting and forward-looking purposes. These plans all feed into the Supervisory Board’s annual meeting
cycle.
For an overview of the composition of the committees on 31 December 2022, see the table under 'Overview
of Supervisory Board committee members'.
Risk Committee
The Risk Committee met 10 times in 2022, of which meetings two were combined with the Remuneration
Committee to address remuneration-related risk methodology elements, such as those relating to the
Variable Remuneration Accrual Model (VRAM) that was introduced in 2018 (see also ‘Remuneration
Committee’). During another Risk Committee meeting there was a combined session with the ESG
Committee on climate risk stress testing. Since 2020, almost all Supervisory Board members have been
members of the Risk Committee, due to the continued importance of risk and how this is managed and
supervised.
The committee assists and advises the Supervisory Board with the performance of its duties in relation to
overseeing: (1) the setting and monitoring of ING’s risk appetite and risk strategy for all types of risk,
including but not limited to financial, non-financial and compliance risk; (2) the effectiveness of the internal

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risk management and control systems; and (3) other related risk management topics. The Risk Committee
prepares the discussions within and decisions of the Supervisory Board on such matters.
The Risk Committee aims to ensure that integrity continues to come first for ING and that critical non-
financial risk areas stay top of mind, as an integral part of ING’s identity. Through risk management ING
builds strong foundations, supported by structural solutions that continue to earn and maintain the trust of
its stakeholders, including its customers and society at large.
During 2022, in light of the situation with regard to Russia and Ukraine and Covid-19, additional updates on
financial, non-financial and compliance risk were provided, both separately and as recurring reporting to
help continue and further bolster ING’s customer diligence and stakeholder integrity. These updates
included the status of ING’s accompanying metrics for risks in the areas of solvency, liquidity and funding,
credit, country, market, IT, non-financial risk and compliance. The discussions were supported by different
analyses conducted on the potential impact of such events on ING’s credit portfolio, capital and liquidity
position, and updates on credit developments in certain countries and portfolios. With respect to the
situation in Russia and Ukraine, the committee also addressed risks related to non-financial risk (including
cybercrime) and sanctions. With respect to Covid-19, the committee addressed risks related to business
continuity, business resilience, the working from home control environment, HR, and IT and cybercrime.
Additional broad risk topics in relation to these events included (1) updates of the bank-wide KYC
enhancement and maturity efforts, (2) a variety of topical dashboards such as on IT (risk), cybersecurity,
sourcing, data quality and data privacy (including GDPR) and (3) the status of implementation of related
regulatory programmes.
The Risk Committee also regularly discussed the status of reported whistleblower concerns. As part of the
annual recurring topics, the Risk Committee discussed the following:
•The annual review of the Risk Appetite Framework and accompanying principles and risk appetite
statements.
•The annual update to the Recovery Plan.
•The impact of upcoming regulations, and credit developments in certain countries and portfolios.
•The review of the scope of ING’s key policies.
As mentioned, in addition to current topical events throughout the year, deep dives and thematic sessions
also took place on specific topics. Deep dives are technical discussions on selected key topics that have
substantial risk management relevance and that contribute to a more in-depth understanding of the
matters at hand. In 2022, there were deep dives on IT and cybersecurity, ING’s Risk Appetite Framework,
data strategy and data management, the bank-wide KYC enhancement programme and liquidity and
funding. Thematic sessions focus specifically on certain themes that need further attention and/or are
looking forward at emerging risks and developments. Thematic sessions in 2022 encompassed:
cybersecurity, ICAAP (including Economic Capital and Stress Testing), internal controls and key control
testing, compliance, climate risk stress testing and modelling. All Supervisory Board members had a
standing invitation for these sessions and participated in several of these as deemed relevant to them.
All relevant items discussed by the committee were reported to the Supervisory Board, with the Supervisory
Board approving those items as required from a governance perspective.
Audit Committee
The Audit Committee met seven times in 2022. During one of its meetings there was a combined session
with the ESG Committee on ESG disclosures.
The committee assists and advises the Supervisory Board with the performance of its duties in relation to
the integrity and quality of ING’s financial reporting, and the effectiveness of ING’s internal risk
management and control systems in relation to financial reporting and prepares the discussions within and
the decisions of the Supervisory Board on such matters.
The Audit Committee addressed, among other things, the following recurring topics:
•The quarterly results and the financial statements, the press releases related to the periodic results and
the Annual Report.
•Judgemental accounting topics.
•Key audit matters, as included in the auditors’ reports.
•Financial reporting, including the quarterly results.
•(The approval of) the external auditor’s audit plan/engagement letter/independence and fees.
•The overall internal control environment, the internal controls over financial reporting, the internal and
external auditor reports.
•The review of the internal audit function.
•Matters related to the financing of the company, including the assessment of ING’s capital and liquidity
position.
•The internal audit plan, including its support and progress monitoring.
•Critical and high rated overdue issues, as reported by the internal audit function.
•The updated internal audit charter.
•The update of ING’s key policies, such as the ING Global Tax Policy.
The Audit Committee performed an assessment of the functioning of the external auditor and the scope
and materiality of the audit plan and the principal risks identified in the audit plan.

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ING Bank Annual Report 2022 41
Specific attention was paid to a variety of other related topics. These included, among other things, the
following recurring topics:
•ING’s long-term CET1 ratio target level.
•ING’s dividend and distribution policy.
•SOx Act framework and controls.
•Capital and liquidity management.
In addition, in 2022, the Audit Committee addressed, among others, the developments in Russia and
Ukraine, ICAAP governance, external audit quality indicators, ESG-disclosures and matters in the context of
Covid-19 uncertainty.
All relevant items discussed by the committee were reported to the SB, with the Supervisory Board
approving those items as required from a governance perspective.
Directly following the Audit Committee meetings, the members of the Audit Committee met in a closed
meeting with the internal and external auditors to seek confirmation that all relevant topics were discussed
in the Audit Committee meetings.
To properly prepare for the regular Audit Committee meetings, the chairperson of the Audit Committee held
separate sessions with the external auditor, the general manager of the internal audit department, the chief
financial officer (CFO) and the Group Controller. The chairperson also met with various senior managers.
Nomination and Corporate Governance Committee
The Nomination and Corporate Governance Committee met 12 times in 2022, of which one was combined
with the Remuneration Committee to address topics that simultaneously covered nomination as well as
remuneration.
The committee assists the SB with the performance of its duties in relation to selection and nomination of,
among others, the members of the Supervisory Board and MBB, talent management and the effectiveness
of ING’s governance arrangements. The committee prepares the discussions with and decisions of the
Supervisory Board on such matters.
With regard to nomination related matters, ING aims to ensure that all of its boards are – at all times –
adequately composed to perform their duties. As its standard practice, the Nomination and Corporate
Governance Committee therefore discusses (1) the performance of the individual members of the MBB (also
serving as input to the Remuneration Committee) and (2) medium- to long-term succession planning for the
MBB and the Supervisory Board. A continuing conversation on MBB succession planning is facilitated by the
chief human resources officer as part of the regular Nomination and Corporate Governance Committee
meetings in the form of deep dives by function and business line.
When selecting suitable board succession candidates, various aspects are to be taken into account in view
of board composition, such as regulatory requirements, suitability considerations, banking and other
industry knowledge, outside positions, independence, no conflicts of interest and availability. Also the
minimum and optimal size of a board and diversity aspects such as how to arrive at an appropriate balance
in its representation of regions, age, gender, knowledge and expertise are to be taken into account. The
generic profile of the Supervisory Board aims to capture these elements, which profile can be found on
ing.com. Read more on the boards’ composition in the ‘Composition of the Management Board Banking and
Supervisory Board’ section that also includes a diversity and competence matrix.
The Nomination and Corporate Governance Committee also focuses on ING’s broader talent and succession
planning in view of bench strength and diversity at higher management levels, with selected key roles
receiving dedicated attention. This is done by taking into account ING’s diversity policy and by accelerating
refreshment where possible without jeopardising business continuity. The diversity policy is published on
ing.com and explained in more detail in ‘Unlocking our people's full potential’. The committee also holds
periodic conversations outside of its regular meetings with internal talented individuals who are considered
to have the potential to assume more senior and complex roles in the organisation over time. The results of
these conversations are fed into the individuals’ coaching and development plans.
With regard to corporate governance, the committee discussed:
•The 2022 Annual Report and the accompanying booklets on ING’s application of the Dutch Corporate
Governance Code and the Dutch Banking Code.
•The approach and agenda for the 2022 AGM.
•The suitability policy framework and its global implementation, thereby also taking into account
regulatory developments.
•The annual updates to the corporate board charters, the governance manual and the decision structure
as well as any changes in board members’ outside positions.
•The review of the scope of ING’s key policies.
All relevant items discussed by the committee were reported to the Supervisory Board, with the Supervisory
Board approving those items as required from a governance perspective.
Remuneration Committee
The Remuneration Committee met seven times in 2022.

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The committee assists the Supervisory Board, with the performance of its duties in relation to remuneration,
the remuneration policies and the application and compliance thereof and prepares the discussions within
and decisions of the Supervisory Board on such matters. In doing so, the Remuneration Committee takes
into account the adequacy of information provided to shareholders on remuneration policies and practices.
As an annual recurring topic, the Remuneration Committee reviewed the remuneration report by way of
benchmarking with the purpose of further improving the remuneration report.
In addition, the Remuneration Committee discussed the progress and performance on the annual targets
set for the MBB. With regard to variable remuneration and the application of ING’s accompanying VRAM
(including last year’s lessons learned), the committee received input and advice from the Risk Committee
following strengthened risk management governance. This served as input for a review of the predefined
thresholds above which the pool for variable remuneration may be unlocked for those eligible as well as the
accompanying individual variable remuneration proposals, including potential cases for holdback or
clawback of deferred compensation by way of malus.
The Remuneration Committee also reviewed the proposed updates to ING’s Remuneration Regulations
Framework as part of its annual review. Throughout the year it assessed Identified Staff and High Earner-
related remuneration matters, based on ING’s remuneration governance structure which is part of the
above mentioned framework. In addition, the Remuneration Committee monitored the development of the
gender pay gap.
All relevant items discussed by the committee were reported to the Supervisory Board, with the Supervisory
Board approving those items as required from a governance perspective.
ESG Committee
In the second quarter of 2022, the Supervisory Board appointed an ESG Committee from among its
members. The ESG Committee has been established for an initial duration of two years. After this period, the
SB will determine whether the ESG Committee shall be made permanent.
To prevent an overlap between the ESG Committee and the other Supervisory Board committees and to
safeguard an aligned and common view on ESG, the ESG Committee consists of at least one member of
each of the other committees.
The ESG Committee assists the Supervisory Board with matters relating to the various areas of ESG
(‘environmental’, ‘social’ and ‘governance’), including but not limited to, the development of ESG and the
integration of ESG in the company and its strategy. In addition, the ESG Committee assists the Supervisory
Board by generally monitoring and advising on relevant ESG developments.
The ESG Committee met three times in 2022. During its first meeting, the ESG Committee discussed and
supported a variety of topics with a focus on the role and scope of the ESG Committee and its Terms of
Reference, which can be found on ING.com. During its subsequent meetings, the ESG Committee discussed
progress and potential impediments as well as relevant trends on ‘environmental’, ‘social’ and ‘governance’
topics and how to connect them with ING’s response and actions on the basis of ING's ESG dashboard. In
addition, the ESG Committee discussed key updates and relevant ESG related matters, such as
greenwashing, sustainability targets and ESG dilemmas. The ESG Committee also discussed any updates of
key ESG policies and ESG related supervisory/regulatory letters and publications. In 2022, members of the
ESG Committee participated in deep dives on ING's approach on environment challenges and key initiatives,
including how we reduce our own footprint, our Terra alignment strategy and our biodiversity approach and
ING's approach on social challenges and key initiatives with a focus on diversity and inclusion, financial
health and human rights. There were thematic sessions on climate risk stress testing and ESG regulatory
disclosures.
All relevant items discussed by the committee were reported to the Supervisory Board, with the Supervisory
Board approving those items as required from a governance perspective.
Overview of SB committee members
The table below reflects the composition of the Supervisory Board committees on 31 December 2022.

Supervisory Board | Risk Commitee | Audit Committee | Nomination and Corporate Governance Committee | Remuneration Committee | ESG Committee
Hans Wijers (chair) | Member | Member | Chair | Member | Member
Mike Rees (vice- chair) | Chair | Member | — | — | —
Juan Colombás | Member | Member | — | — | —
Marianna Gheorge | Member | — | Member | Member | Member
Margarete Haase | Member | Chair | — | — | —
Lodewijk Hijmans van den Bergh | Member | — | — | — | Chair
Herman Hulst | Member | Member | — | — | Member
Harold Naus | Member | — | — | Member | —
Herna Verhagen | — | — | Member | Chair | —

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> Supervisory Board report
ING Bank Annual Report 2022 43
Composition of the Management Board Banking and Supervisory
Board
ING aims to ensure that the boards are – at all times – adequately composed to perform their duties. In
2022, no members were (re-)appointed to the boards.
In line with ING’s strategic priorities and in order to further simplify the management structure of ING Bank,
it was announced on 15 December 2022 that the roles of head of Retail Banking, Challengers & Growth
Markets and Market Leaders will be combined in 2023. Pinar Abay, currently head of Market Leaders, will be
appointed to the role effective 15 May 2023 (subject to regulatory approval). Aris Bogdaneris, currently head
of Retail Banking and Challengers & Growth Markets will step down from the Management Board Banking as
of 15 May 2023 and will leave ING per 1 August 2023 to pursue other opportunities.
Furthermore, Ron van Kemenade, chief technology officer, announced to step down from his position as per
30 April 2023. Succession planning has been initiated for this role.
After more than seven years of dedicated service, Mariana Gheorghe announced that she will not be
available for reappointment to the Supervisory Board at the 2023 AGM. Therefore in 2022, the Nomination
and Corporate Governance Committee and the Supervisory Board initiated the process of selecting and
nominating a candidate for appointment to the Supervisory Board at the 2023 AGM.
On 2 February 2023, it was announced that Hans Wijers has expressed the intention for personal reasons to
hand over his duties as chairman and retire from the Supervisory Board in the second half of 2023. Hans
Wijers was appointed to the Supervisory Board in 2017 and became its chairman in 2018. It was announced
on 3 March 2023 that ING will propose to appoint Karl Guha to the Supervisory Board at the Annual General
Meeting to be held on 24 April 2023. Upon decision by the General Meeting, it is the intention of the
Supervisory Board to elect Karl Guha as its chairman effective 1 July 2023.
The Nomination and Corporate Governance Committee and the Supervisory Board will continue to strive for
an adequate and balanced composition of the Supervisory Board when selecting and nominating new
members for appointment, taking into account ING’s diversity policy and other factors.
All Supervisory Board members, with the exception of no more than one person, shall qualify as
independent as defined in the best practice provision 2.1.8 of the Dutch Corporate Governance Code. The
members of the Supervisory Board are therefore requested to assess annually whether or not they are
independent as set out in the Dutch Corporate Governance Code and to confirm this in writing. On this basis,
the Supervisory Board confirms that all members of the Supervisory Board are to be regarded as
independent on 31 December 2022. On this date all members of the Supervisory Board were also to be
regarded as independent within the meaning of the NYSE listing standards.
Read more in the Corporate governance chapter on the composition of the Management Board Banking and
the Supervisory Board. For the full list of Management Board Banking and Supervisory Board members and
more details see ‘Our leadership’, which information is considered to be incorporated, by reference, in this
Supervisory Board report.

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> Supervisory Board report
ING Bank Annual Report 2022 44
Diversity and competence matrix

Please note the following:
•The purpose of this matrix is to provide an overview on the experience and competencies that ING considers to be the most relevant for its stakeholders.
•The matrix represents to which extent ING's board members have such experience and competencies (either developed already before joining ING and/or during their position(s) at ING).
•The content of the matrix is subject to change in the light of ING’s continually changing situation, markets and environment.
•For the appointments of new board members, all relevant competencies are also shared with ING’s supervisors DNB/ECB based on their standard suitability matrix to assess the collective competence of members of the
management/supervisory body.

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> Supervisory Board report
ING Bank Annual Report 2022 45
Appreciation for the MBB and ING employees
The SB would like to thank the members of the MBB for their contribution to ING’s performance over the past
year. It was certainly another challenging year with macroeconomic and geopolitical uncertainty impacting
our customers, business and society in general. We’re grateful for their efforts in navigating through these
challenges and continuing to create long-term value for our stakeholders. Despite the uncertainty, ING
coped well, continuing to support customers and intensifying our efforts to fight climate change. Our results
for 2022 reflect the strength of our diversified business model and show our resilience and adaptability.
Of course, none of this would have been possible without our employees. We rely on them to implement
ING’s purpose and strategy. The SB appreciates their hard work and dedication in sometimes difficult
circumstances. Our sincere thanks to all.
Amsterdam, 6 March 2023

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> Supervisory Board report
ING Bank Annual Report 2022 46
Corporate governance
This section comprises ING Bank N.V.’s Corporate Governance
Statement.
Dutch Banking Code
The Dutch Banking Code is applied by ING Bank N.V. (ING Bank). The application by ING Bank is described in
the booklet ‘Application of the Dutch Banking Code by ING Bank N.V. (FY2022)’, 9 March 2023, available on
ing.com. This is to be read in conjunction with and deemed to be incorporated in the Annual Report of ING
Bank. The Banking Code can be downloaded from the website nvb.nl/English/.
Financial reporting process
As ING Bank is a consolidated subsidiary of ING Groep N.V. (ING Group), its policies and procedures for
establishing and maintaining adequate internal control over financial reporting are the same as those
applied by ING Group for its consolidated financial statements with respect to ING Bank and the entities
included in the latter's own consolidated financial statements.
ING’s internal control over financial reporting is a process designed under the supervision of our principal
executive and principal financial officers to provide reasonable assurance regarding the reliability of financial
reporting and the preparation of financial statements for external purposes in accordance with generally
accepted accounting principles.
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 the assets of ING;
•Provide reasonable assurance that transactions are recorded as necessary to permit the preparation of
financial statements in accordance with generally accepted accounting principles, and that our receipts
and expenditures are being made only in accordance with authorisations of our management and
directors; and
•Provide reasonable assurance regarding the prevention or timely detection of unauthorised acquisition,
use or disposition of assets that could have material effect on the financial statements.
ING has a process in place where, under the supervision and with the participation of the CEO and CFO, the
effectiveness of internal control over financial reporting is evaluated, based on the criteria of the Committee
of Sponsoring Organisations of the Treadway Commission in Internal Reporting (COSO) - Integrated
Framework (2013 Framework).
Management Board Banking composition
ING aims to have an adequate and balanced composition of its Management Board Banking, with a diverse
selection of persons with knowledge, skills and executive experience, preferably gained in the banking
sector, experience in corporate governance of large stock-listed companies and experience in the political
and social environment in which such companies operate. In addition, there should be a balance of
experience and affinity with the nature and culture of the business of ING. Factors such as nationality,
gender, age and education are also taken into account for the composition of the Management Board
Banking.
The Supervisory Board regularly assesses the composition of the Management Board Banking.
The Gender Diversity Act, which came into force in the Netherlands on 1 January 2022, requires ING to set
appropriate and ambitious targets for gender diversity in its Executive Board and senior management. ING
considers its Management Board Banking to be part of this senior management group for which the target
for gender diversity is set at at least 30% by 2025. See more information on diversity, including on gender
diversity in senior management, in the paragraphs on Unlocking our people's full potential in 'How we are
making the difference'.
Information on the members of the Management Board Banking
Reference is made to the Our leadership section for information on the members of the Management Board
Banking, which information is deemed incorporated by reference.
Supervisory Board composition
ING aims to have an adequate and balanced composition of its Supervisory Board, 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

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> Corporate governance
ING Bank Annual Report 2022 47
in which such companies operate. In the selection of Supervisory Board members, ING strives for a balance
in nationality, gender, age, and educational and work background. In addition, there should be a balance in
the experience and affinity with the nature and culture of the business of ING.
The Supervisory Board is responsible for selecting and nominating candidates for appointment or
reappointment to the Supervisory Board, among others based on the Supervisory Board profile, which is
available on ing.com. The Supervisory Board regularly assesses the composition of the Supervisory Board.
In 2022, three out of nine members of the Supervisory Board were female. We believe the Supervisory Board
is well-balanced in terms of other relevant diversity aspects. Overall, the preferred emphasis on members
with a financial or banking background has been maintained. In terms of nationality, the ratio between
Dutch and non-Dutch nationalities in 2022 was 56 - 44%.
According to the Gender Diversity Act, which came into force in the Netherlands on 1 January 2022, ING is
required to comply with a gender diversity quota of one third male and one third female for its Supervisory
Board. Over the year 2022, the Supervisory Board was compliant.
Relevant positions pursuant to CRD IV
Members of the Supervisory Board may hold other positions, including directorships, either paid
or unpaid. The Capital Requirements Directive 4 (CRD IV) restricts the total number of supervisory board
positions or non-executive directorships with commercial organisations that may be held by a Supervisory
Board member to four, or to two, if the Supervisory Board member also has an executive board position. The
ECB may, under special circumstances, permit a Supervisory Board member to fulfil an additional
supervisory board position or non-executive directorship. Positions with, inter alia, subsidiaries or qualified
holdings are not taken into account in the application of these restrictions. Such positions may not conflict
with the interests of ING Bank. It is the responsibility of the individual member of the Supervisory Board and
the Supervisory Board collectively to ensure that the directorship duties are performed properly and are not
affected by any other positions that the individual may hold outside ING Bank.
Information on the members of the Supervisory Board
Reference is made to the Our leadership section for information on the members of the Supervisory Board,
which information is deemed incorporated by reference. Also read more about the composition and duties
of the Supervisory Board and its committees in the Supervisory Board report and on ing.com.

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> Corporate governance
ING Bank Annual Report 2022 48
Conformity statement
The Management Board Banking is required to prepare the Financial statements and the Annual Report of
ING Bank N.V. for each financial year in accordance with applicable Dutch law and those International
Financial Reporting Standards (IFRS) that were endorsed by the European Union.
Conformity statement pursuant to section 5:25c paragraph 2(c) of the Dutch Financial Supervision Act (Wet
op het financieel toezicht).
The Management Board Banking is responsible for maintaining proper accounting records, for safeguarding
assets and for taking reasonable steps to prevent and detect fraud and other irregularities. It is responsible
for selecting suitable accounting policies and applying them on a consistent basis, making judgements and
estimates that are prudent and reasonable. It is also responsible for establishing and maintaining internal
procedures which ensure that all major financial information is known to the Management Board Banking,
so that the timeliness, completeness and correctness of the external financial reporting are assured.
As required by section 5:25c paragraph 2(c) of the Dutch Financial Supervision Act, each of the signatories
hereby confirms that to the best of his knowledge:
•the ING Bank N.V. 2022 Financial statements give a true and fair view of the assets, liabilities, financial
position and profit or loss of ING Bank N.V. and the enterprises included in the consolidation taken as a
whole; and
•the ING Bank N.V. 2022 Annual Report gives a true and fair view of the position at the balance sheet date,
the development and performance of the business during the financial year 2022 of ING Bank N.V. and
the enterprises included in the consolidation taken as a whole, together with a description of the
principal risks ING Bank N.V. is being confronted with.
Amsterdam, 6 March 2023
The Management Board Banking
S.J.A. (Steven) van Rijswijk
CEO, chairman of the Management Board Banking
T. (Tanate) Phutrakul
CFO
L. (Ljiljana) Čortan
CRO
P. (Pinar) Abay
Head of Market Leaders
A.J.M. (Andrew) Bester
Head of Wholesale Banking
A. (Aris) Bogdaneris
Head of Retail Banking
Head of Challengers & Growth Markets
R.H.E. (Ron) van Kemenade
Chief technology officer
M.A. (Marnix) Stiphout
Chief operations officer / Chief transformation officer

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> Conformity statement
ING Bank Annual Report 2022 49
Risk management
The war in Ukraine had, besides an immense impact on the lives of
millions of people, a negative impact on the global economy. While
businesses and households were still recovering from the economic
consequences of Covid-19, developments in Ukraine further distorted
supply chains, caused higher energy costs and aggravated an already
high inflation rate environment. This, in combination with central bank
rate hikes, worsened the macroeconomic outlook. This section explains
ING’s approach towards 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 risks 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 its risk appetite is core to ING’s
business.
The risk management function supports the EB in formulating the risk appetite, strategies, policies and
limits. It provides adequate steering, oversight, challenge and controls throughout ING on risk-related items.
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’ model. It describes the
key risks that arise from ING’s business model and how these are managed by dedicated risk management
departments, with various specific areas of expertise. The section provides qualitative and quantitative
disclosures on solvency, credit, market, funding and liquidity, ESG, operational, IT, compliance, business and
model risks.
Risk categories
ING’s main risks are described in the categories below. Chapters in the risk management section are based
on how risks are managed internally. Operational and IT risks are part of the Non-financial risk (NFR)
chapter.

Overview of risk categories
Risk categories | Sub-categories | Defined as: |
Financial risk | Solvency risk | The risk of lacking sufficient capital to fulfil business objectives, regulatory requirements or market expectations. A bank that is completely insolvent is unable to pay its debts and will be forced into bankruptcy.
Credit risk | The risk of potential loss due to default by ING’s debtors (including bond issuers) or trading counterparties.
Market risk | The risk of potential loss due to adverse movements in market variables.
Funding and liquidity risk | The risk that ING cannot meet financial liabilities when they become due at reasonable costs and in a timely manner.
Non-financial risks | Operational risk | The risk of direct or indirect loss arising from inadequate or failed internal processes, people and systems or from external events.
Information (Technology) risk | The risk of financial loss, regulatory sanction and/or reputational damage due to ineffectively utilising information, or inappropriately protecting information.
Compliance risk | A threat posed to ING’s standing resulting from failure to act in line with applicable laws and regulations, internal rules (including ING’s Orange Code and global Code of Conduct) and/or societal expectations.
Overarching risks | ESG risk | The risk of losses arising from any negative financial impact on the institution stemming from the current or prospective impacts of environmental, social or governance factors on the institution’s counterparties or invested assets
Business risk | The value or earnings loss due to business and strategic decisions that do not materialise as planned. This risk can be expressed in terms of volumes, margins, expenses and fees and commissions.
Model risk | The risk that the financial or reputational position of ING is negatively impacted as a consequence of the use of models. Model risk can arise from errors in the development, implementation, use or interpretation of models, or from incomplete or wrong data etc., leading to inaccurate, non-compliant or misinterpreted model outputs.

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> Risk Management
ING Bank Annual Report 2022 50

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 ING Bank Consolidated financial statements and are indicated by the symbol (*). This is applicable for the chapters, paragraphs, graphs or tables within the risk management section that are indicated with this symbol in the respective headings or table header. This risk management section also includes additional disclosures beyond those required by IFRS standards, 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 to the accounting basis of measurement. Examples of such differences include the exclusion of accrued interest and certain costs and fees from risk data, and timing differences in exposure values (IFRS 9 models report expected credit loss on underlying exposures). Disclosures in accordance with Part Eight of the CRR2 and CRD V, 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 existing and emerging risks which could cause actual results to differ, in
some instances materially, from those anticipated. They may have a material impact on the reputation of
the company, introduce volatility in future operating results or impact ING’s medium and long-term
strategy including the ability to pay dividends, maintain appropriate levels of capital or meet liquidity and
funding targets. An emerging risk is defined as a risk that has the potential to have a significant negative
effect on our performance, but where the impact on the organisation is currently more difficult to assess
than other risk factors. These risks are on top of other existing risks.
The topics have mainly emerged as part of the annual risk assessment that feeds into, among others, the
annual review of the Stress Testing Framework and the Risk Appetite Framework. The sequence in which the
risks are presented below is not indicative of their likelihood of occurrence or the potential magnitude of
their financial consequences.
The 2022 risk assessment confirmed our top and emerging risks. The top risks in 2022 are related to
geopolitical risk, financial crime, cybercrime and inflation risk. Climate change risk remains an emerging risk,
and reflects the impact that climate change may have on the financial position and/or reputation of ING.
Geopolitical risk
This risk has obviously increased since the early start of 2022, mainly following the war in Ukraine and
subsequent threats by Russia to limit or cut gas exports. Besides Russia's war in Ukraine, tensions between
the US and China relating to Taiwan and trade issues have persisted this year.
The war in Ukraine
The war in Ukraine and rapidly escalating events in 2022 were, and still are, a significant tragedy to the
people, causing disruption to business and economic activity in the region and worldwide. Subsequently, the
US, the UK and the EU initiated sanctions against Russia in 2022. In response, the Russian central bank
enforced liquidity and currency controls. The uncertainty about the outcome of the war will remain in the
longer term.
Sanctions
The international community leveraged their sanction tools in response to the war in Ukraine. Accordingly,
as part of ING’s KYC 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. For sanctions-
related developments, more information is in ‘Compliance risk’.
Our exposures
ING has Wholesale Banking activities in both Russia and Ukraine, as well as investments in Russia, some of
which are denominated in local currency. Investments in Russia are in government securities as required by
a subsidiary under Russian law. As a result of the war in Ukraine and related international response
measures, including sanctions and capital controls, we face an increased risk of default of counterparties
located in Russia and Ukraine. These include counterparties the ultimate parent of which is located in Russia,
which may be considered effectively controlled or influenced through Russian involvement, and other
counterparties in sectors affected by the international response measures. Furthermore, we have
counterparty exposure to Russian entities in connection with foreign exchange derivatives for future receipt
of foreign currencies against the Russian rouble.
Remaining at risk for ING at year-end 2022 is €0.3 billion local equity and €2.5 billion credit exposures
booked outside of Russia. In Ukraine, our exposure was approximately €500 million, mainly with liquidity
facilities and other lending. Early in March 2022, we intensified monitoring of counterparties, continued
managing our exposure and announced a decision to not do new Russia-related business.
The Russian and Ukrainian exposures are under continuous monitoring. Uncertainties on the evolution of
the conflict will remain for some time to come. Since the start of the war, business and risk departments
have worked on several sensitivity analyses and stress tests to assess the potential downside impact of the

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ING Bank Annual Report 2022 51
war, and the potential second order and stagflation impact in 2022. Furthermore, we are working together
with counterparties, both onshore and offshore, to limit risks associated with derivatives exposures.
Financial crime risk
We’re committed to fulfilling our role as a gatekeeper to the financial system, to protect customers, society
and our bank from the corrosive effects of financial crimes such as money laundering, terrorist financing,
bribery and corruption, sanctions evasion and tax offences. It’s our intention to not just comply with
applicable laws and regulations in relation to financial crime, but also to continue to strengthen our financial
crime control framework in a robust and sustainable way to prevent, detect and respond to illicit activity.
We continue to seek to harness new and innovative technological capabilities to create a safer environment
for customers, our bank and society. In 2022, we further adjusted our financial crime risk appetite and
framework of policies and procedures to reflect changes in the risk environment and responded to external
developments.
We also sought to further empower our people with the skills and knowledge to fight financial crime, sharing
insights with them about emerging and evolving threats (including in relation to financial crime risks linked
to or heightened by the Covid-19 pandemic) and enhancing our training framework.
Fighting financial crime and protecting the integrity of the financial system is a challenge for all banks, given
the constantly changing environment and pace at which criminals evolve their methods. We believe we can
be more effective in our efforts if we collectively join forces and share intelligence with other banks and with
national, European and international authorities and law enforcement to combat financial crime. We
therefore continue to proactively participate in public-private partnerships, such as Transaction Monitoring
Netherlands and Germany’s Anti-Financial Crime Alliance, and to collaborate with other banks. Read more in
‘How we are making the difference’ and ‘Compliance risk’.
Cybercrime
Cybercrime remains a continuous threat to companies in general and to financial institutions in particular.
Both the frequency and the intensity of attacks are increasing on a global scale. The sophistication and
implications of ransomware attacks are a growing concern.
Continuous enhancement of the control environment to protect from, and detect and respond to, e-banking
fraud, DDoS, targeted attacks and more specific ransomware attacks remains one of the highest priorities.
Additional 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. In addition, ING continues to
strengthen its global cybercrime and fraud resilience through extensive collaboration across the globe with
financial industry peers, law enforcement authorities, government (e.g. National Cybersecurity Centre) and
Internet Service Providers (ISPs). See also ‘How we are making the difference’ and ‘Non-financial risk’.
Inflation risk
Inflation rates accelerated across the globe at the beginning of 2022, fuelled by the Russian invasion of
Ukraine. Inflationary pressures prompted an adjustment of monetary policy stances by major central banks,
leading to rising interest rates and tighter global financial conditions.
The mix of high inflation and rising interest rates further deteriorated macro-financial conditions,
aggravating pre-existing vulnerabilities for both businesses and households, which were recovering from the
economic consequences of the Covid-19 pandemic, and ultimately increasing banks’ credit risk. Against this
background, ING has taken additional provisions already in the course of 2022.
EU member states' governments have introduced several supporting measures to cushion the rise in energy
prices and inflation. These measures, in conjunction with the reduced fiscal space resulting from the
pandemic-related support measures and the normalisation of the monetary policy stance, increased
sovereign vulnerabilities in financially weaker countries.
Climate change risk
ING is aware of the risks associated with climate change and how these can impact customers and their
financial health. This includes physical risk and transition risk. Physical risk can be acute, such as flood and
wildfires, or chronic, such as increased temperature and rising sea levels. Transition risk can be driven by
policy, technological or market changes as we shift towards a low-carbon global economy and potentially
lead to stranded assets.
An internal programme was launched in 2020 to address impacts resulting from climate change. In March
2022, ING updated its governance approach to embrace ESG holistically in business strategy. An ESG
Committee was created at Supervisory Board level, responsible for supervising the bank’s overall ESG
transformation and advising the MBB on relevant ESG developments. ING also established an ESG Sounding
Board comprised of senior leaders to guide the development and implementation of our strategy for ESG
topics, as well as monitoring and reporting on progress. All ESG-related key performance indicators are
assigned to MBB members and cascaded down through business lines. Further, after a strategic review of
ING’s CRO function, an ESG Risk Centre of Expertise, part of the Integrated Risk department, has been
established. Our 2022 Climate Report on ing.com details our approach and sector-specific insights. See the
‘Sustainability’ section of ing.com for more on climate change.

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> Risk Management
ING Bank Annual Report 2022 52
Risk governance (*)
Effective risk management requires company-wide risk governance. ING’s risk and control structure is based
on the ‘three lines of defence’ governance model. 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 MBB, the EB and the SB, and this approach is cascaded throughout ING.
The heads of ING’s banking business and support functions and the heads of the country units, or their
delegates, are the first line of defence. They have primary ownership, and accountability and responsibility
for assessing, controlling and mitigating all financial and non-financial risks affecting their businesses, as
well as for the completeness and accuracy of the financial statements and risk reports with respect to their
areas of responsibility. The CTO is responsible and accountable for proper security and controls of global
applications and IT platforms servicing the bank and implementing proper processes. The COO domain
builds bridges within ING linking to almost every part of the bank. Its purpose is to drive secure and efficient
processes for customers and colleagues.
The second line of defence consists of oversight and specialised functions in risk management and
compliance. They (1) have co-responsibility for risk management, through articulating and translating the
risk appetite into methodologies and policies to support and monitor business management's control of risk,
(2) objectively challenge risk management execution and control processes and coordinate the reporting of
risks and controls by the first line of defence, (3) advise on risk management and compliance and have
decision-making power in relation to business activities that are judged to present unacceptable risks to ING
and (4) can set minimum requirements in terms of quality and quantity of global resourcing in the risk
management and compliance functions.
The internal audit function forms the third line of defence. It provides independent assurance to the Audit
Committee, the EB and the MBB 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. To
protect its independent nature, decisions regarding the appointment, reappointment or dismissal from
office as well as the remuneration package of the head of the internal audit function require SB approval.
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.
•The SB is, for risk management purposes, advised mainly by the Risk Committee, which assists and
advises in monitoring the risk profile and approving the overarching risk appetite of the company as well
as the structure and effective operation of the internal risk management and control systems.
•The EB is responsible for managing risks associated with all activities of ING Group, whereas the MBB is
responsible for managing risks associated with all activities of ING Bank. The EB and MBB responsibilities
include ensuring that internal risk management and control systems are effective and that ING Group
and ING Bank comply with relevant legislation and regulations. On a regular basis, the EB and MBB report
on these issues and discuss the internal risk management and control systems with the SB. On a
quarterly basis, the EB and MBB report on ING’s risk profile versus its risk appetite to the Risk Committee,
explaining changes in the risk profile.
As a member of the EB and the MBB, the CRO is primarily responsible for: (i) supporting the board in its
engagement with and oversight of the development of the risk appetite and risk appetite statements and
for translating the risk appetite into a risk limits structure, actively engaged in monitoring performance
relative to risk-taking and risk limit adherence; (ii) setting up the risk management framework and
overseeing the development and implementation of risk and compliance policies, processes, models,
compatible methodologies including both forward-looking and backward-looking tools, ongoing
strengthening of risk management/people capabilities and reports, as necessary to ensure the effectiveness
of robust internal control and risk systems to fully support its strategic objectives and all of its risk-taking
activities; (iii) regularly providing comprehensive information on risks to the Management Board, the Risk
Committee and other relevant functions; and (iv) advising about the current risk profile, current state of the
risk culture, utilisation against the established risk appetite, and limits, limit breaches and mitigation plans.
For more on the SB and EB roles and responsibilities see ‘Corporate Governance’.
Executive level (*)
The risk committees described below act within the overall risk policy and delegated authorities granted by
the MBB:
•Global Credit and Trading Policy Committee (GCTP) discusses and approves policies, methodologies, and
procedures related to credit, trading, country, and reputation (i.e. environmental and social risk or ESR)
risks. The GCTP meets monthly. After the MBB and the GCTP, the Credit and Trading Risk Committee
(CTRC) is the highest-level body authorised to discuss and approve policies, methodologies, and
procedures related to credit and trading risk.

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•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. The
GCC(TA) meets twice a week.
•Non-Financial Risk Committee Bank (NFRC Bank) 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, measurement, mitigating and monitoring/
reporting. NFRC Bank meetings are held at least quarterly.
•The Model Risk Management Committee (MoRMC) discusses and steers, on a monthly basis, the overall
model strategy. MoRMC discusses and approves policies and methodologies related to model risk
management.
•Global Data Committee (GDC) oversees (identifies, measures, responds to change and monitors) the
Global Data function and its contribution to wider society. The GDC meets every two months.
Further, in the Asset and Liability Committee Bank (ALCO Bank) risk related topics are discussed as well.
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.
The regional and/or business unit (BU) head of risk are involved in these activities. The local (regional and BU)
head of risk is responsible for the analysis, monitoring and management of risks across the whole value
chain (from front to back office). The local risks are discussed in local risk committees that roll up to the key
risk committees at executive level. Local Client Integrity Risk Committees (CIRCs) assess client integrity risk
and they have a final decision on client acceptance or client off-boarding, from a risk-based perspective, in
the areas of financial crime, Foreign Account Tax Compliance Act (FATCA), Common Reporting Standard
(CRS) and ESR.
Organisational structure (*)
The Risk CRO function is organised along the lines of a matrix structure integrating (1) the Global Risk
functions, (2) the Regional/Country Risk functions at entity level, and (3) the Risk Segments, with a uniform
methodology and terminology, so that a holistic view of all risks is ensured. 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, ensuring a uniform taxonomy and methodology is 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 following organisation chart illustrates the reporting lines in 2022 for the risk management
organisation. The fixed lines reflect hierarchical reporting lines, whereas the dotted lines are for the
functional reporting lines:

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Risk policies, procedures and standards (*)
ING has a framework of risk management policies, procedures, and minimum standards in place to create
consistency throughout the organisation, and to define requirements that are binding for all business units.
The goal of the governance framework of the local business units is to align with ING’s framework and to
meet local (regulatory) requirements. Senior management is responsible for the implementation of and
adherence to policies, procedures and standards. Policies, procedures and standards are regularly reviewed
and updated via the relevant risk committees to reflect changes in requirements, markets, products and
practices.
Internal control framework
In its Enterprise Risk Management (ERM) Framework, ING explains its approach to mitigating risk outside
ING’s risk appetite. The internal control framework (ICF) translates regulations and internal requirements
into policies articulating specific risks and control objectives. These policies form the basis for translation into
process control standards, which are used by the business to support and promote an effective risk and
control environment. The ICF includes binding principles, definitions, process steps, and roles and
responsibilities to create consistent bank-wide policies and control standards.
Global policies and control standards are developed and maintained or updated within the ICF. These global
documents are designed by head-office functions and are to be adhered to by all ING entities and support
functions. In line with the ERM approach, ownership for policies will be with the second line of defence (2nd
LoD), while control standards are to be owned by the first line of defence (1st LoD). Global policy and control
standard documents are approved by relevant approval bodies (e.g. SB, EB, MBB and NFRC Bank).
The policies are based on the risk taxonomy, which is designed to prevent overlaps in policy control
objectives. The control standard owners are responsible for defining the key controls that mitigate the
critical and high inherent risks in the business processes.
The process of developing policy and process control standard documents includes the following steps:
identify the document owner, determine the relevant stakeholders, define a risk-based approach, perform
an impact assessment, involve relevant stakeholders and (local) entities for sounding on key and expected
controls, and determine an approval body.
The principal role of the gatekeepers is to provide quality assurance and to advise on the relevant approval
bodies. The ICF gatekeepers challenge document owners on the alignment of internal control documents
with the agreed methodology and risk taxonomy, and verify that the development and communication of
those documents are in line with the agreed process. All policies, control standards, and procedures are
published on ING’s intranet. New and updated documents are periodically communicated by means of a
dedicated policy update bulletin to the country managers and senior heads of business departments.
Risk culture
At ING, we attach great importance to a sound risk culture, which is essential for performing our role in
society responsibly and to keep the bank safe, secure and compliant. Our risk culture determines the way in
which employees identify, understand, discuss, and act on the risks we are confronted with and the risks we
take. In 2022, we continued to drive several enhancement projects based on our 2020 assessment of our
risk culture. Most notably, enhancing our risk culture monitoring activities and bringing non-financial risk to
life. Furthermore, in 2022 we also handed over the responsibility of developing and maintaining the risk
culture maturity model and risk culture monitoring dashboard to the Risk Culture & Behavioural Risk
department.
Orange Code and the global Code of Conduct
The Orange Code and the global Code of Conduct are the foundation of ING’s risk culture. The global Code of
Conduct defines the most essential conduct principles expected from ING employees in their daily activities,
to create additional risk awareness and better meet expectations stated in external rules and guidelines.
ING employees are required to take an annual e-learning and attest to their adherence to the global Code of
Conduct. In 2021, the global Code of Conduct was embedded into our employees’ performance
management cycle with the aim ensuring continuous attention to the Global Code of Conduct, and dialogue
on how to apply it in our daily work practice.
The Orange Code is a declaration of who we are. It 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 is the sum of two parts, the ING values and ING behaviours, with integrity being the
overarching principle. The ING values (being honest, prudent and responsible) are non-negotiable promises
we make to the world, principles we seek to stick to, no matter what. The ING behaviours (take it on and
make it happen, help others to be successful, and always be a step ahead) represent our way to
differentiate ourselves. The Orange Code is embedded in commitments we make to each other and the
standards by which we measure each other’s performance.
Orange Code decision-making
To enhance risk awareness, we continued to support monitoring risk culture and compliance risk in the
business. This included training by the experts of the newly created Risk Culture & Behavioural Risk (RC&BR)
department, as well as by local compliance experts and data ethics experts with the goal of enhancing
balanced decision-making in line with the Orange Code decision-making model. This four-step model
supports moral learning and well-balanced decision-making.

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Following the initial incorporation of the model in the global Product Approval and Review Process (PARP)
policy in 2020, it was further improved in the updated global PARP of 2022. ING's PARP takes an objective,
helicopter-view to safeguard the long-term customer's interest (societal developments, changing customer
behaviour, life-events and so on) when manufacturing and/or distributing a product. The RC&BR department
is continuing to train experts in this area within the local Compliance teams to support the organisation in
properly applying the model in practice in their respective countries.
Learning
In 2022, we continued to expand and strengthen our required learning curriculum. This is foundational
learning that is centrally created and rolled out to all staff across the bank. The focus in 2022 was on
cybersecurity, fraud and KYC. Formats for our learning continue to be updated to increase engagement and
to drive practical application of the knowledge gained by staff. The curriculum is tracked centrally to
monitor timely completion.
We have expanded our learning for risk professionals, with the Risk Academy providing a range of learning
for Risk staff to support their professional development. These take the form of a comprehensive offering of
learning modules and learning channels that support employees in developing their knowledge, skills and
behaviours.
Dutch Banker’s Oath
In the Netherlands, all employees are required to take the Bankers’ Oath and pledge this promise in a
meaningful ceremony. The Oath came into force in the Netherlands on 1 April 2015, as part of a joint
approach from all banks, aimed at introducing social regulations, a revised Dutch Banking Code
implementing an oath with associated rules of conduct and disciplinary law. This way, Dutch banks show
society what they stand for and are accountable for, both as individual banks and as a sector. In 2021, due
to the Covid-19 pandemic, ING in the Netherlands held virtual Bankers’ Oath ceremonies, instead of physical
ones, to allow new employees (around 400 a month) to still take the Oath on time and in a meaningful
ceremony. This was continued throughout 2022. Before taking the Oath, an e-learning is provided and the
importance of the Oath is discussed. Also, dilemmas that the employees may come across in their daily
work are shown, aimed at ensuring careful balancing of the interests of all our stakeholders, in the decisions
we make. In 2020 and 2021 the whole Bankers’ Oath programme for new joiners was revised and updated,
to ensure that all elements still align with current developments, both internally and externally.
Remuneration
ING aims to align its remuneration policy with its risk profile and the interests of all stakeholders. For more
information on ING’s compensation and benefits policies and its relation to the risk taken, go to the Capital
Requirements Regulation (CRR) Remuneration Disclosure published on ing.com.
Risk Culture & Behavioural Risk department (RC&BR)
In March 2022, the Behavioural Risk department, the Risk Academy and Culture & Ethics department were
combined to form a new Centre of Expertise for Risk Culture & Behavioural Risk, reporting directly to the
CRO. The aim of the department is to provide a clear vision, aligned strategy and sound methodological
approach to identify, assess and bring change to the way employees act on risks.
Behavioural risk
Behavioural risk is an increasingly important risk 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 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 the standard across ING to signal behavioural
risks going forward. In 2022, behavioural risk assessments were carried out and focused on the topic of
escalation behaviour.
Behavioural risk interventions
Based on the results of the executed behavioural risk assessments, the behavioural risk intervention team
mitigates behavioural risk in a focused manner. Effective mitigation requires a deep understanding of what
drives undesired behaviours. Behavioural and organisational science theories and evidence-based
techniques and tools play an important role in designing and facilitating interventions.
In 2022, the intervention team worked on several intervention plans. Together with Global KYC, the
intervention team followed up on the previously held 'KYC World Cafe' – a large group change activity that
drives common understanding, engagement and ownership and enhances learning and behavioural
change, specifically designed for the KYC community. Another example that the team worked on in 2022 is
the development and execution of new interventions that have been designed to improve speak-up and
escalation behaviour in certain parts of the organisation.

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The behavioural risk assessment and intervention team works closely with the business units and
departments such as HR, Compliance and Internal Audit to align on and embed desired leadership and risk
behaviours (i.e. speak up, psychological safety, communication, guiding leadership).
Risk Culture programme
Throughout 2021 and 2022, ING executed the risk culture programme that was developed based on the
2020 self-assessment. The emphasis in 2022 was on further evolving the risk culture dashboard as well as
facilitating meaningful conversations on risk culture throughout the organisation. Risk culture is actively
discussed by the MBB and the SB on a quarterly basis.
Risk cycle process
ING uses a step-by-step risk management approach to identify, manage and mitigate financial and non-
financial risks. The approach consists of a cycle of five recurrent activities: risk identification, risk assessment,
risk control, risk monitoring, and risk reporting. The cycle is designed to determine what the risks are, assess
which of these can really do harm, take mitigating measures to control these risks, monitor the
development of the risk to see if the measures taken are effective, and report the findings to management
at all relevant levels to enable them to take action when needed.
The cycle recurs in two ways. First, the identification, assessment, review, and update of mitigating
measures are repeated periodically. Second, this periodic monitoring exercise may indicate emerging risks,
known risks that are changing, risk levels that are changing, or current control measures that are not
effective enough. Further analyses of these findings may then result in renewed and more frequent risk
identification, and/or assessment, and/or change of mitigating measures.
Risk identification
Risk identification is a joint effort of the business and the risk management functions. Its goal is to detect
potential new risks and determine changes in known risks. Regular risk identification is essential for effective
risk management. Potential risks that are not identified, will not be controlled and monitored and may lead
to surprises later. Known risks may have changed over time and as a consequence the existing mitigating
measures and monitoring may be inadequate or obsolete.
Risk identification is performed periodically. In case of material internal or external change, additional ad
hoc risk identification can be performed.
Risk assessment
Each identified risk is assessed qualitatively or quantitatively to determine its importance. This enables ING
to decide which of the identified risks need control measures and how strict or tolerant these measures
should be. Known risks are reassessed to detect any change in the risk level.
The importance of a risk is based on both the likelihood that the risk materialises and the subsequent
financial or reputational impact that may occur should the risk arise. Unlikely risks with a potentially high
impact need to be controlled. A risk that is likely to happen regularly but expected to have a modest
financial impact may not need to be mitigated if the consequences are accepted by management.
Risk control
Risks can be controlled by mitigating measures that lower the likelihood the risk occurs, lower the impact
when it occurs or both. The ultimate measure to lower a risk is to stop the activity or service that causes the
risk (risk avoidance). Risk control and mitigation measures are defined and maintained both bank-wide and
at the local level.
Monitoring and reporting
ING monitors risk-control measures by checking if they are executed, complied with and have the expected
mitigating effects and by following the development of the risks and their risk levels. Risk reporting provides
senior and local management with the information they need to manage risks.
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.
Policy
The RAF policy explains the setup of the overarching global risk appetite. Within the RAF, ING monitors a
range of financial and non-financial risk metrics with an aim to keep our risk profile 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 assumptions and metrics, is regularly reviewed so that it remains relevant. The RAF
combines various financial and non-financial risk appetite statements (RAS) into a single, coordinated
approach to provide the business with a clear overview of the relevant risks and the tools to manage them.

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This view allows the EB, the MBB and senior management to form an opinion on the adequacy of internal
risk management and control systems for the risks ING faces while pursuing its strategy.
Process
The RAF is focused on setting the risk appetite at the consolidated level and across the different risk
categories, and provides the principles for cascading this risk appetite down into the organisation. The RAF
and underlying limit allocation are reviewed on an annual basis, or more frequently if necessary, based on
their quarterly review in the MBB, 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 need SB approval are called boundaries and the underlying metrics supporting the boundaries
which need EB and MBB approval are called instruments.
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 within ING’s
risk management function. It benchmarks the current risk framework against regulatory developments.
Known risks are re-assessed either to confirm risk levels or to take account of potential changes. The
assessment is executed following the current set of risk appetite statements.
Step 2. Set Risk Appetite Framework
Based on ING’s risk assessment and risk purpose, boundaries for the overarching risk frameworks are set.
Once the overarching risk appetite thresholds have been set and approved by EB/MBB and subsequently by
SB, the statements are translated into risk-type-specific statements and lower-level thresholds which are
set and approved by senior risk committees, like ALCO Bank, GCTP and Bank NFRC. Cascading is done via
several detailed risk appetite statements which have been defined per risk type, the combination of which is
aimed to ensure compliance with the overarching solvency, concentration and funding and liquidity RASs.
Examples of underlying risk metrics include:
•Solvency and profitability (e.g. CET1 ratio, MREL ratio and earnings at risk).
•Funding and liquidity (e.g. liquidity coverage ratio (LCR) and net stable funding ratio (NSFR)).
•Credit risk (e.g. exposure at default (EAD) and risk weighted assets (RWA)).
•Market risk trading book (e.g. event risk, historical value at risk (HVaR)).
•Market risk banking book (e.g. net interest income (NII) at risk and revaluation reserve at risk).
•Non-financial risk (e.g. capital-at-risk and management of audit issues).
•Compliance risk (e.g. key risk indicators on fraud management and sourcing).
•Business risk (e.g. economic capital).
•Model risk (e.g. number of inadequate pillar 1 models).
ING has started including 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 with the aim of
ensuring that the potential risks stemming from e.g. transition risk and physical risk are properly captured in
the RAF.
Step 3. Cascade into statements per risk type and business unit
The bank-wide risk appetite is translated 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.

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Step 4. Monitor and manage underlying risk limits
To verify that it remains within the RAF, ING reports its risk positions vis-à-vis its limits on a regular basis to
senior management committees. The quarterly risk update reflecting the exposure of ING against the risk
appetite is submitted quarterly to the MBB, the EB and the SB and its Risk Committee. Moreover, every
quarter the financial plan is checked 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 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. Since the outbreak of the Russia/Ukraine war,
ING assessed the potential impact on its financial position via different types of stress tests. In addition to
assessing P&L, capital and liquidity positions of ING for a range of different scenarios, idiosyncratic risks were
also included. The outcome of these stress tests helped management get insight into the potential impact
and define actions to mitigate this potential impact.
In the first half of 2022, ING executed the regulatory climate risks stress-test scenario, which is a part of the
biannual ECB Single Supervisory Mechanism (SSM) stress test. This regulatory stress test, combined with
internal analyses done on climate risk, is used for enhancing ING’s internal climate risk stress testing. In the
last quarter of 2022, ING has introduced a 'Climate Risk with Geopolitical Angle scenario', which will be
reported quarterly together with the other standard scenarios.
Types of stress tests
Within ING, different types of stress tests are performed. 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 pre-defined severe adverse outcome.

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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
determined in the previous step, 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.
•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 calculate the impact of the scenarios. In these models,
statistical analysis is combined with expert opinion to make sure that the results adequately reflect the
scenario assumptions. The methodologies are granular and portfolio-specific and use different
macroeconomic and market variables as input variables. The calculations are in line with our financial and
regulatory reporting frameworks. The stress-testing models are subject to review by Model Risk
Management.

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Solvency risk
Introduction
Solvency risk is the risk of lacking sufficient capital to fulfil the business objectives, regulatory requirements
or market expectations. A bank that is insolvent 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 that all material risks are identified, managed
and covered sufficiently by loss-absorbing capital to ensure continuity in case of materialisation of
unexpected risks in times of stress. Given the interdependencies to other financial and non-financial risks,
this balancing act of capital adequacy needs to be done within a sound and integrated management
approach coherently linking all moving parts of the bank in line with the long-term business strategy.
Governance
Group Treasury (“GT”) Balance Sheet & Capital Management, is responsible for maintaining the adequate
capitalisation of ING Group and ING Bank entities, to manage the risk associated with ING’s business
activities. This involves not only managing, planning and allocating capital within ING Group, ING Bank and
its various entities, but also helping to execute necessary capital market transactions, term (capital) funding
and risk management transactions. ING takes an integrated approach to assess the adequacy of its capital
position in relation to its risk profile and operating environment. This means GT Balance Sheet & Capital
Management takes into account both regulatory and internal, economic based metrics and requirements as
well as the interests of key stakeholders such as shareholders and rating agencies.
ICAAP framework
ING’s Internal Capital Adequacy Assessment Processes (ICAAP) aims to ensure that capital levels remain
adequate both looking-forward and under adverse conditions in terms of covering material risks-to-capital
from both a normative and 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 do play an important role.
The continued strength of ING’s capital position, the adequacy of the financial position and risk
management effectiveness are essential for achieving the strategy. ING’s capital and funding strategy
determines the underlying ICAAP elements and thereby contributes to the business continuity of ING from
different perspectives.
Managing ING’s capital entails finding the right balance between supply and demand while taking into
account market and macro circumstances. The process of balancing these strategic goals is captured in the
ICAAP framework and 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, published in November 2018:
•Risk identification and assessment.
•Risk appetite.
•Solvency stress testing.
•Planning and forecasting.
•Capital management
•Continuity.
Risk identification and assessment
ING’s capital management and solvency risk management starts with the risk identification and risk
assessment process. Its main purpose is to detect potential new risks and to identify changes in the
potential impact of known risks. On an annual basis, ING performs a thorough review of its solvency risks or
risks to capital. Within this assessment, bottom-up assessments are combined with top-down assessments,
including a questionnaire and interviews with senior management. The results of the risk assessment are
discussed in ALCO Bank, which comprises almost the full MBB. Once approved, the conclusions of the risk
assessment feed into the annual review of the Risk Appetite Framework, the Stress Testing Framework and
the Economic Capital Framework. 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
As explained in the RAF section in the previous chapter, ING has established overarching solvency risk
boundaries. Boundaries are risk appetite statements that are essential for risk management activity, making
it of paramount importance to keep these boundaries within the defined level. The SB is responsible for
approving and monitoring the boundaries. These boundaries are complemented by a sequence of risk-type-
specific instruments (risk appetite statements). These underlying risk appetite statements are cascaded
down into the organisation and dedicated risk thresholds are set that are used for day-to-day monitoring
and management of ING’s risks. 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 and provides insight into which entities or portfolios are vulnerable to which type of risks

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or in which type of 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 that are
described in the overall section on stress testing.
ING distinguishes the following three types of stress test analysis:
•Sensitivity analysis: Assess the impact of a pre-defined shock in one or more risk drivers. The main
purpose of sensitivity analyses is to monitor the impact of this pre-defined (or standardised) shock over
time to get an understanding of how the risk profile of the bank has developed. In contrast with scenario
analyses, sensitivity analyses are built on a predefined set of shocks that don't necessarily relate to a
qualitative story line.
•Scenario analysis: Used to assess the impact of historical, statistical and/or hypothetical circumstances
on the financial position of ING. These stress tests often build on a qualitative scenario narrative and
reflect risk topics that are deemed relevant for ING given, for example, its business model or geographical
presence. To execute such a stress test, scenarios need to be determined that are dynamic and forward
looking and incorporate the occurrence of a string of events through time.
•Reverse stress testing: The purpose is to identify scenarios that could lead to a pre-defined outcome. This
could, for example, be a CET1 ratio or LCR to define the point at which the bank is considered not viable
anymore. The added value of reverse stress testing is to explore risk drivers and stress scenarios outside
the existing range.
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. Its objective is to inform and advise the management on the capital development and need of ING
Group and ING Bank, under base case and adverse scenarios. It describes how ING shall finance the expected
capital constraints taking into consideration growth projections, capital and risk evolution, macro and
market conditions, both under the normative and economic perspective. The capital and funding plan is
discussed and approved by ALCO Bank and updated at least twice a year. Within these updates, ING takes
account of recent market and risk developments and aims to ensure that capital planning adheres to the
solvency risk appetite set by the SB.
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 while 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 to 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. See also Note 47 ‘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 therefore set up a continuity (safety) net of contingency and recovery planning. As part of this, ING
set up ongoing monitoring of relevant indicators with the aim of awareness and preparedness to act pro-
actively 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.
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 triggering further management action
and 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 (CAS)
The CAS is ING Bank’s quarterly assessment of its capital adequacy and takes into account 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.
•The ability to meet internal and external requirements in the case of stressed events or should a risk
materialise.

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ING Bank Annual Report 2022 62
The CAS 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. On a quarterly basis
the CAS document is prepared. 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.
Capital developments
ING Bank’s capital ratios at the end of the year decreased compared to 2021 primarily due to higher risk-
weighted assets and as most of the net profit of the year with EUR 2.75 billion additional distributions were
up streamed to ING Group. Risk-weighted assets were mainly impacted by rating downgrades on Russia-
related exposure, currency movements, the implementation of EBA guidelines on the treatment of
structural FX positions and model impacts. Model impacts reflect the introduction of a risk-weight floor on
Dutch residential mortgages by the Dutch Central Bank as well as ongoing redevelopment of internal
models and EBA guidelines. ING continues to maintain a strong and high-quality capital level.
ING Bank paid EUR 3.5 billion of dividend to ING Group in relation to net profit and an additional EUR 2.75
billion for distribution to shareholders by the Group.
ING Bank N.V. has a CET1 ratio of 12.6% versus an overall CET1 requirement (including buffer requirements)
of 7.10%. The Bank’s Tier 1 ratio decreased from 16.5% to 14.5% compared to last year. The Banks’s Total
capital ratio decreased to 17.5%.

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ING Bank Annual Report 2022 63
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.
Governance (*)
ING’s credit risk strategy is to maintain an internationally diversified loan and bond portfolio, while avoiding
large risk concentrations. The emphasis is on managing business developments within the business lines by
means of a top-down risk appetite framework (RAF), which sets concentration limits for countries, individual
clients, sectors, products, secondary risk (collateral/guarantees) and investment activities. The aim is to
support relationship banking activities, while maintaining internal risk/reward guidelines and controls.
A new Credit Risk department was established in 2022. This department is responsible for setting the credit
risk strategy for ING and aims to ensure credit risk and credit restructuring are managed from an
overarching point of view rather than per business line. The head of Credit Risk is supported by the following
teams within this new department:
•Portfolio, Strategy & Governance team: responsible for setting up credit risk strategies and risk appetite
statements, performing analysis and monitoring of the credit risk position of ING, as well as setting and
maintaining the credit risk framework and policies.
•Credit Risk Control Unit: responsible for the design or selection, implementation, oversight and
performance of the rating systems.
•Global Credit Risk Restructuring: responsible for a safe, compliant and data driven credit loss process by
managing loan loss provisioning and finding solutions for business customers in financial difficulty. The
team focuses on management of the global loan loss provisioning, not only of individual WB provisions,
but also collective WB and Retail Banking provisions.
While the Credit Risk department has oversight of the Bank credit risk strategy and risk appetite across
Retail Banking risk and Wholesale Banking risk, the head of Retail/Rest of World (RoW) Risk and head of
Wholesale Banking Risk aim to ensure the management of the risk within these business lines. Also refer to
the Risk governance and organisational structure in the introductory section of the Risk management
chapter.
The credit risk function encompasses the following activities:
•Measuring, monitoring and managing credit risks in the bank’s portfolio, including the measures taken in
response to the war in Ukraine.
•Challenging and approving new and modified transactions and borrower reviews.
•Managing the levels of provisioning and risk costs, and advising on impairments.
•Providing consistent credit risk policies, systems and tools to manage the credit lifecycle of all activities.
Credit risk categories (*)
In the following table the different types of credit risk categories are described and a reconciliation with the
notes in the financial statements is also included:

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ING Bank Annual Report 2022 64

Reconciliation between credit risk categories and financial position (*)
Credit risk categories | Notes in the financial statements
Lending risk: is 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. | Note | 2 | Cash and balances with central banks
Note | 3 | Loans and advances to banks
Note | 4 | Financial assets at fair value through profit or loss
Note | 5 | Financial assets at fair value through other comprehensive income
Note | 7 | Loans and advances to customers
Note | 41 | Contingent liabilities and commitments
Investment risk: is 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. | Note | 4 | Financial assets at fair value through profit or loss
Note | 5 | Financial assets at fair value through other comprehensive income
Note | 6 | Securities at amortised cost
Money market risk: arises when ING places short-term deposits with a counterparty in to manage excess liquidity. In the event of a counterparty default, ING may lose the deposit placed. | Note | 2 | Cash and balances with central banks
Note | 3 | Loans and advances to banks
Note | 7 | Loans and advances to customers
Pre-settlement risk: 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). | Note | 4 | Financial assets at fair value through profit or loss
Note | 14 | Financial liabilities at fair value through profit or loss
Note | 40 | Offsetting financial assets and liabilities
Settlement risk: 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. | Note | 4 | Financial assets at fair value through profit or loss
Note | 11 | Other assets
Note | 14 | Financial liabilities at fair value through profit or loss
Note | 16 | Other liabilities

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 (RAF).
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 RAF. The credit risk appetite is expressed in
quantitative and qualitative measures. Having a credit risk appetite provides:
•Clarity about the credit risks that ING is prepared to assume, target setting and prudent risk
management.
•Consistent communication to different stakeholders.
•Guidelines on how to align reporting and monitoring tools with the organisational structure and strategy.
•Alignment of business strategies and key performance indicators of business units with ING’s credit risk
appetite through dynamic planning.
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 which ING takes, and the composition of the credit
portfolio, including its concentration and diversification objectives in relation to business lines, sectors and
products. The credit risk appetite framework has also been extended to embed climate risk elements. The
first steps towards introducing climate risk elements in the credit risk appetite framework were taken in
2022 and these are expected to further evolve and mature. The climate risk elements within the credit risk
appetite framework allow for more efficient steering of sector concentrations from a climate risk
perspective.
The credit risk appetite and 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 event 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 reviewed 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 and industry sector concentration: ING has an established credit concentration risk
framework to identify, measure and monitor single name concentration and industry sector
concentration (systemic risk). The same concept of boundaries and instruments is applicable.
•Product and secondary risk concentration: ING has established a concentration framework to identify,
measure and monitor product concentration and secondary risk.
•Scenarios and stress tests: Stress testing evaluates ING’s financial stability under severe, but plausible
stress scenarios, and supports decision-making that assures ING remains a going concern even after a

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ING Bank Annual Report 2022 65
severe event occurs. In addition to the bank-wide stress testing framework described above, ING
performs sensitivity analyses regularly to assess portfolio risks and concentrations.
•Product approvals: The product approval and review process (PARP) assesses and manages risks
associated with the introduction of new or modified products. Its goal is that sound due diligence is
performed by relevant stakeholders and the relevant risks (credit, operational, compliance, etc.) are
addressed appropriately.
•Strategy and risk appetite papers: These are detailed analyses of defined products and/or industries. The
papers include the identification of the major risk drivers and mitigants, the internal business mandate,
and propose the risk (including business) parameters – and potentially the maximum product and/or
portfolio limit - to support that business. A strategy and risk appetite paper is always prepared by the
front office responsible for the internal business mandate and requires an approval from the designated
approval authority. Strategy and risk appetite papers may also have geographical and/or business
limitations (e.g. local vs. global).
•Credit approval process: The purpose of the credit approval process is that individual transactions and the
risk associated with these transactions are assessed on a name-by-name basis. For each type of client
there is a dedicated process with credit risk managers specialised along the business lines of ING,
including the use of automated decision-making in certain cases. The credit approval process is
supported by a risk rating system and exposure monitoring system. Risk ratings are used to indicate a
client’s creditworthiness which translates into a probability of default. This is used as input to determine
the maximum risk appetite that ING has for a given type of client (reference benchmark). The
determination of the delegated authority (the amount that can be approved at various levels of the
organisation) is a function of the risk rating of the client and ING’s credit risk exposure on the client.
Where necessary, underwriting standards are reviewed and refined to limit the credit risk to portfolios
particularly sensitive to certain market circumstances, such as Covid-19 at the time, or currently in the
context of the deteriorating economic outlook.
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). Bank-wide, ING has
implemented approximately 100 credit risk models, for regulatory capital, economic capital and loan loss
provisioning purposes.
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 contain characteristics of statistical models combined 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 ‘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/CRDIV, 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 scale (1 = highest rating; 22 = lowest 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 grades are composed of the following categories:
•Investment grade (risk rating 1-10).
•Non-investment grade (risk rating 11-17).
•Sub-standard (risk rating 18-19).
•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, local 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 enterprise (SME) in the Netherlands, Belgium, 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 manual input, with the ratings being manually updated at least annually.

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ING Bank Annual Report 2022 66
More frequent reviews (e.g. quarterly) are performed where considered necessary, for example portfolios
and clients most at risk of being impacted by the Russian invasion of Ukraine and expected spillover effects.
After the introduction of IFRS 9 in 2018 and especially with the introduction of new regulations, including the
new definition of default (DoD) in 2020, ING has also embarked on multi-year redevelopments of its credit
risk models.
Credit risk systems
Credit risk tools and data standards
The acceptance, maintenance, measurement, management and reporting of credit risks at all levels of ING
is 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 credit risk tools centrally with
the philosophy of using a single source of data in an integrated way. This includes applying a combination
of the ING policy, the regulatory environment in which we operate and the daily processes that are active
throughout the Bank. Disciplined application in these three areas is essential for achieving high data quality
standards.
The Credit Risk Control Unit (CRCU), which is part of the Credit Risk department, manages the CRCU control
framework offering quality assurance on the regulatory areas of responsibility: the design or selection,
implementation, oversight, and performance of the rating systems. This framework leans on control
execution in other teams such as Model Development in Integrated Risk where the combination of these
different teams is considered for the CRCU self-assessment.
Credit risk portfolio (*)
ING’s credit exposure is mainly related to lending to individuals and businesses followed by investments in
bonds and securitised assets, and money market. Loans to individuals are mainly mortgage loans secured
by residential property. Loans (including guarantees issued) to businesses are often collateralised, but may
be unsecured based on the internal analysis of the borrower’s creditworthiness. Bonds in the investment
portfolio are generally unsecured, but predominantly consist of bonds issued by central governments and
EU and/or OECD based financial institutions. Secured bonds, such as mortgage-backed securities and asset-
backed securities are secured by the underlying diversified pool of assets (commercial or residential
mortgages, car loans and/or other assets) held by the securities issuer. For money market, exposure is
mainly deposits to central banks. The last major credit risk source involves pre-settlement exposures which
arise from trading activities, including derivatives, repurchase transactions and securities lending/borrowing
transactions. This is also commonly referred to as counterparty credit risk.

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ING Bank Annual Report 2022 67

Portfolio analysis per business line (*) |  |  |  |  |  |  |  |  |  |  |
Outstandings per line of business (*)1, 2, 3
in € million | Wholesale Banking | Retail Benelux | Retail Challengers & Growth Markets | Corporate Line | Total
Rating class | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Investment grade | 1 (AAA) | 89,686 | 81,615 | 324 | 331 | 32,492 | 27,089 | 2,529 | 2,363 | 125,032 | 111,398
2-4 (AA) | 49,320 | 56,982 | 7,871 | 5,863 | 40,498 | 41,646 | 12 | 15 | 97,701 | 104,506
5-7 (A) | 79,292 | 72,052 | 45,471 | 28,456 | 61,422 | 59,040 | 320 | 482 | 186,505 | 160,029
8-10 (BBB) | 129,709 | 124,622 | 117,172 | 125,469 | 56,046 | 57,394 | 2,497 | 2,502 | 305,424 | 309,986
Non-Investment grade | 11-13 (BB) | 56,409 | 61,996 | 55,945 | 60,296 | 46,657 | 42,554 | 4 | 37 | 159,016 | 164,883
14-16 (B) | 13,693 | 16,699 | 14,224 | 14,560 | 11,662 | 10,800 |  |  | 39,579 | 42,059
17 (CCC) | 1,858 | 1,712 | 2,021 | 2,158 | 1,014 | 731 | 299 | 178 | 5,192 | 4,779
Substandard grade | 18 (CC) | 3,564 | 865 | 1,304 | 904 | 519 | 477 |  |  | 5,386 | 2,245
19 (C) | 731 | 126 | 962 | 1,162 | 490 | 451 |  |  | 2,183 | 1,739
Non-performing loans | 20-22 (D) | 4,354 | 3,937 | 4,762 | 5,035 | 2,592 | 3,153 |  |  | 11,708 | 12,124
Total | 428,616 | 420,606 | 250,056 | 244,232 | 253,391 | 243,334 | 5,662 | 5,577 | 937,725 | 913,749
Industry |  |  |  |  |  |  |  |  |  |  |
Private Individuals |  | 32 | 30 | 163,243 | 161,125 | 191,556 | 184,810 |  |  | 354,831 | 345,965
Central Banks |  | 80,006 | 83,878 |  |  | 23,541 | 22,573 | 1,495 | 643 | 105,043 | 107,094
Natural Resources |  | 44,695 | 51,937 | 1,160 | 1,225 | 694 | 692 |  |  | 46,549 | 53,855
Real Estate |  | 26,426 | 26,472 | 22,648 | 22,691 | 3,439 | 3,536 |  |  | 52,513 | 52,699
Commercial Banks |  | 42,036 | 39,582 | 194 | 230 | 5,721 | 6,390 | 2,911 | 3,006 | 50,863 | 49,208
Non-Bank Financial Institutions |  | 54,274 | 46,597 | 1,379 | 1,473 | 504 | 395 | 102 | 124 | 56,258 | 48,590
Central Governments |  | 41,622 | 40,530 | 2,880 | 1,730 | 3,838 | 3,686 | 1,016 | 1,696 | 49,356 | 47,642
Transportation & Logistics |  | 25,474 | 24,123 | 4,038 | 4,206 | 1,471 | 1,269 |  |  | 30,982 | 29,597
Utilities |  | 22,683 | 22,452 | 1,865 | 1,370 | 150 | 113 |  |  | 24,698 | 23,935
Food, Beverages & Personal Care |  | 13,681 | 14,003 | 7,356 | 6,926 | 2,585 | 2,411 |  |  | 23,623 | 23,340
Services |  | 9,926 | 9,449 | 11,606 | 11,290 | 981 | 974 | 33 | 30 | 22,546 | 21,743
General Industries |  | 11,731 | 11,487 | 5,753 | 5,554 | 3,381 | 3,086 |  |  | 20,865 | 20,127
Lower Public Administration |  | 6,020 | 6,163 | 5,921 | 5,079 | 9,725 | 8,029 |  |  | 21,666 | 19,271
Other | 50,009 | 43,903 | 22,014 | 21,333 | 5,805 | 5,369 | 104 | 77 | 77,932 | 70,682
Total | 428,616 | 420,606 | 250,056 | 244,232 | 253,391 | 243,334 | 5,662 | 5,577 | 937,725 | 913,749

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ING Bank Annual Report 2022 68

Outstandings per line of business (*) - continued1, 2, 3
in € million | Wholesale Banking | Retail Benelux | Retail Challengers & Growth Markets | Corporate Line | Total
Region | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Europe | Netherlands | 61,143 | 74,175 | 154,253 | 152,597 | 254 | 173 | 2,898 | 2,826 | 218,548 | 229,771
Belgium | 27,144 | 32,205 | 88,767 | 84,748 | 669 | 948 | 0 | 19 | 116,580 | 117,919
Germany | 24,441 | 22,669 | 463 | 508 | 127,764 | 118,734 | 63 | 46 | 152,730 | 141,956
Poland | 16,350 | 15,454 | 49 | 45 | 26,831 | 26,560 | 0 | 4 | 43,229 | 42,063
Spain | 10,491 | 10,130 | 71 | 83 | 25,649 | 27,294 | 25 | 35 | 36,237 | 37,542
United Kingdom | 27,735 | 28,193 | 152 | 187 | 185 | 109 | 107 | 78 | 28,179 | 28,567
Luxembourg | 26,113 | 26,632 | 4,953 | 4,769 | 639 | 468 | 15 | 18 | 31,720 | 31,887
France | 18,484 | 18,786 | 643 | 606 | 4,448 | 7,123 | 1 | 3 | 23,576 | 26,517
Rest of Europe | 77,814 | 64,028 | 400 | 364 | 18,750 | 17,826 | 24 | 16 | 96,989 | 82,233
America | 80,444 | 71,471 | 190 | 186 | 1,795 | 1,559 | 22 | 35 | 82,450 | 73,251
Asia | 46,291 | 45,439 | 73 | 91 | 121 | 132 | 2,504 | 2,498 | 48,989 | 48,159
Australia | 9,817 | 8,957 | 16 | 18 | 46,281 | 42,405 | 2 | 1 | 56,116 | 51,382
Africa | 2,348 | 2,467 | 28 | 31 | 5 | 4 | 0 | 0 | 2,381 | 2,501
Total | 428,616 | 420,606 | 250,056 | 244,232 | 253,391 | 243,334 | 5,662 | 5,577 | 937,725 | 913,749

1 Based on credit risk measurement contained in lending, pre-settlement, money market and investment activities.
2 Based 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.
3 Geographical areas are based on country of residence, except for private individuals for which the geographical areas are based on the primary country of risk.
Overall portfolio (*)
During 2022, ING’s portfolio size increased by €24.0 billion (+2.62%) to €937.7 billion outstandings. The net
volume growth was spread across all the business lines. Foreign exchange rate changes had a positive
impact on portfolio growth, mainly in WB, and increased total outstanding by €6.3 billion, driven by the
appreciation of the US dollar (+6.2%) against the euro, partially compensated by the British pound sterling
(-5.3%), the Polish new zloty (-1.8%), and new Turkish lira (-23.7%).
Rating distribution (*)
Overall, the rating class distribution remained stable in 2022. The share of investment grade rating classes
increased from 75.1% to 76.2%, while the share of non-investment grade decreased, from 23.2% to 21.7%.
Sub-standard grade outstandings increased from 0.4% to 0.8% of the total portfolio, whereas non-
performing loans decreased from 1.3% to 1.2%.
With respect to the rating distribution within the business lines, in WB, investment grade increased to 81.2%
(from 79.7%), where non-investment grade exposures decreased to 16.8% (from 19.1%) compared to 2021.
Substandard grade assets increased from 0.2% to 1.0% of total Wholesale Banking assets, primarily as a
result of increases in Russia, in the natural resources industry. The share of non-performing loans for WB
remained stable at 1.0% (from 0.9%).
The rating distribution for Retail Benelux improved mostly because of Dutch residential mortgages, shifting
from rating class BB/BBB to A. The share of A-rated mortgages increased from 9.3% to 24.0% of the
portfolio. In Belgium, residential mortgages showed a modest increase of BBB assets, from single A.
Substandard grade Belgium mortgage outstandings increased to 1.0% (from 0.8%).
In Retail Challengers & Growth Markets, the distribution across rating classes remained rather stable in 2022.
Overall share of investment grade decreased from 76.1% to 75.2%, NPL decreased to 1.0% (from 1.3%).

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> Credit risk
ING Bank Annual Report 2022 69
Industry (*)
In line with our objective to give stakeholders insight into the portfolio, we present the business lending
portfolio per industry breakdown in accordance with the NAICS definition. The industry composition within
Retail is concentrated in private individuals with 65.0% for Retail Benelux and 76.0% for Retail Challengers &
Growth Markets.
In Market Leaders, the overall volumes increase is mainly explained by Belgium (+4.7%), whereas the
Netherlands remained stable in 2022 (+1.1%). In C&G, the increase in volume is in private individuals,
primarily in Germany, and to a lesser extent in Australia and Spain. A decrease in France is explained by the
discontinuation of retail activities. Within WB, an increase in exposures is noted mainly in non-bank financial
institutions (NBFI) of €7.7 billion (notably in Germany, France and the US). Apart from NBFI, an increase is
observed in other industries (+€6.1 billion), compensated by a decrease in natural resources (€7.2 billion).

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ING Bank Annual Report 2022 70

Outstandings by economic sectors and geographical area (*) 1
in € million | Region |  |  |  |  |  |  |  |  |  |  |  |  | Total
Industry | Netherlands | Belgium | Germany | Poland | Spain | United Kingdom | Luxembourg | France | Rest of Europe | America | Asia | Australia | Africa | 2022
Private Individuals | 114,625 | 44,193 | 101,529 | 13,767 | 24,865 | 138 | 3,486 | 2,731 | 13,654 | 161 | 131 | 35,528 | 24 | 354,831
Central Banks | 35,202 | 14,338 | 21,041 | 1,060 | 347 | 427 | 6,820 | 35 | 18,092 | 0 | 4,962 | 2,695 | 24 | 105,043
Natural Resources | 3,084 | 1,356 | 809 | 746 | 169 | 4,442 | 2,764 | 470 | 12,154 | 8,771 | 10,398 | 1,028 | 361 | 46,549
Real Estate | 17,586 | 10,112 | 1,388 | 2,374 | 1,391 | 413 | 3,797 | 3,155 | 3,378 | 3,474 | 1,180 | 4,263 | 2 | 52,513
Commercial Banks | 1,359 | 265 | 3,974 | 551 | 402 | 4,933 | 4,480 | 4,371 | 6,368 | 9,945 | 12,041 | 1,765 | 409 | 50,863
Non-Bank Financial Institutions | 2,710 | 1,041 | 5,054 | 2,299 | 99 | 8,229 | 4,489 | 3,220 | 4,495 | 19,636 | 4,091 | 896 | 0 | 56,258
Central Governments | 3,342 | 7,716 | 1,179 | 6,578 | 4,578 | 46 | 175 | 1,797 | 8,444 | 13,979 | 333 | 636 | 551 | 49,356
Transportation & Logistics | 3,967 | 2,183 | 608 | 1,300 | 690 | 1,787 | 583 | 733 | 7,808 | 3,378 | 6,806 | 531 | 608 | 30,982
Utilities | 1,551 | 1,630 | 2,814 | 679 | 1,227 | 2,953 | 572 | 980 | 4,302 | 4,347 | 1,545 | 1,897 | 200 | 24,698
Food, Beverages & Personal Care | 7,249 | 3,002 | 573 | 2,334 | 475 | 739 | 1,667 | 469 | 2,668 | 3,245 | 942 | 248 | 13 | 23,623
Services | 4,819 | 8,816 | 1,254 | 1,101 | 67 | 685 | 808 | 1,066 | 1,120 | 1,821 | 357 | 632 | 0 | 22,546
General Industries | 5,430 | 2,689 | 1,007 | 2,849 | 311 | 330 | 604 | 245 | 3,152 | 2,926 | 1,311 | 9 | 0 | 20,865
Lower Public Administration | 272 | 5,638 | 5,197 | 644 | 200 | 0 | 313 | 3,126 | 402 | 1,310 | 0 | 4,564 | 0 | 21,666
Other | 17,353 | 13,602 | 6,302 | 6,946 | 1,416 | 3,058 | 1,164 | 1,179 | 10,952 | 9,457 | 4,891 | 1,424 | 188 | 77,932
Total | 218,548 | 116,580 | 152,730 | 43,229 | 36,237 | 28,179 | 31,720 | 23,576 | 96,989 | 82,450 | 48,989 | 56,116 | 2,381 | 937,725
Rating class |  |  |  |  |  |  |  |  |  |  |  |  |  |
Investment grade | 174,972 | 76,244 | 130,285 | 27,501 | 28,556 | 23,160 | 26,053 | 17,545 | 64,884 | 63,870 | 39,903 | 41,476 | 213 | 714,662
Non-Investment grade | 40,325 | 36,036 | 20,967 | 14,596 | 7,330 | 4,634 | 5,442 | 5,814 | 27,617 | 17,615 | 7,638 | 13,914 | 1,858 | 203,786
Sub-standard grade | 1,508 | 984 | 579 | 422 | 105 | 41 | 80 | 16 | 2,903 | 311 | 124 | 257 | 239 | 7,569
Non-performing loans | 1,743 | 3,316 | 899 | 710 | 246 | 344 | 145 | 201 | 1,584 | 654 | 1,325 | 470 | 72 | 11,708
Total | 218,548 | 116,580 | 152,730 | 43,229 | 36,237 | 28,179 | 31,720 | 23,576 | 96,989 | 82,450 | 48,989 | 56,116 | 2,381 | 937,725
1 Geographical areas are based on country of residence, except for private individuals for which the geographical areas are based on the primary country of risk.

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> Credit risk
ING Bank Annual Report 2022 71

Outstandings by economic sectors and geographical area (*) 1
in € million | Region |  |  |  |  |  |  |  |  |  |  |  |  | Total
Industry | Netherlands | Belgium | Germany | Poland | Spain | United Kingdom | Luxembourg | France | Rest of Europe | America | Asia | Australia | Africa | 2021
Private Individuals | 113,846 | 42,961 | 95,583 | 14,397 | 23,895 | 157 | 3,388 | 3,115 | 13,215 | 167 | 155 | 35,058 | 27 | 345,965
Central Banks | 46,902 | 18,253 | 17,811 | 112 | 3,027 | 2,853 | 8,569 | 1,039 | 4,485 | 0 | 2,856 | 1,168 | 18 | 107,094
Natural Resources | 3,734 | 1,180 | 1,208 | 722 | 291 | 4,487 | 2,497 | 405 | 15,471 | 9,473 | 12,593 | 1,013 | 780 | 53,855
Real Estate | 17,426 | 10,011 | 1,520 | 2,357 | 1,528 | 436 | 4,201 | 3,254 | 3,461 | 3,521 | 935 | 4,045 | 4 | 52,699
Commercial Banks | 1,378 | 318 | 3,887 | 707 | 392 | 4,156 | 3,205 | 5,520 | 6,353 | 7,089 | 13,526 | 2,265 | 413 | 49,208
Non-Bank Financial Institutions | 3,043 | 921 | 3,146 | 1,718 | 72 | 7,764 | 4,798 | 1,790 | 3,947 | 17,772 | 3,209 | 411 | 0 | 48,590
Central Governments | 4,911 | 7,396 | 1,179 | 7,473 | 4,417 | 67 | 203 | 2,065 | 7,695 | 10,927 | 299 | 533 | 477 | 47,642
Transportation & Logistics | 4,572 | 2,209 | 506 | 1,177 | 723 | 1,760 | 582 | 982 | 6,837 | 3,410 | 5,682 | 645 | 514 | 29,597
Utilities | 1,545 | 1,213 | 3,024 | 822 | 1,270 | 2,980 | 397 | 1,433 | 4,202 | 4,106 | 1,355 | 1,368 | 220 | 23,935
Food, Beverages & Personal Care | 6,581 | 2,869 | 616 | 2,146 | 489 | 711 | 1,600 | 1,232 | 2,580 | 3,131 | 1,140 | 235 | 12 | 23,340
Services | 4,615 | 9,115 | 1,105 | 866 | 119 | 523 | 450 | 1,470 | 861 | 1,539 | 479 | 565 | 36 | 21,743
General Industries | 5,389 | 2,891 | 1,011 | 2,612 | 381 | 395 | 532 | 271 | 3,363 | 2,116 | 1,151 | 15 | 0 | 20,127
Lower Public Administration | 343 | 5,158 | 5,787 | 636 | 0 | 0 | 296 | 2,732 | 467 | 1,197 | 46 | 2,608 | 0 | 19,271
Other | 15,485 | 13,424 | 5,573 | 6,319 | 940 | 2,277 | 1,168 | 1,210 | 9,297 | 8,803 | 4,732 | 1,454 | 0 | 70,682
Total | 229,771 | 117,919 | 141,956 | 42,063 | 37,542 | 28,567 | 31,887 | 26,517 | 82,233 | 73,251 | 48,159 | 51,382 | 2,501 | 913,749
Rating class |  |  |  |  |  |  |  |  |  |  |  |  |  |
Investment grade | 180,787 | 78,195 | 119,311 | 26,856 | 29,522 | 22,820 | 26,150 | 20,622 | 52,875 | 53,725 | 36,777 | 38,200 | 79 | 685,920
Non-Investment grade | 45,530 | 35,600 | 21,250 | 14,148 | 7,647 | 5,234 | 5,568 | 5,774 | 27,993 | 18,184 | 10,534 | 11,998 | 2,259 | 211,721
Sub-standard grade | 1,230 | 868 | 390 | 290 | 89 | 56 | 81 | 2 | 308 | 203 | 191 | 217 | 58 | 3,985
Non-performing loans | 2,224 | 3,256 | 1,006 | 768 | 284 | 458 | 87 | 119 | 1,056 | 1,139 | 656 | 966 | 105 | 12,124
Total | 229,771 | 117,919 | 141,956 | 42,063 | 37,542 | 28,567 | 31,887 | 26,517 | 82,233 | 73,251 | 48,159 | 51,382 | 2,501 | 913,749

1 Geographical 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 share of the Netherlands in the overall portfolio reduced to 23.3% (2021: 25.1%).
The most noticeable trend in the Netherlands was the decrease in exposure with central banks (-€11.7
billion). Outstandings to private individuals were stable at 62.5% (2021: 62.3%) of total outstandings (excl.
Central Banks). In Belgium, no substantial moves were observed in the portfolio, apart from a decrease in
central banks (€3.9 billion).
In terms of rating distribution in individual countries, the total share of investment grade/non-investment
grade remains substantial for the Netherlands at 98.5% (2021: 98.5%) and in Belgium 96.3% (2021: 96.5%).
Substandard grade assets increased slightly, in the Netherlands from 0.5% to 0.7% and in Belgium from
0.7% to 0.8%. In the Netherlands, the NPL share decreased in 2022, from 1.0% to 0.8%, whereas Belgium
remained flat at 2.8%.

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> Credit risk
ING Bank Annual Report 2022 72
In Challengers & Growth Markets, ING has a strong market position in residential mortgages in Germany,
Australia, Spain and Poland. Mortgage portfolios increased in Germany, Australia and Spain in 2022.
The top-five countries within Rest of Europe based on outstandings were: Switzerland (€25.0 billion), Italy
(€17.7 billion), Romania (€10.3 billion), Turkey (€7.8 billion) and Ireland (€5.6 billion). Outstandings in Rest of
Europe were primarily impacted by Switzerland (central bank outstandings +€15.3 billion).
In Europe, outside the Benelux, rating distribution in most countries remained stable. The most noticeable
moves in rating distribution were observed in Rest of Europe, where the development of the Russian
portfolio caused an increase in substandard from 0.4% to 3.0% and NPL from 1.3% to 1.6%. Note the
paragraph on Russian exposures in section 'Risk management at ING Bank'. Apart from Russia, noticeable
moves occurred in France, where NPL increased from 0.4% to 0.9% impacted by the decommissioning of
the Retail business in France. And in the UK, where NPL decreased from 1.6% to 1.2%.
The increase in exposure in the Americas region was mainly driven by FX impact. In terms of rating
distribution for America region, an increase in investment grade is observed to 77.6% (from 73.0%), non-
investment grade decreased to 21.3% from 25.1%. Sub-standard grade increased to 0.4%, while NPL
improved to 0.8% (from 1.5%). Australia’s rating distribution improved with a decrease of NPL’s from 1.9% to
0.8% of the portfolio.
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 exclusively 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
on 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 to ensure 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 increased the haircuts applied to collateral values used in stage 3 individual provisions as at
31 December 2021 and 31 December 2022 to reflect the increased risk of inflated asset prices in certain
sectors of the economy. The haircut is applied on real estate, shipping and aviation collateral values 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, financial collateral (cash
and securities) and guarantees. ING obtains cover that is eligible for credit risk mitigation under CRR/CRDIV,
as well as cover that is not eligible. Collateral covering financial market transactions is valued on a daily
basis, and 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. Our definition of non-performing is explained in detail in ‘Credit restructuring’ (below). For
additional insight, a breakdown of ING’s portfolio by industry and geography is provided.

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ING Bank Annual Report 2022 73
The next table gives an overview of the collateralisation of the ING’s total portfolio.

Cover values including guarantees received (*) |
in € million |  | Cover type | Collateralisation |
2022 | Outstandings | Mortgages | Financial Collateral | Guarantees | Other covers | No Cover | Partially covered | Fully covered |
Consumer lending | 353,323 | 700,961 | 5,626 | 24,231 | 42,817 | 6.2% | 7.6% | 86.2% |
Business lending | 379,070 | 167,122 | 29,501 | 118,294 | 438,864 | 37.5% | 22.3% | 40.2% |
Investment and money market | 141,432 | 0 | 5 | 1,213 | 2 | 99.1% | 0.6% | 0.3% |
Total lending, investment and money market | 873,824 | 868,083 | 35,132 | 143,738 | 481,683 | 34.8% | 12.9% | 52.3% |
Pre-settlement | 63,901 |  |  |  |  |  |  |  |
Total Bank | 937,725 |  |  |  |  |  |  |  |

Cover values including guarantees received (*)
in € million |  | Cover type | Collateralisation
2021 | Outstandings | Mortgages | Financial Collateral | Guarantees | Other covers | No Cover | Partially covered | Fully covered
Consumer lending | 344,188 | 690,752 | 6,533 | 25,688 | 40,618 | 6.3% | 7.6% | 86.1%
Business lending | 413,670 | 160,694 | 23,454 | 112,095 | 332,989 | 44.2% | 20.2% | 35.5%
Investment and money market | 112,360 | 43 | 63 | 1,100 | 167 | 98.9% | 0.8% | 0.3%
Total lending, investment and money market | 870,218 | 851,490 | 30,050 | 138,882 | 373,774 | 36.0% | 12.8% | 51.2%
Pre-settlement | 43,531 |  |  |  |  |  |  |
Total Bank | 913,749 |  |  |  |  |  |  |

Excluding the pre-settlement portfolio, 52.3% (2021: 51.2%) of ING’s outstandings were fully collateralised in
2022. Since investments traditionally do not require covers, the percentage for ‘no covers’ in this portfolio is
above 95%. However, 99% of the investment outstanding is investment grade. Improved economic
conditions in ING’s main markets contributed to improved collateral valuations, observed in consumer
lending. Relative to the overall developments in the housing markets and the impact on provisioning, note
the paragraphs on ‘management adjustments’ in the Loan Loss provisioning section, that were made to
reflect potential impact of higher inflation, higher rates and market uncertainty.
Consumer lending portfolio (*)
The consumer lending portfolio accounts for 37.7% (2021: 37.7%) of ING’s total outstanding, primarily
consisting of residential mortgage loans and other consumer lending loans. As a result, 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 (34.4%), Germany (28.0%), Belgium and Luxembourg (13.2%) and Australia (10.7%).
Relative to the overall developments in the housing markets and loan loss provisions for the mortgage
portfolio’s, note that management adjustments are recognised to maintain an appropriate level of
provisions. See paragraph on ‘management adjustments’ in the loan loss provisioning section.
Business lending portfolio (*)
Business lending accounts for 40.4% (2021: 45.3%) of ING’s total outstanding. Business lending presented in
this section does not include pre-settlement, investment and money market exposures.

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> Credit risk
ING Bank Annual Report 2022 74
Credit quality (*)

Credit risk categories (*)
| Regular | Watch List | Restructuring 1 | Non-performing 1
Possible ratings | 1–19 | 1–19 | 11–20 | 20-22
Typical ratings | 1–14 | 15–17 | 18–20 | 20-22
Deterioration in risk | Not significant | Significant | Significant | Significant
Significant intervention | Not required | Not required | Required | Required
Account Ownership | Front Office | Front Office | Front Office | Front Office
Credit Risk Management | Regular | Regular | Credit Restructuring | Credit Restructuring
Primary Manager | Front Office | Front Office | Credit Restructuring | Credit Restructuring
Accounting provisioning | Stage 1/2 | Stage 1/2 | Stage 2/3 | Stage 3

1 More information on the Restructuring and Non-performing categories can be found in the Credit restructuring section.

Credit quality outstandings (*)
in € million | 2022 | 2021
Performing not past due | 799,655 | 819,183
Business lending performing past due | 7,659 | 8,121
Consumer lending performing past due | 780 | 1,142
Non-performing | 11,691 | 12,021
Total lending and investment | 819,785 | 840,466
Money market | 54,039 | 29,752
Pre-settlement | 63,901 | 43,531
Total | 937,725 | 913,749

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 is applicable to private
individuals, as well as business lending. An obligation is considered ‘past due’ if a payment of interest or
principal is more than one day late. ING aims to help its customers as soon as they are past due by
reminding them of their payment obligations. In its contact with the 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 cured, for example because the customer is unable or unwilling to pay, 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.
ING has aligned the regulatory concept of non-performing with that of the definition of default. Hence, in
WB, obligors are classified as non-performing when a default trigger occurs:
•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.
•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.
Further, WB has an individual name approach, using early warnings indicators to signal possible future
issues in debt service.

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> Credit risk
ING Bank Annual Report 2022 75

Ageing analysis (past due but performing): Consumer lending portfolio by geographic area, outstandings (*)1,2
in € million | 2022 | 2021
Region | Past due for 1–30 days | Past due for 31–60 days | Past due for 61–90 days | Past due for >90 days | Total | Past due for 1–30 days | Past due for 31–60 days | Past due for 61–90 days | Past due for >90 days | Total
Europe | Belgium | 294 | 27 | 18 |  | 339 | 599 | 53 | 61 |  | 714
Germany | 68 | 34 | 13 |  | 116 | 105 | 27 | 11 |  | 143
Luxembourg | 43 | 4 | 2 |  | 48 | 73 | 3 | 1 | 1 | 78
Netherlands | 36 | 10 | 5 |  | 50 | 31 | 9 | 3 |  | 43
Poland | 59 | 8 | 4 |  | 71 | 35 | 5 | 3 |  | 43
Spain | 13 | 9 | 5 |  | 27 | 13 | 7 | 5 |  | 26
France | 2 |  |  |  | 2 | 2 |  |  |  | 2
United Kingdom |  |  |  |  |  |  |  |  |  | 1
Rest of Europe | 60 | 15 | 8 |  | 83 | 52 | 9 | 5 |  | 66
America | 1 |  |  |  | 1 |  |  |  |  |
Australia | 29 | 11 | 2 |  | 42 | 17 | 7 | 1 |  | 25
Total | 604 | 119 | 57 |  | 780 | 927 | 123 | 91 | 1 | 1,142

1 Based on consumer lending. The amount of past due but performing financial assets in respect of non-lending activities was not significant.
2 The absolute and relative materiality thresholds used for determining a defaulted status do not apply for the purposes of classification as past due. Below these thresholds, arrears of more than 90 days are reported as past due.
The past due but performing outstanding of consumer lending decreased by €362 million. The largest
decrease was observed in Belgium (-€375 million), in term loans (-€188 million) and in Residential Mortgage
(-€113 million). Moderate increase was seen in Poland (+€28 million), Rest of Europe (+€17 million) and
Australia (+€16 million), with each mainly visible in the 1–30 days past due bucket.

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ING Bank Annual Report 2022 76

Ageing analysis (past due but performing): Business lending portfolio by geographic area, outstandings (*)1
in € million | 2022 | 2021
Region | Past due for 1–30 days | Past due for 31–60 days | Past due for 61–90 days | Past due for >90 days | Total | Past due for 1–30 days | Past due for 31–60 days | Past due for 61–90 days | Past due for >90 days | Total
Europe | Belgium | 579 | 49 | 10 |  | 639 | 1,676 | 178 | 8 |  | 1,863
United Kingdom | 1,147 | 77 | 512 |  | 1,736 | 1,036 | 108 | 16 |  | 1,159
Luxembourg | 302 | 1 |  |  | 303 | 586 | 270 |  | 1 | 856
Netherlands | 730 | 30 | 15 |  | 775 | 553 | 16 | 4 |  | 574
Poland | 279 | 35 | 14 |  | 329 | 94 | 5 | 2 | 1 | 102
Spain |  |  |  |  |  | 95 |  | 1 |  | 96
France | 83 | 6 |  |  | 90 | 36 | 5 |  |  | 41
Germany | 44 | 16 |  |  | 60 | 5 |  | 2 |  | 7
Rest of Europe | 474 | 239 | 1 | 1 | 715 | 571 | 57 | 1 | 1 | 629
America | 1,901 | 67 | 19 |  | 1,986 | 2,076 | 71 |  |  | 2,146
Asia | 553 | 48 |  |  | 601 | 276 |  | 25 |  | 302
Australia | 359 | 61 | 4 | 2 | 426 | 327 | 17 |  | 1 | 345
Total | 6,452 | 629 | 575 | 4 | 7,659 | 7,331 | 727 | 60 | 3 | 8,121

1 The absolute and relative materiality thresholds used for determining a defaulted status do not apply for the purposes of classification as past due. Below these thresholds, arrears of more than 90 days are reported as past due.
Total past due but performing outstanding of business lending decreased by €462 million. These were
mainly contributed by decreased outstanding in the 1-30 days (€879 million) past due bucket, partly offset
by increased outstanding in 61–90 days past due bucket (€515 million). The top three areas of decrease in
the 1-30 days bucket were Belgium (€1,097 million), Luxembourg (€284 million) and America (€175 million).
The top three areas of increase in the 1-30 days bucket were Asia (€277 million), Poland (€185 million) and
the Netherlands (€177 million).
Credit restructuring (*)
Global Credit Restructuring (GCR) is the dedicated and independent department that deals with non-
performing loans and loans that hold a reasonable probability that ING will end up with a loss, if no specific
action is taken. GCR handles accounts or portfolios requiring an active approach, which may include
renegotiation of terms and conditions and business or financial restructuring. The loans are managed by
GCR or by units in the various regions and business units. ING uses three distinct statuses to categorise the
management of clients with (perceived) deteriorating credit risk profiles, i.e. there is increasing doubt as to
the performance and the collectability of the client’s contractual obligations:
•Watch list: Usually, a client is first classified as watch list when there are concerns of any potential or
material deterioration in credit risk profile that may affect the ability of the client to adhere to its debt
service obligations or to refinance its existing loans. Watch List status requires more than usual
attention, increased monitoring and quarterly reviews. Some clients with a Watch List status may
develop into a Restructuring status or even a Recovery status.
•Restructuring: A client is classified in restructuring when there are concerns about the client’s financial
stability, credit worthiness, and/or ability to repay, but where the situation does not require the
termination or acceleration of facilities or the liquidation of collateral. ING’s actions aim to maintain the
going concern status of the client by:
•restoring the client’s financial stability;
•supporting the client’s turnaround;
•restoring the balance between debt and equity; and
•restructuring the debt to a sustainable situation.
•Recovery: A client is classified as in recovery when ING and/or the client concludes that the client’s
financial situation cannot be restored and a decision is made to terminate the (credit) relationship or

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> Credit risk
ING Bank Annual Report 2022 77
even to enter into bankruptcy. ING prefers an amicable exit, but will enforce and liquidate the collateral
or claim under the guarantees if deemed necessary.
Watch list, restructuring and recovery accounts are reviewed at least quarterly by the front office, GCR and
the relevant credit risk management executives.
Forbearance (*)
Forbearance occurs when a client is unable to meet their financial commitments due to financial difficulties
they face or are about to face and ING grants concessions towards them. Forborne assets are assets in
respect of 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 with the aim of maximising the client’s
repayment ability and therewith avoiding a default situation or helping the client to return to a performing
situation.
For ING retail units, clear criteria has 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
on a portfolio (retail) basis.
All exposures are eligible for forbearance measures, i.e. both performing (Risk ratings 1-19) and non-
performing (risk ratings 20-22) exposures. 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 € million | 2022 | 2021
Business line | Outstanding s | Of which: performin g | Of which: non- performing | % of total portfolio | Outstanding s | Of which: performin g | Of which: non- performing | % of total portfolio
Wholesale Banking | 8,359 | 5,880 | 2,478 | 2.7% | 9,798 | 7,455 | 2,343 | 3.1%
Retail Banking | 8,080 | 4,973 | 3,107 | 1.6% | 10,018 | 6,339 | 3,679 | 2.1%
Total | 16,438 | 10,853 | 5,585 | 2.0% | 19,816 | 13,793 | 6,022 | 2.5%

Summary Forborne portfolio by forbearance type (*)
in € million | 2022 | 2021
Forbearance type | Outstanding s | Of which: performin g | Of which: non- performing | % of total portfolio | Outstanding s | Of which: performin g | Of which: non- performing | % of total portfolio
Loan modification | 15,317 | 10,428 | 4,889 | 1.9% | 18,311 | 13,128 | 5,183 | 2.3%
Refinancing | 1,121 | 426 | 695 | 0.1% | 1,505 | 666 | 839 | 0.2%
Total | 16,438 | 10,853 | 5,585 | 2.0% | 19,816 | 13,793 | 6,022 | 2.5%

As of 31 December 2022, ING’s total forborne assets decreased by €3.4 billion compared to 31 December
2021. WB decreased by €1.4 billion and Retail Banking decreased by €1.9 billion.
Wholesale Banking (*)
As of December 2022, WB forborne assets amounted to €8.4 billion (2021: €9.8 billion), which represented
2.7% (2021: 3.1%) of the total WB portfolio.

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ING Bank Annual Report 2022 78

Wholesale Banking: Forborne portfolio by geographical area (*)
in € million | 2022 | 2021
Region | Outstandings | Of which: performing | Of which: non- | Outstandings | Of which: performing | Of which: non-
performing | performing
Europe | Netherlands | 720 | 630 | 90 | 1,012 | 811 | 201
Belgium | 659 | 651 | 8 | 329 | 321 | 8
Germany | 580 | 466 | 115 | 868 | 658 | 210
United Kingdom | 1,044 | 721 | 323 | 1,344 | 913 | 432
Italy | 205 | 157 | 48 | 286 | 261 | 25
Norway | 33 |  | 33 | 79 | 29 | 50
Poland | 203 | 189 | 14 | 181 | 160 | 21
Rest of Europe | 2,176 | 1,749 | 427 | 2,381 | 2,181 | 200
America | 1,353 | 1,032 | 321 | 1,900 | 1,326 | 574
Asia | 1,107 | 143 | 964 | 685 | 292 | 393
Australia | 217 | 132 | 85 | 568 | 416 | 152
Africa | 61 | 10 | 51 | 164 | 88 | 76
Total | 8,359 | 5,880 | 2,478 | 9,798 | 7,455 | 2,343

Wholesale Banking: Forborne portfolio by economic sector (*)
in € million | 2022 | 2021
Industry | Outstandings | Of which: performing | Of which: non- | Outstandings | Of which: performing | Of which: non-
performing | performing
Natural Resources | 1,239 | 603 | 636 | 2,047 | 1,177 | 870
Real Estate | 2,000 | 1,917 | 84 | 1,665 | 1,570 | 95
Transportation & Logistics | 1,073 | 868 | 205 | 1,336 | 1,061 | 274
Food, Beverages & Personal Care | 1,082 | 543 | 539 | 1,202 | 749 | 452
Services | 697 | 665 | 32 | 793 | 687 | 106
Automotive | 172 | 125 | 46 | 581 | 535 | 46
Utilities | 469 | 255 | 214 | 407 | 271 | 136
General Industries | 255 | 176 | 80 | 366 | 321 | 45
Retail | 302 | 227 | 76 | 361 | 304 | 57
Chemicals, Health & Pharmaceuticals | 191 | 168 | 23 | 347 | 324 | 22
Builders & Contractors | 168 | 94 | 74 | 177 | 135 | 41
Other | 710 | 240 | 469 | 516 | 318 | 197
Total | 8,359 | 5,880 | 2,478 | 9,798 | 7,455 | 2,343

The main concentration of forborne assets in a single country was in the United Kingdom with 12% (2021:
14%) of the total WB forborne assets and 13% (2021: 18%) of the total non-performing forborne assets.
WB forborne assets decreased by €1.44 billion compared to 2021, of which the performing forborne assets
decreased by €1.58 billion. This was visible across all industries (except for Real estate) and locations (except
for Belgium and Poland).
WB's forborne assets were mainly concentrated in natural resources, real estate, transportation & logistics
and food beverages & personal care. These four economic sectors accounted for 65% of the total WB
forborne outstandings. During 2022, an increase in forborne assets was visible in the real estate industry (+€
0.3 billion), offset by a decrease in Natural Resources (-€0.8 billion), Automotive (-€ 0.4 billion), Food,
Beverages & Personal Care (-€0.1 billion) and Transportation & Logistics (-€0.2 billion).
Retail Banking (*)
As of the end of December 2022, Retail Banking forborne assets totalled €8.1 billion, which represented 1.6%
of the total Retail Banking portfolio.

Retail Banking: Forborne portfolio by geographical area (*)
in € million | 2022 | 2021
Region | Outstandings | Of which: performing | Of which: non- | Outstandings | Of which: performing | Of which: non-
performing | performing
Europe | Netherlands | 2,832 | 2,043 | 789 | 4,171 | 3,224 | 947
Belgium | 2,644 | 1,331 | 1,314 | 3,319 | 2,035 | 1,284
Germany | 804 | 610 | 194 | 497 | 306 | 191
Poland | 588 | 309 | 279 | 450 | 152 | 298
Turkey | 64 | 31 | 32 | 146 | 97 | 49
Italy | 131 | 52 | 79 | 129 | 47 | 82
Romania | 124 | 53 | 71 | 115 | 49 | 66
Spain | 35 | 15 | 20 | 35 | 11 | 23
Rest of Europe | 73 | 48 | 25 | 99 | 68 | 30
America | 13 | 12 |  | 9 | 7 | 2
Asia | 3 | 1 | 1 | 3 | 1 | 1
Australia | 768 | 467 | 302 | 1,045 | 340 | 705
Africa | 1 |  |  | 1 |  |
Total | 8,080 | 4,973 | 3,107 | 10,018 | 6,339 | 3,679

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> Credit risk
ING Bank Annual Report 2022 79
The main concentration of forborne assets in a single country was in the Netherlands with 35% (2021: 42%)
of total Retail Banking forborne assets and 25% (2021: 26%) of the non-performing forborne assets. Next to
that, Belgium had to 33% (2021: 33%) of the total Retail forborne assets.
Non-performing loans (*)
ING’s loan portfolio is under constant review. Loans to obligors that are considered more than 90 days past
due and above applicable thresholds are reclassified as non-performing. For business lending portfolios,
there generally are reasons for declaring a loan non-performing prior to the obligor being 90 days past due.
These reasons include, but are not limited to, ING’s assessment of the customer’s perceived inability to meet
its financial obligations, or the customer filing for bankruptcy or bankruptcy protection.
The table below represents the breakdown by industry of credit risk outstandings that have been classified
as non-performing.

Non-performing Loans: outstandings by economic sector and business lines (*)1
in € million | Wholesale Banking | Retail Benelux | Retail Challengers & Growth Markets | Corporate Line | Total
Industry | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Private Individuals |  |  | 2,174 | 2,424 | 1,954 | 2,445 |  |  | 4,129 | 4,869
Natural Resources | 1,369 | 1,325 | 34 | 46 | 17 | 27 |  |  | 1,421 | 1,398
Food, Beverages & Personal Care | 672 | 681 | 438 | 428 | 122 | 130 |  |  | 1,233 | 1,239
Transportation & Logistics | 367 | 575 | 165 | 180 | 51 | 52 |  |  | 583 | 807
Services | 119 | 224 | 448 | 499 | 61 | 63 |  |  | 628 | 786
Real Estate | 172 | 132 | 486 | 495 | 54 | 59 |  |  | 712 | 686
General Industries | 114 | 66 | 268 | 272 | 100 | 123 |  |  | 482 | 461
Builders & Contractors | 139 | 93 | 244 | 224 | 110 | 112 |  |  | 493 | 429
Retail | 98 | 140 | 107 | 103 | 39 | 47 |  |  | 244 | 290
Utilities | 387 | 199 | 7 | 10 | 7 | 11 |  |  | 401 | 221
Chemicals, Health & Pharmaceuticals | 175 | 65 | 115 | 70 | 20 | 22 |  |  | 310 | 158
Telecom | 288 | 28 | 12 | 1 | 3 | 3 |  |  | 303 | 31
Other | 440 | 305 | 260 | 282 | 52 | 58 |  |  | 753 | 646
Total | 4,340 | 3,833 | 4,759 | 5,035 | 2,592 | 3,153 |  |  | 11,691 | 12,021

1 Based on Lending and Investment outstandings.

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> Credit risk
ING Bank Annual Report 2022 80

Non-performing Loans: outstandings by economic sectors and geographical area (*)
in € million | Region |  |  |  |  |  |  |  |  |  |  |  |  | Total
Industry | Netherlands | Belgium | Germany | Poland | Spain | United Kingdom | France | Luxembourg | Rest of Europe | America | Asia | Australia | Africa | 2022
Private Individuals | 574 | 1,538 | 739 | 185 | 194 | 4 | 11 | 36 | 470 | 3 | 4 | 370 | 1 | 4,129
Natural Resources | 57 | 33 |  | 14 |  |  |  | 53 | 432 | 77 | 649 | 85 | 21 | 1,421
Food, Beverages & Personal Care | 310 | 179 | 24 | 109 |  | 173 | 7 |  | 228 | 77 | 126 |  |  | 1,233
Transportation & Logistics | 232 | 58 | 1 | 36 | 47 | 20 |  | 2 | 154 | 24 | 7 | 1 |  | 583
Services | 136 | 375 | 2 | 43 | 5 |  | 3 | 2 | 21 | 40 |  |  |  | 628
Real Estate | 89 | 376 |  | 54 |  | 84 | 25 | 19 | 7 | 47 |  | 11 |  | 712
General Industries | 127 | 142 | 17 | 78 |  |  | 31 | 2 | 26 | 58 |  |  |  | 482
Builders & Contractors | 65 | 187 | 2 | 86 |  |  |  | 20 | 101 | 32 |  |  |  | 493
Retail | 31 | 85 | 38 | 26 |  |  | 18 | 1 | 13 | 22 | 7 | 2 |  | 244
Utilities | 6 | 6 | 26 | 23 |  |  |  |  | 17 | 194 | 129 |  |  | 401
Chemicals, Health & Pharmaceuticals | 51 | 100 | 2 | 15 |  | 14 | 100 |  | 28 |  |  |  |  | 310
Telecom | 24 | 1 |  | 3 |  |  |  |  |  | 5 | 270 |  |  | 303
Other | 40 | 232 | 48 | 38 |  | 50 |  | 10 | 79 | 75 | 130 |  | 51 | 753
Total | 1,742 | 3,312 | 899 | 710 | 246 | 344 | 196 | 145 | 1,578 | 654 | 1,324 | 470 | 72 | 11,691

Non-performing Loans: outstandings by economic sectors and geographical area (*)
in € million | Region |  |  |  |  |  |  |  |  |  |  |  |  | Total
Industry | Netherlands | Belgium | Germany | Poland | Spain | United Kingdom | France | Luxembourg | Rest of Europe | America | Asia | Australia | Africa |
Private Individuals | 776 | 1,578 | 721 | 206 | 232 | 8 | 16 | 35 | 497 | 3 | 4 | 791 | 1 | 4,869
Natural Resources | 67 | 44 |  | 20 |  | 27 |  |  | 116 | 577 | 421 | 90 | 37 | 1,398
Food, Beverages & Personal Care | 299 | 176 | 25 | 111 |  | 226 | 7 | 2 | 37 | 228 | 128 | 1 |  | 1,239
Transportation & Logistics | 385 | 55 | 1 | 35 | 47 | 20 |  | 3 | 165 | 29 | 49 | 17 |  | 807
Services | 199 | 385 |  | 45 | 5 | 66 |  | 4 | 22 | 52 | 6 | 1 |  | 786
Real Estate | 167 | 303 |  | 61 |  | 88 | 21 | 21 | 9 |  |  | 16 |  | 686
General Industries | 110 | 173 | 18 | 91 |  |  | 4 | 3 | 34 | 27 |  |  |  | 461
Builders & Contractors | 43 | 188 | 4 | 83 |  |  |  | 2 | 58 | 50 |  |  |  | 429
Retail | 40 | 70 | 34 | 30 |  |  | 56 | 1 | 21 | 21 | 14 | 2 |  | 290
Utilities | 8 | 9 | 71 | 26 |  |  |  |  | 28 | 30 |  | 48 |  | 221
Chemicals, Health & Pharmaceuticals | 63 | 48 | 2 | 16 |  |  |  |  | 29 |  |  |  |  | 158
Telecom | 13 | 1 |  | 2 |  | 10 |  |  | 1 | 5 |  |  |  | 31
Other | 42 | 226 | 129 | 41 |  | 2 | 14 | 15 | 38 | 37 | 34 | 1 | 67 | 646
Total | 2,212 | 3,255 | 1,005 | 768 | 284 | 447 | 119 | 87 | 1,056 | 1,060 | 656 | 966 | 105 | 12,021

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> Credit risk
ING Bank Annual Report 2022 81
In December 2022, the NPL portfolio decreased to €11.7 billion, (Dec 21: €12.0 billion). The decrease was
driven by Challengers and Growth (-€561 million) and Market Leaders(-€276 million), while Wholesale
Banking (+€494 million) increased. The decrease in Challengers & Growth Markets and Market Leaders was
mainly witnessed in Private individuals, and was offset by an increase in Wholesale Banking mainly
witnessed in Telecom and Utilities industries. The top three countries by NPL outstanding remained Belgium,
the Netherlands and Germany. Together they accounted for 50.9% (€5.9 billion) of NPL outstanding (Dec 21:
53.8% (€6.5 billion).
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 certain 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 Lifetime ECL for credit impaired exposures (Stage 3) below €1 million.
•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: (1) to the economic outlook and (2) 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 IFRS9 and the
regulatory technical standards (RTS) and EBA guidelines. More information can be found in section 1.7.8 of
the Consolidated financial statements.
Climate and environmental risks in IFRS 9 models (*)
ING is evolving in its credit risk management framework to further develop a better understanding of
emerging climate and environmental risks. Banks, including ING, are in the process of collecting and
analysing empirical historical data and moving towards embedding these emerging risks into their credit
risk management processes and eventually into their IFRS 9 ECL models.
In 2022, ING continued to enhance the tools used to identify and assess climate and environmental (C&E)
risks in our portfolio. We created C&E risk sector heatmaps for both WB and Retail Banking that facilitated
the identification of exposure to C&E risks by means of scores assigned to transition and physical risk
drivers. They also enabled us to understand the magnitude of the C&E risk impact on a sectoral level and
pinpointed sectors with highest C&E risk exposure. In the past two years, we have improved our
understanding of the physical risk impact of climate events on our mortgage portfolio.
The integration of quantified inputs from the heatmaps into risk modelling has not yet been implemented
for a number of reasons including a lack of data to assess C&E risks at a client level. Refer to the section
'Environmental, social and governance risk' for further details on the heatmaps and the related challenges.
At this point in time it is not possible to incorporate climate risk separately into IFRS 9 ECL models given the
lack of sufficient empirical historical data and the above-mentioned limitations in the risk assessments on
client level. Where climate and environmental factors have impacted the economy in the recent past or
present, these impacts are however currently implicitly embedded in ING's IFRS9 ECL models through the
projected macroeconomic indicators (e.g. GDP growth and unemployment rates). We note that our ECL
models are primarily sensitive to the short-term economic outlook as we use a three-year time horizon for
macroeconomic outlook, after which a mean reversion approach is applied.
With regard to our evaluation of climate-related matters, where such events have already occurred (e.g.
floods), the impact of such events are individually assessed in the calculation of Stage 3 Individual provisions
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.
As of 31 December 2022, reported ECL includes a management adjustment of €10 million to address the
increased credit risk in ING’s livestock farming portfolio resulting from nitrogen reduction targets introduced
by the Dutch Government. Refer to the section 'Management overlays' for further details.

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> Credit risk
ING Bank Annual Report 2022 82

Reconciliation gross carrying amount (IFRS 9 eligible) and statement of financial position |  |  |  |  |  |  |
in € million | 2022 | 2021
| Gross Carrying Amount | Allowances for credit losses | Cash and on- demand bank positions | Reverse Repurchase transactions | Cash collateral | Other | Statement of financial position | Gross Carrying Amount | Allowances for credit losses | Cash and on- demand bank positions | Reverse Repurchase transactions | Cash collateral | Other | Statement of financial position
Amounts held at Central Banks | 88,349 | -12 | -1,170 |  |  | 447 | 87,614 | 104,875 | -6 | 1,650 |  |  | 1 | 106,520
Loans and Advances to Banks | 8,796 | -37 | 2,851 | 19,395 | 3,679 | 419 | 35,103 | 15,213 | -22 | 1,674 | 3,403 | 3,287 | 36 | 23,591
Financial Instruments FVOCI Loans | 640 | -1 |  |  |  | 4 | 643 | 837 | -1 |  |  |  | 3 | 838
Financial Instruments FVOCI Debt securities | 28,752 | -21 |  |  |  | 364 | 29,095 | 27,201 | -12 |  |  |  | 150 | 27,340
Securities at Amortised Cost | 48,372 | -17 |  |  |  | -195 | 48,160 | 47,358 | -19 |  |  |  | 980 | 48,319
Loans and Advances to customers | 642,678 | -5,984 |  | 1,306 | 4,176 | -6,619 | 635,557 | 622,100 | -5,274 |  | 1,487 | 3,178 | 6,059 | 627,550
Total on-balance (IFRS 9 eligible) | 817,587 | -6,071 | 1,681 | 20,701 | 7,855 | -5,580 | 836,173 | 817,585 | -5,334 | 3,324 | 4,890 | 6,466 | 7,229 | 834,158
Guarantees and irrevocable facilities (IFRS 9 eligible) | 149,732 | -29 |  |  |  |  |  | 134,122 | -34 |  |  |  |  |
Total Gross Carrying Amount (IFRS 9 eligible) | 967,319 | -6,101 |  |  |  |  |  | 951,707 | -5,368 |  |  |  |  |

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 value adjustments on hedged items, deferred acquisition costs on residential mortgages and
a receivable which is offset against a liquidity facility.

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> Credit risk
ING Bank Annual Report 2022 83
Portfolio quality (*)
The table below describes the portfolio composition over the different IFRS 9 stages and rating classes. The
Stage 1 portfolio represents 91.5% (2021: 93.5%) of the total gross carrying amounts, mainly composed of
investment grade, while Stage 2 makes up 7.3% (2021: 5.2%) and Stage 3 makes up 1.2% (2021: 1.3%) of
the total gross carrying amounts, respectively.

Gross carrying amount per IFRS 9 stage and rating class (*)1,2,3
in € million | 12-month ECL (Stage 1) | Lifetime ECL not credit impaired (Stage 2) | Lifetime ECL credit impaired (Stage 3) | Total
2022
Rating class | Gross Carrying Amount | Provisions | Gross Carrying Amount | Provisions | Gross Carrying Amount | Provisions | Gross Carrying Amount | Provisions
Investment grade | 1 (AAA) | 100,885 | 2 | 284 |  |  |  | 101,169 | 2
2-4 (AA) | 98,181 | 5 | 2,493 | 1 |  |  | 100,675 | 6
5-7 (A) | 177,617 | 23 | 4,596 | 4 |  |  | 182,214 | 27
8-10 (BBB) | 320,972 | 98 | 14,714 | 29 |  |  | 335,687 | 127
Non-Investment grade | 11-13 (BB) | 155,910 | 277 | 17,365 | 91 |  |  | 173,275 | 368
14-16 (B) | 23,649 | 168 | 19,386 | 471 |  |  | 43,035 | 639
17 (CCC) | 7,671 | 8 | 4,572 | 194 |  |  | 12,244 | 202
Substandard grade | 18 (CC) |  |  | 5,198 | 595 |  |  | 5,198 | 595
19 (C) |  |  | 2,116 | 293 |  |  | 2,116 | 293
Non-performing loans | 20-22 (D) |  |  |  |  | 11,708 | 3,841 | 11,708 | 3,841
Total | 884,886 | 581 | 70,725 | 1,679 | 11,708 | 3,841 | 967,319 | 6,101

1 Compared to the credit risk portfolio, the differences are mainly undrawn committed amounts (€150.1 billion) and other positions (€4.4 billion) not included in Credit outstandings and non-IFRS 9 eligible assets (€116.1 billion, mainly guarantees, letters of credit and pre-
settlement exposures) included in Credit outstandings.
2 For a reference to the Notes in the consolidated financial statements, we refer to the table ‘Reconciliation between credit risk categories and financial position’.
3 IAS 37 provisions are established for non-credit replacement guarantees not in the scope of IFRS 9. Total IAS 37 provisions (€109 million) are excluded.

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> Credit risk
ING Bank Annual Report 2022 84

Gross carrying amount per IFRS 9 stage and rating class (*)1,2,3
in € million | 12-month ECL (Stage 1) | Lifetime ECL not credit impaired (Stage 2) | Lifetime ECL credit impaired (Stage 3) | Total
2021
Rating class | Gross Carrying Amount | Provisions | Gross Carrying Amount | Provisions | Gross Carrying Amount | Provisions | Gross Carrying Amount | Provisions
Investment grade | 1 (AAA) | 107,788 | 3 |  |  |  |  | 107,788 | 3
2-4 (AA) | 106,673 | 5 | 197 |  |  |  | 106,870 | 5
5-7 (A) | 152,255 | 17 | 1,001 | 1 |  |  | 153,256 | 17
8-10 (BBB) | 328,301 | 73 | 7,232 | 14 |  |  | 335,533 | 87
Non-Investment grade | 11-13 (BB) | 162,912 | 208 | 14,679 | 86 |  |  | 177,592 | 294
14-16 (B) | 26,852 | 185 | 17,931 | 404 |  |  | 44,783 | 589
17 (CCC) | 5,377 | 10 | 4,354 | 198 |  |  | 9,730 | 207
Substandard grade | 18 (CC) |  |  | 2,314 | 173 |  |  | 2,314 | 173
19 (C) |  |  | 1,769 | 142 |  |  | 1,769 | 142
Non-performing loans | 20-22 (D) |  |  |  |  | 12,072 | 3,851 | 12,072 | 3,851
Total | 890,158 | 501 | 49,476 | 1,016 | 12,072 | 3,851 | 951,707 | 5,368

1 Compared to the credit risk portfolio, the differences are mainly undrawn committed amounts (€133.3 billion) not included in Credit outstandings and non-IFRS 9 eligible assets (€95.1 billion, mainly guarantees, letters of credit and pre-settlement exposures) included in Credit
outstandings.
2 For a reference to the Notes in the consolidated financial statements, we refer to the table ‘Reconciliation between credit risk categories and financial position’.
3 IAS 37 provisions are established for non-credit replacement guarantees not in the scope of IFRS 9. Total IAS 37 provisions (€114.4 million) are excluded.
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 €0.4 billion from €12.1 billion as of 31 December 2021 to
€11.7 billion as of 31 December 2022, mainly as a result of write-offs and generally low inflow into NPL
(credit impaired) in 2022. Stage 3 provisions remained however flat at €3.8 billion, reflecting worsened
macroeconomic outlook.
•Stage 2 gross carrying amount increased by €21.2 billion from €49.5 billion as of 31 December 2021 to
€70.7 billion. This is mainly caused by the significant lifetime PD trigger (€14.8 billion) driven by
downgrades of the Russian portfolio and economic turmoil. Furthermore, the implementation of a
stricter PD backstop methodology has driven the increase in Stage 2 gross carrying amounts,(€11.4
billion, mainly investment grade exposures). Other Stage 2 triggers such as the 30 Days past due and
watchlist triggers (€1.2 billion and €1.1 billion respectively), were more than offset by the forbearance
trigger (-€6.4 billion). For the latter, a two-year probation period is required before a client can move back
to Stage 1 and the decrease relates to the fact that the start of the Covid-19 pandemic is now more than
two years ago.
•Stage 2 provisions increased by €0.7 billion to €1.7 billion as of 31 December 2022, largely driven by the
migration of the Russian portfolio to Stage 2 and worsened macro-economic outlook. The
implementation of the threefold increase in lifetime PD backstop trigger had limited impact on provisions
as it mainly impacts investment grade exposures.

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ING Bank Annual Report 2022 85
•In 2022, the largest increases in Stage 2 by sector were in Non-bank financial institutions, Real estate,
Chemicals health & pharmaceuticals and Lower public administration of €3.5 billion, €2.8 billion, €2.5
billion and €2.1 billion respectively The increase in Stage 2 for non-bank financial institutions mainly
resulted from the implementation of the threefold increase in lifetime PD backstop trigger, that mainly
impacts investment grade exposures. Other drivers were downgrades in the Russian portfolio and
economic turmoil. The largest decreases were in Automotive and Transportation & logistics with €0.9
billion and €0.6 billion releases respectively. The largest Stage 2 outstandings per economic sector as of
31 December 2022 are Real estate, Services, Natural resources and Non-bank financial institutions
representing 10%, 7%, 7% and 7% of the total Stage 2 gross carrying amounts respectively.
Additional information on macroeconomic scenarios is included in the section ‘Macroeconomic scenarios
and sensitivity analysis of key sources of estimation uncertainty’.

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ING Bank Annual Report 2022 86

Changes in gross carrying amounts and loan loss provisions (*)1, 2
in € million | 12-month ECL (Stage 1) | Lifetime ECL not credit impaired (Stage 2) | Lifetime ECL credit impaired (Stage 3) | Total
2022 | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions
Opening balance | 890,158 | 501 | 49,476 | 1,016 | 12,072 | 3,851 | 951,707 | 5,368
Transfer into 12-month ECL (Stage 1) | 8,513 | 21 | -8,105 | -142 | -408 | -47 |  | -168
Transfer into lifetime ECL not credit impaired (Stage 2) | -42,439 | -76 | 43,222 | 730 | -784 | -90 |  | 564
Transfer into lifetime ECL credit impaired (Stage 3) | -3,524 | -8 | -1,216 | -82 | 4,740 | 1,234 |  | 1,144
Net remeasurement of loan loss provisions |  | 8 |  | 223 |  | 199 |  | 430
New financial assets originated or purchased | 248,443 | 228 |  |  |  |  | 248,443 | 228
Financial assets that have been derecognised | -138,250 | -70 | -11,312 | -94 | -2,805 | -215 | -152,366 | -379
Net drawdowns and repayments | -78,015 |  | -1,340 |  | 21 |  | -79,334 |
Changes in models/risk parameters |  | -8 |  | 13 |  | 25 |  | 30
Increase in loan loss provisions |  | 95 |  | 648 |  | 1,106 |  | 1,849
Write-offs |  |  |  | -1 | -1,129 | -1,129 | -1,130 | -1,130
Recoveries of amounts previously written off |  |  |  |  |  | 71 |  | 71
Foreign exchange and other movements |  | -15 |  | 16 |  | -58 |  | -57
Closing balance | 884,886 | 581 | 70,725 | 1,679 | 11,708 | 3,841 | 967,319 | 6,101

1 Stage 3 Lifetime credit impaired provision includes €4 million on Purchased or Originated Credit Impaired.
2 The addition to the loan provision (in the consolidated statement of profit or loss) amounts to €1.861 million of which €1.850 million related to IFRS 9 eligible financial assets, -€3 million related to non-credit replacement guarantees and €14 million to modification gains and
losses on restructured financial assets.

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ING Bank Annual Report 2022 87

Changes in gross carrying amounts and loan loss provisions (*)1,2
in € million | 12-month ECL (Stage 1) | Lifetime ECL not credit impaired (Stage 2) | Lifetime ECL credit impaired (Stage 3) | Total
2021 | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions
Opening balance | 844,020 | 581 | 59,313 | 1,476 | 13,398 | 3,797 | 916,732 | 5,854
Transfer into 12-month ECL (Stage 1) | 15,157 | 20 | -14,322 | -279 | -835 | -54 |  | -313
Transfer into lifetime ECL not credit impaired (Stage 2) | -19,737 | -32 | 20,537 | 206 | -800 | -74 |  | 100
Transfer into lifetime ECL credit impaired (Stage 3) | -2,166 | -13 | -1,589 | -96 | 3,755 | 820 |  | 712
Net remeasurement of loan loss provisions |  | -130 |  | -228 |  | 404 |  | 46
New financial assets originated or purchased | 208,501 | 149 |  |  |  |  | 208,501 | 149
Financial assets that have been derecognised | -125,819 | -73 | -11,935 | -104 | -1,898 | -237 | -139,652 | -414
Net drawdowns and repayments | -29,799 |  | -2,526 |  | -694 |  | -33,019 |
Changes in models/risk parameters |  | 12 |  | 41 |  | 130 |  | 184
Increase in loan loss provisions |  | -67 |  | -460 |  | 989 |  | 462
Write-offs |  |  |  |  | -854 | -854 | -854 | -854
Recoveries of amounts previously written off |  |  |  |  |  | 45 |  | 45
Foreign exchange and other movements |  | -13 |  | 1 |  | -125 |  | -138
Closing balance | 890,158 | 501 | 49,476 | 1,016 | 12,072 | 3,851 | 951,707 | 5,368

1 Stage 3 Lifetime credit impaired provision includes €4 million on Purchased or Originated Credit Impaired.
2 The addition to the loan provision (in the consolidated statement of profit or loss) amounts to € 516 million of which € 462 million related to IFRS-9 eligible financial assets, € 43 million related to non-credit replacement guarantees and € 11 million to modification gains and
losses on restructured financial assets.

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ING Bank Annual Report 2022 88

Exposure per stage, coverage ratio and stage ratio’s 2
in € million | 2022 | 2021
Balance sheet | Gross Carrying Amount | Allowances for credit losses | Coverage ratio | Stage Ratio | Gross Carrying Amount | Allowances for credit losses | Coverage ratio | Stage Ratio
Loans and advances to Banks (including Central Banks) | 97,146 | 49 | 0.1% |  | 120,089 | 28 |  |
Stage 1 | 95,788 | 9 | % | 99% | 119,896 | 24 |  | 100%
Stage 2 | 1,339 | 20 | 1.5% | 1% | 193 | 4 | 2.0% |
Stage 3 | 20 | 20 | 100.0% |  |  |  |  |
Loans and advances to Customers | 643,317 | 5,984 | 0.9% |  | 622,100 | 5,274 | 0.8% |
of which: Residential mortgages | 326,928 | 677 | 0.2% |  | 310,068 | 513 | 0.2% |
Stage 1 | 312,165 | 75 |  | 96% | 297,915 | 37 |  | 96%
Stage 2 | 11,877 | 176 | 1.5% | 4% | 8,777 | 128 | 1.5% | 3%
Stage 3 | 2,886 | 426 | 14.8% | 1% | 3,376 | 348 | 10.3% | 1%
Of which: Consumer Lending (excl. Residential mortgages) | 26,348 | 990 | 3.8% |  | 32,423 | 1,409 | 4.3% |
Stage 1 | 23,101 | 184 | 0.8% | 88% | 28,554 | 217 | 0.8% | 88%
Stage 2 | 2,145 | 223 | 10.4% | 8% | 2,654 | 367 | 13.8% | 8%
Stage 3 | 1,102 | 583 | 52.9% | 4% | 1,215 | 825 | 67.9% | 4%
Of which: Loans to public authorities | 17,272 | 17 | 0.1% |  | 14,333 | 12 | 0.1% |
Stage 1 | 15,977 | 4 |  | 93% | 13,906 | 2 |  | 97%
Stage 2 | 1,120 | 7 | 0.6% | 7% | 344 | 5 | 1.5% | 2%
Stage 3 | 175 | 6 | 3.4% | 1% | 84 | 4 | 5.1% | 1%
Of which: Corporate Lending | 272,769 | 4,300 | 1.6% |  | 265,276 | 3,340 | 1.3% |
Stage 1 | 227,167 | 279 | 0.1% | 83% | 229,906 | 185 | 0.1% | 87%
Stage 2 | 38,497 | 1,225 | 3.2% | 14% | 28,568 | 505 | 1.8% | 11%
Stage 3 | 7,105 | 2,795 | 39.3% | 3% | 6,801 | 2,649 | 39.0% | 3%
Other IFRS 9 Eligible Financial Instruments 1 | 226,856 | 67 |  |  | 209,518 | 66 |  |
Stage 1 | 210,689 | 29 |  | 93% | 199,982 | 35 |  | 95%
Stage 2 | 15,746 | 27 | 0.2% | 7% | 8,941 | 6 | 0.1% | 4%
Stage 3 | 421 | 11 | 2.7% | % | 596 | 24 | 4.1% |
Total Gross Carrying Amount (IFRS 9 eligible) | 967,319 | 6,101 | 0.6% |  | 951,707 | 5,368 | 0.6% |

1 Includes Off balance sheet IFRS 9 eligible guarantees and irrevocable facilities
2 The exposure classification to residential mortgages, consumer lending and corporate lending is aligned to the regulatory definition

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ING Bank Annual Report 2022 89
Modification of financial assets (*)
The table below provides the following information:
•Financial assets that were modified during the year (i.e. qualified as forborne) while they had a loss
allowance measured at an amount equal to lifetime ECL.
•Financial assets that were reclassified to stage 1 during the period.

Financial assets modified (*)
in € million | 2022 | 2021
Financial assets modified during the period |  |
Amortised cost before modification | 1,304 | 2,595
Net modification results | -124 | -47
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 | 2,382 | 448

Macroeconomic scenarios and sensitivity analysis of key sources of estimation
uncertainty (*)
Methodology (*)
Our methodology in relation to the adoption and generation of macroeconomic scenarios is described in
this section. We continue to follow this methodology in generating our probability-weighted ECL, with
consideration of alternative scenarios and management adjustments supplementing this ECL where, in
management's opinion, 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). The Oxford Economics’ Global Economic Model (OEGEM) 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 two panels of ING experts. The first panel
consists of economic experts from Global Markets Research and risk and modelling specialists, while the
second panel consists of relevant senior managers.
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 OEGEM.
To understand the baseline level of uncertainty around any forecast, Oxford Economics keeps track of all its
deviations (so called forecast errors) of the past 20 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, Oxford Economics 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 for the 90th percentile of that distribution because this
corresponds with the way risk management earnings-at-risk is defined within the Bank. The upside scenario
is represented by the 10th percentile of the distribution. The applicable percentiles of the distribution imply
a 20% probability for each alternative scenario. Consequently, the baseline scenario has a 60% probability
weighting. Please note that, given their technical nature, the downside and upside scenarios are not based
on an explicit specific narrative.
Macroeconomic scenarios applied (*)
The loan loss provisions are based on the December 2022 consensus forecasts.

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ING Bank Annual Report 2022 90
Baseline assumptions (*)
The general picture that the consensus conveys is that global economic growth is being challenged by
persistent inflationary pressures which are being met by central banks lifting interest rates. The consensus
expects recession to occur in many European countries in 2022-2023, while the US economy is anticipated
to stagnate. Economic growth is expected to resume in the years thereafter as inflation normalises and
monetary conditions become less tight. In economies that have experienced a notable surge in house prices
during the pandemic and its aftermath, affordability pressures amid the higher interest rate environment
are expected to lead to a moderation of growth or price declines in the near to medium-term.
The December 2022 consensus expects global output (as measured by the weighted average GDP growth
rate of ING's 25 main markets) to slow further from 6.0% in 2021, to 2.5% in 2022 and 1.3% in 2023. For
2024-2025, economic growth is expected to pick up again to 2.4%.
The US economy is expected to stagnate in 2023 as high inflation, rising interest rates, supply chain
difficulties, softer labour market dynamics, and global headwinds weaken demand. Consumer spending
growth is under downward pressure as slower employment gains curb income growth and pandemic-
related savings have diminished. With the headwinds seen fading slowly, the US economy is expected to
gather strength again in 2024. The consensus expects the growth rate of the US economy to fall from 1.9%
in 2022 to 0.2% in 2023 and to recover to on average 1.7% in 2024-2025.
Eurozone economies are dealing with the consequences of the ongoing war in Ukraine, broadening
inflationary pressures and a general deterioration of sentiment across industries and consumers.
The ECB has shifted to a hawkish tilt but government fiscal support targeting higher energy prices is
softening the economic pain in many countries. Overall, the eurozone economy is forecasted to stagnate in
2023, but Germany – as well as some other countries – faces recession reflecting its large exposure to gas
supply cuts, relatively large manufacturing sector and exposure to a slower growing Chinese economy.
Elsewhere in Europe, the outlook is equally bleak. In Poland, economic fallout from the war in Ukraine and
the related energy price shock point to a significant economic slowdown from 5.0% in 2022 to 1.0% in 2023.
However, the scope for a rise in unemployment is seen to be limited as the Polish labour market remains
tight, partially due to population ageing. As in the eurozone, the central bank is tightening monetary policy,
but fiscal policy remains expansive. The consensus expectation for Turkey is also for economic growth to
ease as the economic slowdown in Europe weighs on external demand and high inflation persists. The
consensus sees economic growth in Turkey slowing from 5.2% in 2022, to on average 2.4% in 2023-2024
and increasing again to 3.0% in 2025.
After a weak growth rate of 3.1% in 2022, economic growth in China is expected to pick-up to on average
4.7% in 2023-2025. The drag exerted by the authorities’ Covid-19 policies is assumed to moderate, while
state investment will support demand. However, the real estate downturn continues to weigh on the
outlook.
The global economic slowdown, together with tighter monetary policy and high inflation is weighing on
economic growth in Australia. After growing by 3.8% in 2022, the outlook sees a growth rate of 1.8% for
2023-2024 and some pick-up to 2.6% for 2025. However, despite the economic slowdown, conditions in the
labour market are expected to remain tight.
When compared to the December 2021 consensus forecast, used for the 2021 Annual Report, the December
2022 forecast assumes much weaker economic circumstances. Global GDP was expected to increase by
2.5% in 2022 (compared to 4.1% assumed before) and 1.3% in 2023 (3.1% assumed before). The downgrade
reflects the economic impacts of the war in Ukraine and tighter monetary conditions.
Alternative scenarios and risks (*)
Because of the possible consequences of the war in Ukraine, uncertainty surrounding the forecasts is higher
than usual. This relates in particular to uncertainty about European energy supplies and worries about more
persistent high inflation. To take the general increase of uncertainty surrounding the forecasts into account,
the dispersion of the alternative scenarios has been set again at the widened level used for year-end 2021
provisioning (the half-widened dispersion). As a result, the near-term dispersion of the forward-looking
distributions (from which the alternative scenarios are derived) is larger than in normal times. Meanwhile, at
the end of the scenario horizon the dispersion has remained unchanged and hence is comparable to
scenarios generated prior to the war in Ukraine.
The baseline scenario assumes a significant easing of inflation in 2023 and relatively resilient labour
markets. However, a longer period of weakness, due to stickier inflation and more aggressive monetary
policy tightening that triggers a more notable softening of the labour market and greater falls in financial
asset and property prices, could lead to a more protracted and deeper economic slowdown. As such, the
balance of risks to the baseline outlook is negative and the alternative scenarios have a downward skew in
line with the outcomes of Oxford Economics’ Global Risk Survey. The downward skew is less negative
compared to what has been applied for year-end 2021 at which time – set against a higher baseline – apart
from higher inflation, worries about supply chain disruptions and further corona virus waves were being
seen as top near-term downside risks.
The downside scenario – though technical in nature – sees for most countries a fast deceleration of
economic growth followed by a recession. Unemployment increases strongly in this scenario and house
prices in most countries show outright falls. The downside scenario captures a possible escalation of the war
in Ukraine and a more pronounced and prolonged surge in inflation.

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ING Bank Annual Report 2022 91
The upside scenario – while equally technical in nature – reflects the possibility of a better economic outturn
if the war in Ukraine ended quickly, fuelling a rebound in consumer spending. The recovery is further
supported by looser monetary policy as weaker inflation prompts central banks to hold back tightening.
Management adjustments applied this year (*)
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 can also be applied
where the impact of the updated macroeconomic scenarios is over- or under-estimated by the IFRS 9
models.
ING has internal governance frameworks and controls in place to assess the appropriateness of all
management adjustments.

Management adjustments to ECL models (*)
in € million | 2022 | 2021
Economic sector based adjustments | 71 | 341
Second order impact adjustments | 334 |
Payment holiday adjustments |  | 32
Mortgage portfolio adjustments | 105 | 124
Other Post Model Adjustments 1 | -57 | 121
Total management adjustments | 453 | 618
1 Prior period figure has been updated to conform to current year presentation. |  |

December 2021 management adjustments included an economic sector-based management adjustment
of €341 million because of delays in defaults occurring in the Covid-19-related crisis, mainly as a result of
government support programmes. In determining the sector-based management adjustment, a heatmap
approach was used to adjust the probability of default for sectors where businesses are significantly
impacted by the pandemic. In 2022, as it became clearer the Covid-19 pandemic had less impact than
expected on the number of defaults, the economic sector-based management adjustment has been largely
released and while at the same time management adjustments for the second order impact of the war in
Ukraine were introduced (see below). Of the remaining economic sector based adjustments of €71 million as
of 31 December 2022, €61 million relates to Business Banking clients that have benefited from Covid-19
related government support programmes in the Netherlands such as deferral of tax payments that ended in
the second half of 2022, and €10 million relates to an overlay for livestock farming sector in the
Netherlands. In the Netherlands, nitrogen reduction targets affect the livestock farming sector mainly
because of endorsed closing activities nearby Natura 2000 areas and because of expected transition to
other business models in the sector. As these specific risks are not incorporated in the model ECL, an overlay
was recognised.
ING has performed an assessment for both WB and Retail Banking on the impact of the war in Ukraine, the
increase in energy prices and other second order macroeconomic developments such as an increase in
inflation and rising interest rates. This resulted in a second order impact overlay of €334 million in total as of
31 December 2022, of which €164 million relates to Retail Banking segments and €170 million to the
Wholesale Banking segment.
As the credit risk models assume that these second order effects materialise via other risk drivers such as
GDP and unemployment rates with a delay, an overlay approach was determined to timely estimate the
Expected Credit Losses related to reduced repayment capacity and affordability for private individuals and
business clients in the Retail Banking segment. The €164 million includes an overlay of €22 million for clients
participating in the payment holiday scheme in Belgium that was introduced in 2022 to support customers
impacted by the inflation and high energy prices.
In WB, it was assessed that the economic effects of Covid-19 was not the highest risk anymore and that
other risks have emerged – mainly high energy prices, high interest rates and inflation, supply chain issues
and staffing shortages. A heatmap approach was used to adjust the probability of default for clients that
are expected to be significantly impacted by these emerged risks.
Given Covid-19-related payment holiday programmes have generally expired, this management
adjustment has been fully released in 2022.
Model based ECL of mortgage portfolios has decreased over the past years and until the third quarter of
2022, driven by significant increase of house prices in various countries. Management adjustments of €105
million in total, mainly in Stage 2 and 3, have been recognised by ING in the Netherlands, Belgium, Germany
and Australia to maintain an appropriate level of ECL and reflecting a potential impact of market
uncertainty on the recovery value of residential real estate (impacted by higher inflation and interest rates).
The management adjustment for the Netherlands and part of the Belgian mortgage portfolio was
determined by developing three alternative macroeconomic forecast scenarios, in addition to the consensus
base, up- and down-scenarios, that reflect a correction in the house prices in the next three years bringing it
back in line with the historical growth rate. For other countries, management adjustments were determined
by calculating the impact of lower house prices on LTVs and LGDs.
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. These result
from both regular model maintenance and ING’s multiyear programme to update ECL models for the new
definition of default. These adjustments will be removed once updates to the specific models have been
implemented.

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> Credit risk
ING Bank Annual Report 2022 92
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 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. ING also observes that,
in general, the WB business is more sensitive to the impact of forward-looking macroeconomic scenarios.
The purpose of the sensitivity analysis is to enable the reader to understand the extent of the impact from
the upside and downside scenario on model-based reportable ECL.
In the table below the real GDP is presented in percentage year-on-year change, the unemployment in
percentage of total labour force and the house price index (HPI) in percentage year-on-year change.

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ING Bank Annual Report 2022 93

Sensitivity analysis as at December 2022 (*)
|  | 2023 | 2024 | 2025 | Un-weighted ECL (€ mln) | Probability- weighting | Reportable ECL (€ mln)1
Netherlands Upside scenario | Real GDP | 2.2 | 2.3 | 2.9 | 274 | 20% | 381
Unemployment | 4.0 | 3.9 | 3.8
HPI | 13.0 | 11.8 | 2.5
Baseline Scenario | Real GDP | 0.2 | 1.4 | 1.8 | 349 | 60%
Unemployment | 4.5 | 4.8 | 4.9
HPI | 3.7 | 3.7 | 2.4
Downside scenario | Real GDP | -4.2 | 0.7 | 0.9 | 583 | 20%
Unemployment | 6.4 | 7.8 | 8.7
HPI | -8.0 | -6.5 | 2.2
Germany Upside scenario | Real GDP | 1.7 | 2.3 | 1.8 | 606 | 20% | 745
Unemployment | 2.6 | 2.2 | 1.8
HPI | 0.6 | 3.9 | 6.2
Baseline Scenario | Real GDP | -0.7 | 1.4 | 1.5 | 726 | 60%
Unemployment | 3.2 | 3.1 | 3.1
HPI | -1.8 | 0.9 | 2.7
Downside scenario | Real GDP | -4.8 | 0.1 | 1.0 | 942 | 20%
Unemployment | 4.8 | 5.3 | 5.6
HPI | -6.2 | -3.3 | -1.4
Belgium Upside scenario | Real GDP | 1.7 | 2.1 | 2.1 | 535 | 20% | 596
Unemployment | 5.5 | 5.5 | 5.3
HPI | 2.3 | 2.6 | 3.1
Baseline Scenario | Real GDP | 0.0 | 1.6 | 1.8 | 584 | 60%
Unemployment | 6.1 | 6.3 | 6.1
HPI | 1.4 | 2.2 | 2.5
Downside scenario | Real GDP | -3.2 | 1.0 | 1.5 | 692 | 20%
Unemployment | 7.5 | 8.5 | 8.4
HPI | -1.2 | 0.9 | 1.2
United States Upside scenario | Real GDP | 3.0 | 1.5 | 3.4 | 100 | 20% | 221
Unemployment | 3.4 | 2.8 | 2.5
HPI | 3.7 | 7.4 | 8.1
Baseline Scenario | Real GDP | 0.2 | 1.1 | 2.3 | 188 | 60%
Unemployment | 4.3 | 4.4 | 3.9
HPI | 2.5 | 2.2 | 2.8
Downside scenario | Real GDP | -4.1 | 0.2 | 0.6 | 442 | 20%
Unemployment | 6.4 | 7.7 | 8.2
HPI | -1.2 | -3.8 | -3.5

1 Excluding management adjustments.

Sensitivity analysis as at December 2021 (*)
|  | 2022 | 2023 | 2024 | Un-weighted ECL (€ mln) | Probability- weighting | Reportable ECL (€ mln)1
Netherlands Upside scenario | Real GDP | 5.1 | 2.9 | 2.7 | 259 | 20% | 307
Unemployment | 3.2 | 2.9 | 2.9
HPI | 23.3 | 10.9 | 0.9
Baseline Scenario | Real GDP | 3.4 | 2.0 | 1.7 | 289 | 60%
Unemployment | 3.7 | 4.1 | 4.3
HPI | 13.1 | 2.8 | 0.8
Downside scenario | Real GDP | -1.5 | 1.2 | 0.7 | 411 | 20%
Unemployment | 5.6 | 6.8 | 7.8
HPI | 0.3 | -7.7 | 0.6
Germany Upside scenario | Real GDP | 6.2 | 3.1 | 1.6 | 457 | 20% | 483
Unemployment | 2.9 | 2.2 | 1.9
HPI | 12.9 | 7.9 | 5.3
Baseline Scenario | Real GDP | 4.0 | 2.3 | 1.4 | 475 | 60%
Unemployment | 3.4 | 3.1 | 3.1
HPI | 10.4 | 4.6 | 1.9
Downside scenario | Real GDP | -0.6 | 0.9 | 0.8 | 535 | 20%
Unemployment | 5.0 | 5.4 | 5.7
HPI | 5.3 | 0.4 | -2.1
Belgium Upside scenario | Real GDP | 4.6 | 2.5 | 2.0 | 364 | 20% | 393
Unemployment | 5.6 | 5.6 | 5.9
HPI | 3.9 | 2.7 | 2.9
Baseline Scenario | Real GDP | 3.1 | 2.0 | 1.8 | 383 | 60%
Unemployment | 6.1 | 6.3 | 6.3
HPI | 3.0 | 2.3 | 2.3
Downside scenario | Real GDP | -0.4 | 1.4 | 1.4 | 451 | 20%
Unemployment | 7.6 | 8.6 | 9.0
HPI | 0.4 | 1.0 | 1.0
United States Upside scenario | Real GDP | 6.7 | 2.4 | 3.1 | 28 | 20% | 75
Unemployment | 3.5 | 2.5 | 2.4
HPI | 10.4 | 8.1 | 8.7
Baseline Scenario | Real GDP | 4.0 | 2.5 | 2.1 | 55 | 60%
Unemployment | 4.0 | 3.7 | 3.7
HPI | 9.1 | 3.0 | 3.3
Downside scenario | Real GDP | -0.7 | 1.1 | 0.3 | 183 | 20%
Unemployment | 6.5 | 7.4 | 8.0
HPI | 5.3 | -3.2 | -3.0

1 Excluding management adjustments.

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> Credit risk
ING Bank Annual Report 2022 94
When compared to the sensitivity analysis of 2021, the macroeconomic inputs for 2022 and 2023 are less
favourable, driven by a worsened macroeconomic outlook as a result of the war in Ukraine as well as its
indirect effects such as inflation and increasing interest rates. Both 2021 and 2022 contain half-widened
dispersion around upside and downside scenarios, for 2021. This reflects continuing but decreased short-
term uncertainty relating to the impact of Covid-19 and for 2022 reflecting short-term uncertainty around
the war in Ukraine and its indirect effects. The increase in reportable ECL compared to 2021 is mainly caused
by higher model ECL amounts as per December 2022 as a result of increased provisions for Russia-related
exposures in Stage 2.
While the table above does give a high-level indication of the sensitivity of the outputs to the different
scenarios, it does not provide insight into the interdependencies and correlations between different
macroeconomic variable inputs. On a total ING level, the unweighted ECL for all collective provisioned clients
in the upside scenario was €2,680 million, in the baseline scenario €3,177 million and in the downside
scenario €4,456 million compared to €3,209 million reportable collective provisions as at 31 December 2022
(excluding all management adjustments). This reconciles as follows to the reported ECL’s:

Reconciliation of model (reportable) ECL to total ECL (*)
in € million | 2022 | 2021
Total model ECL 1 | 3,209 | 2,408
ECL from individually assessed impairments | 2,439 | 2,342
ECL from management adjustments | 453 | 618
Total ECL | 6,101 | 5,368
1 Prior period figure has been updated to conform to current year presentation. |  |

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 since initial origination or purchase. ING considers the credit risk of an asset
to have significantly increased when either a threshold for absolute change in lifetime probability of default
(PD) or a relative change in lifetime PD is reached.
It should be noted that the lifetime PD thresholds are not the only drivers of stage allocation. An asset can
also change stages as a result of other triggers, such as having over 30 days arrears, being on a watch list or
being forborne. Refer to section 1.7.8 of Note 1 ‘Basis of preparation and significant accounting policies’ for
an exhaustive list. Furthermore, this analysis is rudimentary in the sense that other parameters would
change when an asset changes stages.
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 thresholds for the absolute change in lifetime PD vary between 75bps for Retail
portfolios, 100bps for WB and 250bps for SMEs, based on the characteristics of the specific portfolio. ING is in
the process of refining the thresholds on a portfolio level. These have already been implemented for more
than 20 percent of the portfolio, resulting in deviating absolute lifetime PD thresholds.
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 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 that is optimised depending on the observed default rates and overall average riskiness
of the portfolio. While the scaling factor is associated with a whole portfolio/segment, the PD at origination
is facility-specific and, in this sense, the relative threshold may differ facility by facility.
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 said 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
In the table below 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 2021 and year-end 2022.

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ING Bank Annual Report 2022 95
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.

Quantitative SICR thresholds (*)
| 2022 | 2021
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 | 2.7 | 2.3 | 2.7 | 2.2
Consumer Lending | 2.8 | 1.8 | 2.8 | 1.7
Business Lending | 2.8 | 2.1 | 4.0 | 2.2
Governments and Fin. Institutions | 3.0 | 1.9 | 7.9 | 2.2
Other Wholesale Banking | 2.8 | 1.9 | 4.5 | 2.0

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. In 3Q 2022, following up an ECB request, a
new backstop trigger was implemented. The new trigger forces Stage 2 classification in case the lifetime PD
at reporting date has increased more than three times with respect to the origination, regardless of the
actual staging thresholds in force for a given portfolio. The new requirement entails that the threshold ratio
in the table above is effectively capped at a threefold increase for December 2022. The effect of this trigger
is especially apparent in the average thresholds ratio for investment grade facilities when confronting 2021
and 2022 figures. Since for investment grade assets thresholds tend to be looser given the good quality of
underlying counterparties ratings, the backstop trigger is more impactful.
In terms of impact on ING portfolio, the application of the new backstop trigger resulted in an increase of
Stage 2 exposure. However, since the trigger impacts mainly good quality assets for which regular staging
thresholds are typically above a threefold increase in PD, the corresponding impact in provisions was
limited.
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 Bank level, the total model ECL, which is the ECL collective-assessment without taking
management adjustments into account, is €3,209 million (2021: €2,408 million) of which performing assets
constitute €1,884 million (2021: €1,003 million) . To demonstrate the sensitivity of the ECL to these PD
thresholds bands, an analysis was run on all collectively-assessed assets, which assumed all assets were
below the threshold (Stage 1) and apportioned a 12-month ECL. On the same asset base, analysis was run
which assumed all performing assets were above the threshold (Stage 2) and apportioned a lifetime ECL.
This gave rise to hypothetical collective-assessment ECLs of €1,348 million (2021: €634 million) and €3,391
million (2021: €2,232 million) respectively. Please note that in this analysis, all other ECL risk parameters
(except for the stage) were kept equal.

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> Credit risk
ING Bank Annual Report 2022 96
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. This means that financial instruments in
the trading books should be free of trade restrictions. 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.
ING recognises the importance of sound market risk management and bases its market risk management
framework on the need to identify, assess, control and manage market risks. The approach consists of five
recurring activities: risk identification, risk assessment, risk control, risk monitoring and risk reporting.
Governance (*)
A governance framework has been established defining specific roles and responsibilities of business
management units, market risk management units, and internal approval bodies per activity.
Supervision of market risk falls under the responsibility of the EB/MBB and is delegated to the ALCO function,
where ALCO Bank is the highest approval authority and sets the market risk appetite. ALCO Bank monitors
ING’s adherence to the risk appetite for market risk and sets additional limits where appropriate. These limits
are cascaded through the organisation through lower level ALCOs. This ALCO structure facilitates top-down
risk management, limit setting, and the monitoring and control of market risk.
FR maintains a limit framework in line with ING’s Risk Appetite Framework. The businesses are responsible
for adhering to the limits which are reviewed on an annual basis and are ultimately approved by the ALCO
Bank. Limit excesses are reported to senior management in line with the ALM Limit excess reporting
procedure upon which the business needs to act accordingly. To adhere to the established limit framework,
ING implements hedging and risk mitigation strategies that range from the use of traditional market
instruments, such as interest rate swaps, to more sophisticated hedging strategies.
The organisational structure facilitates top-down risk management by recognising that risk taking and risk
management occur to a large extent at the regional/local level. Bottom-up reporting from regional/local
units to head office units allows each management level to assess the market risks relevant at the
respective levels.
Several committees govern communication between the parties involved in market risk management:
•The Market Risk Model Committee (MRMC, reporting to ALCO Bank), is the dedicated authority within ING
for the approval of all funding and liquidity risk, banking and trading risk and counterparty credit risk
models, methodologies and related parameters. This is comparable with the CTRC, which reports into the
GCTP.
•The Valuation Model Committee approves pricing models for trading and banking books.
Financial Risk provides risk reporting to the EB and MBB, the ALCO Bank and the senior executive
management of related business functions.
The following sections elaborate on the various elements of the risk management framework for:
•Market risk economic capital (trading and banking books).
•Market risks in banking books.
•Market risks in trading books.
Market risk economic capital (trading and banking books)
Economic capital for market risk is the economic capital necessary to withstand unexpected value
movements due to changes in market variables and model risk.
Economic capital for market risk is calculated for exposures in both banking portfolios and trading portfolios
and includes interest rate risk, credit spread risk, equity price risk, foreign exchange rate risk, customer
behaviour risk, model risks and pension risk. Economic capital for market risk is calculated using internally
developed methodologies with a 99.9% confidence level and a horizon of one year.
For the trading books, the linear interest rate risk and other risk types as well as equity investments in the
banking books, the Value at Risk (VaR) are taken as a starting point for the economic capital calculations for
market risk. The VaR is measured at a 99% confidence level with a one-day holding period.
To arrive at the economic capital for market risk, a simulation-based model is used which includes scaling to
the required confidence level and holding period. In determining this scaling factor, other factors are also
taken into account like the occurrence of large market movements (events).
Embedded options, e.g. the prepayment option and offered rate option in mortgages in the banking books,
result in non-linear interest rate risk in the banking books. Embedded options are economically hedged
using a delta-hedging methodology, leaving the mortgage portfolio exposed to convexity risk, volatility risk

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> Market risk
ING Bank Annual Report 2022 97
and model risk. For the calculation of economic capital for this non-linear interest rate risk, ING performs a
Monte Carlo simulation.
While aggregating the different economic capital market risk figures for the different portfolios,
diversification benefits (based on stressed correlations) are taken into account as it is not expected that all
extreme market movements will appear at the same moment.
Market risk in banking books (*)
ING makes a distinction 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 it is centrally managed. The scheme below presents the transfer and
management process of market risks in the banking books:

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> Market risk
ING Bank Annual Report 2022 98
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.
Governance (*)
The management of interest rate risk follows the Interest Rate Risk in the Banking Book (IRRBB) framework
as approved by ALCO Bank. This framework describes roles, responsibilities, risk metrics, and the policies and
procedures related to interest rate risk management. Furthermore, ALCO Bank reviews and sets the risk
appetite for interest rate risk, on an annual basis. The risk appetite is translated into limits for the interest
rate risk metrics.
As a result of this framework, 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.
•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. The
main objective is to maximise the economic value of the capital investment book while having stable
earnings.
Commercial activities can result in linear interest rate risk, for example, tenors and duration of new
production and re-pricing of assets differ from those of liabilities. Also, interest rate risk can arise from
customer behaviour and/or convexity risk, depending on the nature of the underlying product
characteristics.
Customer behaviour risk is defined as the potential future (value) loss due to deviations in the actual
behaviour of clients versus the modelled behaviour towards the embedded options in commercial products.
General sources of customer behaviour risk, among other things, include 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 three main product
types: funds entrusted as savings and 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. Interest rate risk can arise when there is a
misalignment between the change in market rates and adjustment of savings rates, which can either have
a positive or negative impact on the income as a consequence of the potential misalignment to the related
(assumption based) investment strategy of ING’s savings. Interest rate risk is modelled based on the stability
of the deposit 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. Savings volumes are typically
assumed to be relatively stable and less sensitive to rate changes.
Interest rate risk for mortgages arises due to prepayment possibilities in these mortgages. In modelling this
risk, both interest rate dependent pre-payments and constant prepayments are considered. Next to a
dependence on interest rates, modelled prepayments may include other effects such as loan-to-value,
seasonality and the reset date of the loan. In addition, the interest sensitivity of embedded offered rate
options may be considered.
Wholesale Banking loans typically do not experience interest rate dependent prepayment behaviour, 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 research. However, the substantial change in the interest rate environment makes extensive
research more challenging than before and may increase model risk. Models are backtested and updated
when deemed necessary in an annual procedure. Model parameters and the resulting risk measures are
approved by (local) ALCO.
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 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. However, 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

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ING Bank Annual Report 2022 99
interest rate changes, excluding the first-order effects. In some cases, convexity risk is transferred from the
commercial books to treasury books using cap/floor contracts.
In the following sections, the interest rate risk exposures in the banking books are presented. ING uses risk
measures based on both an earnings and a value perspective. Net interest income (NII)-at-risk is used to
provide the earnings perspective and the net present value (NPV)-at-risk figures provide the value
perspective. Please note that the expected interest rate risk coming forward from the business is assumed
to be linearly hedged but no additional corrective management actions are taken into account in the NPV-
at-Risk measure. In the NII-at-Risk measure, a more dynamic hedging process is taken into account.
During 2022, the following activities related to the risk measurement for IRRBB were performed:
•Annual review of the risk appetite for Market Risks in the Banking Book including further enhancement.
•Further assessment and development of sub-risk types, such as tenor basis risk, vega optionality risk and
client behaviour risk.
•Set up of standardised risk measurement related to climate risk.
•Annual review of the interest rates scenarios used for calculating NII-at-Risk and NPV-at-Risk.
•Annual savings/current account model updates.
•Annual update of parameters of prepayment models for market developments.
•A specific, internal firm-wide stress test relating to climate risk.
•Further enhancement of the IRRBB framework in relation to upcoming regulatory requirements (e.g.
anticipation on implementation and measurement of the upcoming regulatory metric NII SOT,
development of additional requirements coming forward from latest EBA guidelines).
•Improvement of the FX framework.
Net interest income (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 are included in this risk metric. NII-at-Risk is a metric
that helps provide insight to what extent ING's NII under our Dynamic Plan deviates from the interest rates
development assumed.
In its risk management, ING monitors the NII-at-Risk under a three-year timeframe. Interest rates are
stressed during the first year versus the prevailing curve, taking gradual changes over the first year. The rate
changes considered comprise both upward and downward scenarios, as well as 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 deposits client rates (mainly savings), (partially) tracking changes in market interest rates.
•Change in funding profile of mortgages, due to an expected increase or decrease in expected
prepayments.
•Higher/lower returns of (re-)investments of capital investment.
•Open interest rate positions, leading to changes in return because of different market rates.
•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 to
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,
amongst others, 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 tables below reflect a parallel, linear interest rate movement during a year
('ramped') under the assumption of balance sheet developments in line with the ING's Dynamic Plan with a
time horizon of one year.

NII-at-Risk banking books per business - year one (*)
in € million | 2022 | 2021
| Ramped, unfloored | Ramped, unfloored
parallel ▼ | parallel ▲ | parallel ▼ | parallel ▲
By business |  |  |  |
Wholesale Banking | 4 | -47 | 46 | -33
Retail Banking Benelux | -88 | 59 | -122 | 132
Retail Challengers & Growth Markets | -41 | 113 | -93 | 75
Corporate Line Banking | -18 | 18 | -58 | 58
Total | -142 | 142 | -226 | 232

EUR ramped (unfloored) is at +/- 100bps in 1 year
USD ramped (unfloored) is at +/- 120bps in 1 year
The NII-at-Risk is primarily driven by the difference in sensitivity of client liabilities, mainly savings, versus
the sensitivity of client assets and investments to rate changes. The investment of own funds only impacts
the earnings sensitivity marginally, as only a relatively small part has to be (re)invested within the one-year
horizon.

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> Market risk
ING Bank Annual Report 2022 100

NII-at-Risk banking book per currency - year one (*)
in € million | 2022 | 2021
| Ramped, unfloored | Ramped, unfloored
parallel ▼ | parallel ▲ | parallel ▼ | parallel ▲
By currency |  |  |  |
Euro | -119 | 114 | -181 | 179
US Dollar | -1 | 2 | -23 | 23
Other | -23 | 27 | -23 | 30
Total | -142 | 142 | -226 | 232

EUR ramped (unfloored) is at +/- 100bps in 1 year
USD ramped (unfloored) is at +/- 120bps in 1 year
At the end of 2022, the NII is projected to be slightly higher when interest rates rise. In this scenario, one-
year (re-) investment returns are higher than the modelled increase in client deposit rates and modelled
extra funding costs due to higher funding costs for mortgages.
The projected change in NII numbers in the tables above include projected changes in client deposit rates for
the ramped parallel up scenario. Without increasing client deposit rates, the NII-at-Risk for the parallel
ramped up scenario would be significantly higher, meaning that the actual client deposit rate tracking of
market interest rates in such scenario is a key driver in the NII development of the bank.
The change in NII under a declining or upward interest rate scenario may not be equal. This is then caused
by 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.
Year-on-year variance analysis (*)
In 2021, interest rates remained at very low levels and short-term interest rates were even negative. In
2022, interest rates in both short and longer tenors increased significantly. Central banks tightened
monetary conditions to counter high inflation specifically as a follow up to high energy prices. In 2022, the
rate environment was characterised by increasing interest rates. ING applied a dynamic hedging process, by
which interest rate risk was transferred from the business to Group Treasury and subsequently hedged in
the markets. This process mitigates interest rate risk resulting in a lower sensitivity for rate changes of ING's
NII. However, the main drivers in a potential change of NII sensitivity are balance sheet developments,
specifically relating to mortgages, loans and savings. In the eurozone, mortgage production was impacted
by an increase in interest rates. Next to the impact on new production, the prepayment incentive decreased
due to the increase in interest rates. The funds entrusted volume did not change significantly, The impact of
explicit and implicit floors on both rates of client assets and savings phased out in the course of the year on
the back of the interest rate increases. Pre-existing hedges, as executed by Group Treasury, were also
adjusted continuously throughout the year to hedge any interest rate risk coming from higher interest
rates. Given that Group Treasury is included in the Wholesale Banking risk numbers, these adjustments
changed the Wholesale Banking NII-at-Risk. Furthermore, ING’s investment of own funds took place against
a lower duration reducing sensitivity. Excluding Model Risk, the total NII-at-Risk remains relatively limited in
comparison to ING’s total interest income.
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. This does not include positive earnings in our commercial books. The NPV-at-Risk is defined as the
outcome of an instantaneous increase or decrease in interest rates from applying currency-specific
scenarios. The NPV-at-Risk asymmetry between the downward and upward shock is mainly caused by
convexity risk in the mortgage and savings portfolio.
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.

NPV-at-Risk banking books per business (*)
in € million | 2022 | 2021
| unfloored | unfloored
parallel ▼ | parallel ▲ | parallel ▼ | parallel ▲
By business |  |  |  |
Wholesale Banking | -1,474 | 1,299 | -1,477 | 1,444
Retail Banking Benelux | -307 | -76 | -953 | -202
Retail Challengers & Growth Markets | 1,327 | -1,373 | 832 | -1,111
Corporate Line Banking | 1,049 | -1,003 | 1,820 | -1,712
Total | 594 | -1,153 | 223 | -1,580

EUR (unfloored) +/- 100bp shock scenario
USD (unfloored) +/- 120bp shock scenario

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> Market risk
ING Bank Annual Report 2022 101
Year-on-year variance analysis (*)
The overall NPV sensitivity for the rates-up scenario decreased in 2022. This is mainly due to the shorter
duration at which ING strategically invests its own funds. These investments are done in the Corporate Line
Banking.
The changes in NPV-at-Risk in the segments Retail Benelux and Retail Challengers & Growth Markets were
partly offsetting, whereby the higher interest rates reduced the overall convexity. The resulting impact on
retail sensitivity of the increase in interest rates was hedged by Group Treasury in line with the internal ALM
practices. The Group Treasury exposure is reported under business line Wholesale Banking.
IBOR transition (*)
In line with the recommendations from the Financial Stability Board, a fundamental review of benchmarks
for important interest rates has been undertaken. Some interest benchmarks have been reformed, while
others have or will be replaced by risk-free rates (RFR) and discontinued. Following the cessation of GBP, CHF,
JPY, and EUR LIBOR rates on 31 December 2021, USD LIBOR will cease on 30 June 2023.
In 2022, the focus shifted to USD LIBOR, with new USD lending now using the recommended alternative
rates based on SOFR. This is consistent with guidance issued to limit the use of USD LIBOR from
1 January 2022 onward. Risk reduction trades to help manage the run-off of existing USD LIBOR contracts
and positions are a permitted exception.
To enable these changes, the financial sector has issued several guidance papers and other initiatives to
help phase this transition. For example, ISDA has issued an IBOR fallback supplement to help ensure clear
fallback rates apply upon the discontinuation of key IBORs. For loans, various recommendations have been
made to help ensure the inclusion of consistent robust fallback provisions. Public authorities have also
recognised that many contracts do not contain provisions for any alternatives, contain inappropriate
alternatives, or cannot be renegotiated prior to the expected cessation date (‘tough legacy’ contracts). For
example, the Financial Conduct Authority (FCA) is expected to ask the USD LIBOR administrator to continue
publishing a 'synthetic' LIBOR rate for 15 months beyond the cessation date to provide extra time for any
remaining contracts. A similar action was taken for GBP and JPY LIBOR. The US has also implemented the
Adjustable Interest Rate (LIBOR) Act, that will revise the contractual terms of in scope contracts to reference
a rate based on SOFR upon cessation of USD LIBOR.
Due to the discontinuation of this important rate, ING, its customers, and the financial services industry face
a number of risks. These risks include legal, financial, operational, and conduct risk. Legal risks are related to
any required changes to existing transactions. Financial risks may arise due to declining liquidity and may
impact a contract directly or the ability to hedge the risks in that contract. Operational risks arise due to the
requirement to adapt IT systems, trade reporting infrastructure and operational processes. Conduct risk also
plays a role, as renegotiation of loan contracts requires active engagement from all parties to a contract,
and may lead to negotiations concentrated in a period close to actual cessation. ING continues to reach out
to impacted clients to manage the relevant timelines.
During 2022, ING sought to ensure that a large portion of the derivative portfolio is covered by ISDA
fallbacks. Regarding the loans, many facilities have already been transitioned to alternative rates.
Additionally, for the remaining portfolio the parameters for the required changes have been communicated
to counterparties, with many now in active discussions on the remaining steps.
The ING IBOR programme has governance in place with progress being tracked by business line steering
committees reporting to a central IBOR steering committee. The programme assesses and coordinates the
actions necessary to manage the required changes to internal processes and systems, including pricing, risk
management, legal documentation, hedge arrangements, as well as the impact on customers. ING
continues to monitor market developments and reform plans for other rates, to anticipate the impact on
the programme, our customers and any related risks.
One such development concerns key Polish Zloty benchmarks. The roadmap published by the Polish
National Working Group in 2022 indicates that the plan is for the market to be ready for a cessation of
WIBOR and WIBID Reference Rates in 2025. It is expected that the reform will be completed by the end of
2024, with the offering of financial products using the new benchmark (WIRON) to progress gradually in
2023 and 2024. 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.
As at 31 December 2022, ING has exposures that have yet to transition related to USD LIBOR and WIBOR.
The tables below summarise these approximate exposures. They exclude exposures that will expire before
the transition date 30 June 2023 and 1 January 2025, respectively. The GBP LIBOR, CHF LIBOR and EONIA
contracts included as at 31 December 2021 have all transitioned or matured.

Non derivative Financial instruments to transition to alternative benchmarks (*)
in € million at 31 December 2022 | Financial Assets non- derivative | Financial Liabilities non-derivative | Off balance sheet commitments
| Carrying value | Carrying value | Nominal value
By benchmark rate |  |  |
GBP LIBOR |  |  |
USD LIBOR | 30,040 | 1,637 | 7,644
CHF LIBOR |  |  |
EONIA |  |  |
WIBOR | 22,154 |  | 1,411
Total | 52,194 | 1,637 | 9,055

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> Market risk
ING Bank Annual Report 2022 102

Non derivative Financial instruments to transition to alternative benchmarks (*)
in € million at 31 December 2021 | Financial Assets non- derivative | Financial Liabilities non-derivative | Off balance sheet commitments
| Carrying value | Carrying value | Nominal value
By benchmark rate 1 |  |  |
GBP LIBOR | 764 |  | 350
USD LIBOR | 41,805 | 1,542 | 16,435
CHF LIBOR | 1 |  |
EONIA |  | 23 | 184
Total | 42,570 | 1,565 | 16,969

1 WIBOR transition plans became concrete in 2022 and therefore no comparatives for 2021 are included.
For derivatives linked to USD LIBOR, the conduct risk is limited as the majority are transacted with clearing
houses, which will transition through a standardised exercise in the second quarter of 2023. For USD LIBOR
derivatives that are not centrally cleared, the main transition will occur via the ISDA IBOR fallback protocol at
30 June 2023.

Derivative Financial instruments to transition to alternative benchmarks (*)
| 31 December 2022 | 31 December 2021
in € million | Nominal value | Nominal value
By benchmark rate 1 |  |
GBP LIBOR |  | 822
USD LIBOR 2 | 495,318 | 488,499
WIBOR 3 | 136,318 |
Total | 631,636 | 489,321

1 For cross-currency swaps all legs of the swap are included that are linked to a main IBOR that is significant to ING.
2 The prior period has been updated to improve consistency and comparability.
3 WIBOR transition plans became concrete in 2022 and therefore no comparatives for 2021 are included.
In addition to the amounts in the table above, ING has interest rate swaptions that refer to the USD LIBOR
ICE swap rate with a notional of €10,810 million (2021: €10,343 million) that are yet to transition. The
transition of these contracts is in general governed by a specific ISDA protocol.
Given that IBOR Reform may have various accounting implications, the International Accounting Standards
Board (IASB) has undertaken a two-phase project:
•Phase 1 addresses those issues that affect financial reporting before the replacement of an existing
benchmark. Phase 1 amendments to IFRS were issued by the IASB in 2019 and were early adopted by
ING in the same year. This allows ING to apply a set of temporary exceptions to continue hedge
accounting even when there is uncertainty about contractual cash flows arising from the reform. Under
these temporary exceptions, interbank offered rates are assumed to continue unaltered for the purposes
of hedge accounting until such time as the uncertainty is resolved.
•Phase 2 focuses on issues that may affect financial reporting when the existing benchmark rate is
reformed or replaced. Phase 2 amendments to IFRS were issued by the IASB in 2020 and became
effective in 2021. Phase 2 amendments to IFRS relate mainly to accounting for changes in the basis for
determining the contractual cash flows of financial assets and liabilities due to the IBOR reform and
impact on hedge accounting when an existing benchmark rate is reformed or replaced with an
alternative risk-free rate.
Specifically, Phase 2 amendments require that the effective interest rate on debt financial instruments is
adjusted, and hedge accounting continues on transition to risk free rates, but only to the extent that the
modifications made to financial instruments are those necessary to implement the IBOR Reform and that
the new basis for calculating cash flows is ‘economically equivalent’ to the previous basis. By applying these
mandatory amendments, ING avoids recognising modification gains and losses on debt instruments that
would otherwise be required in the absence of Phase 2 amendments (changes to debt instruments resulting
from IBOR Reform are treated as a reset to the instrument’s variable interest rate). In addition, ING avoids
hedge accounting discontinuations when modifying both hedged items and hedging instruments (and
related hedge documentation) as a consequence of IBOR reform that would otherwise be required in the
absence of Phase 2 amendments.
As explained above, Phase 1 and Phase 2 IBOR amendments to IFRS, amongst other changes, provide
specific hedge accounting reliefs that allow hedge accounting relationships to continue when IBOR Reform is
ongoing. Phase 1 reliefs cease to apply when uncertainty arising from IBOR Reform is no longer present with
respect to the timing and amount of the IBOR-based cash flows of the relevant instruments. It is ING’s policy
to cease to apply Phase 1 reliefs when the applicable contract (either hedging instrument or hedged item) is
actually modified. As a result, for these hedge accounting relationships the applicable Phase 1 reliefs ceased
to apply and Phase 2 became applicable. For USD LIBOR exposures, and although the administrator of LIBOR
confirmed on 5 March 2021 its plans for the cessation of USD LIBOR rates at the end of June 2023, there is
still uncertainty with respect to the timing of the transition as well as the transition strategy for individual
hedged items and/or hedging instruments linked to USD LIBOR. Therefore, for USD LIBOR 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, Phase 2 reliefs will become applicable.
In addition, in 2022 ING started to apply Phase 1 reliefs to the hedge accounting relationships linked to
WIBOR as there is uncertainty arising from the WIBOR reform with respect to the timing and the amount of
the underlying cash flows to which ING is exposed.

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> Market risk
ING Bank Annual Report 2022 103
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.
Governance – Core banking business (*)
Every business unit hedges the FX risk resulting from core banking business activities into its base currency.
Consequently, assets and liabilities are matched in terms of currency.
Governance – FX translation result (*)
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. 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 result (*)
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 Market Risk Banking Book RAS.
EBA Structural FX Guidelines
EBA guidelines on structural FX positions became effective in 2022. 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.

Foreign currency exposures banking books (*)
in € million | Foreign Investments | Hedges | Net exposures
| 2022 | 2021 | 2022 | 2021 | 2022 | 2021
US dollar 1 | 10,470 | 8,218 | -2,376 | -99 | 8,093 | 8,119
Pound sterling | 1,364 | 1,593 | -58 |  | 1,306 | 1,592
Polish zloty | 2,714 | 2,761 | -321 | -142 | 2,393 | 2,620
Australian dollar | 3,781 | 3,774 | -2,673 | -2,511 | 1,108 | 1,263
Turkish lira | 750 | 729 |  |  | 750 | 729
Chinese yuan | 1,871 | 1,976 |  | -107 | 1,871 | 1,869
Russian rouble | 391 | 256 |  | -174 | 392 | 82
Other currency | 5,740 | 5,860 | -3,761 | -3,453 | 1,979 | 2,407
Total | 27,081 | 25,167 | -9,189 | -6,486 | 17,892 | 18,681
Hyperinflation accounting and goodwill impairment had limited impact on the Turkish lira FX exposure to the CET1 Ratio. The structural Turkish lira exposure arising from ING Bank Turkey’s assets and liabilities remains within risk limits.

Equity price risk in banking books (*)
Governance (*)
ING maintains a strategic portfolio with substantial equity exposure in its banking books. Local offices are
responsible for the management of the equity investment positions. Financial Risk is responsible for
monitoring the regulatory capital for equity investments on a monthly basis and acts independently from
ING/local management when monitoring these positions.
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 value 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 €1,500 million (2021: €1,587 million) and equity securities
held at fair value through other comprehensive income (FVOCI) of €1,887 million (2021: €2,457 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.

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> Market risk
ING Bank Annual Report 2022 104
Year-on-year variance analysis (*)
In 2022, the revaluation reserve equity securities decreased by €95 million from €1,282 million to €1,187
million. In 2022, the equity securities at fair value through OCI decreased by €570 million mainly due to
divestment of HQLA eligible equity instruments.

Revaluation reserve equity securities at fair value through other comprehensive income (*)
in € million | 2022 | 2021
Positive re-measurement | 1,190 | 1,291
Negative re-measurement | -4 | -9
Total | 1,187 | 1,282

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 2022, 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.
Governance (*)
The Financial Markets Risk Committee (FMRC) is the market risk committee that, within the risk appetite set
by the ALCO Bank, sets the market risk limits both on an aggregated level and on a desk level. Financial Risk/
Trading Risk Management (FR/ TRM) advises both FMRC and ALCO Bank on the market risk appetite of the
trading activities.
With respect to the trading portfolios, 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. Trading activity is
systematically reviewed and positioned against the mandates are assessed jointly by the first and second
lines of defence.
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 Event Risk (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.
As of June 2022, ING has received an official permission from the ECB to perform offsetting of positions with
the exception of Ukraine, Russia and Turkey. Hence the regulatory capital numbers reported from Q2 2022
onwards, are calculated with offsetting for all base entities excluding Ukraine, Turkey and Russia.
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%, 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) if 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 e.g. 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 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 ten-day horizon the one-day risk factor shifts are scaled by the
square root of ten 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: HVaR 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
ten 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

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> Market risk
ING Bank Annual Report 2022 105
backtest, the actual daily trading results (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%, an outlier is expected once in every
100 business days.
On an overall level in 2022, there were five outliers for hypothetical P&L and three outliers for actual P&L.
The actual and hypothetical outliers occurred during the past one year concentrated in 1Q2022 mainly due
to large moves in Russian credit default swaps and Rouble volatility.
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 ten-day horizon. The data for
the historical stress period used currently includes the height of the credit crisis around the fall of Lehman
Brothers, and this choice is reviewed regularly. 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% 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 are based on historical market data. The
rating change is simulated for all issuers over the different liquidity horizons (i.e. time required to liquidate
the position or hedge all significant risks) within one year. Movements across different rating categories and
probabilities of default are governed by a credit-rating transition matrix. An internal transition matrix along
with internal LGDs is used, to comply with the consistency requirement. The financial impact is then
determined for the simulated migration to default, or for the simulated migration to a different rating
category, based on LGD or credit spread changes, respectively.
The liquidity horizon has been set to the regulatory minimum of three months for all positions in scope. ING
reviews the liquidity horizons on a yearly basis, based on a structured assessment of the time it takes to
liquidate the positions in the trading portfolio.
Stress testing and event risk (*)
Stress testing and event risk are valuable risk management tools. In addition to the bank-wide stress test
framework as described in the stress-testing section, FI-FM Risk performs additional assessments, specific to
the trading book, with various frequencies: sensitivity analyses (single-risk factor and multi-risk factor), ad-
hoc stress tests (e.g. Covid-19 scenarios) and structured stressed scenario tests under the event risk
framework - to monitor market risks under extreme market conditions. Event risk evaluates the bank’s
financial stability under severe but plausible stress scenarios and assists in decision-making aimed at
maintaining a financially healthy going-concern institution after a severe event occurs. Event risk is based
on historical as well as hypothetical extreme scenarios. The result is an estimate of the profit and loss
caused by a potential event and its worldwide impact for ING.
ING’s event risk policy is based on a large set of possible stress scenarios per risk type. 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. For equity products, for example, both a crisis scenario
(prices decrease) as well as a bull scenario (prices increase) are assumed. Scenarios are calculated based on
events happening independently, jointly by region, or in all countries simultaneously. This way, for each risk
type, a large set of scenarios is calculated. The worst scenarios per market are combined across markets by
assessing both independent events per market, and the worst events happening in all markets at the same
time.
Other trading controls
HVaR and event risk limits are the most important limits to control the trading portfolios. Additionally, limits
have been set on SVaR and IRC. Furthermore, 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

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> Market risk
ING Bank Annual Report 2022 106
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 from 2020 to 2022.
1 CVA risk is not included in VaR.
The risk figures in the backtesting graph above and in the table below relate to all trading books for which
the internal model approach is applied, i.e. all trading books, including credit exposure management books.

1d VaR for internal model approach trading portfolios
in € million | Minimum | Maximum | Average | Year end
| 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Interest rate 1 | 1 | 4 | 17 | 20 | 9 | 8 | 13 | 5
Equity and commodity | 2 | 1 | 7 | 4 | 3 | 2 | 2 | 2
Foreign exchange | 1 |  | 22 | 3 | 4 | 1 | 3 | 1
Credit spread | 1 | 2 | 15 | 11 | 4 | 4 | 1 | 2
Diversification 2 |  |  |  |  | -9 | -5 | -5 | -4
Total VaR 2 | 5 | 4 | 22 | 26 | 12 | 10 | 14 | 6

1 For 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.
2 The 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.
3 CVA risk is not included in VaR.
Average 1D/10D HVaR, 10D SVaR, IRC over 2022 has increased compared to 2021, the capital increase is
driven by an increase in market volatility following the war in Ukraine as well as the FX and CDS hedges put
in place as macro hedges and to hedge exposure to Russian counterparties. The average for all risk classes
increased in 2022, especially for FX which increased due to the Russian crisis. The 1D HVaR at the period end
of 2021 increased from €6 million to €14 million at period end of 2022, due to the market recovery from the
Covid-19 crisis.
ING doesn’t 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 € million | 2022 | 2021
VaR (10 day 99%) |  |
1 Maximum value | 79 | 78
2 Average value | 37 | 27
3 Minimum value | 15 | 12
4 Period end | 42 | 18
Stressed VaR (10 day 99%) |  |
5 Maximum value | 147 | 105
6 Average value | 77 | 80
7 Minimum value | 47 | 64
8 Period end | 65 | 74
Incremental Risk Charge (99.9%) |  |
9 Maximum value | 270 | 195
10 Average value | 113 | 71
11 Minimum value | 34 | 37
12 Period end | 76 | 65
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

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> Market risk
ING Bank Annual Report 2022 107
Regulatory capital
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. ING
received 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. Capital for foreign
exchange risk from the banking books and for collective investment undertakings (CIUs) exposures in trading
books are calculated using the standardised approach with fixed risk weights. ING does not have a
correlation trading portfolio or any other securitisations in the trading book.
Standardised approach

EU MR1: Market risk under Standardised Approach
in € million | 2022 | 2021
| RWA | RWA
Outright products |  |
1 Interest rate risk (general and specific) | 10 | 6
2 Equity risk (general and specific) |  |
3 Foreign exchange risk | 5,332 |
4 Commodity risk |  |
Options |  |
5 Simplified approach |  |
6 Delta-plus method |  |
7 Scenario approach |  |
8 Securitization (specific risk) |  |
9 Total | 5,342 | 6

The MRWA under standardised approach have sharply increased compared to 2021. In 2022, MRWA is
calculated for FX exposures, in line with the new CRR Standardized Approach that was introduced in 2022.
Internal model approach
Market risk regulatory capital decreased slightly during 2022 compared to 2021. The main reduction is
coming from SVaR where December 2021 was calculated on a fully deconsolidated basis, while HVaR
increased due to the high market volatility in 2022.

EU MR2-A: Market risk under Internal Model Approach
in € million | 2022 | 2021
|  | RWA | Capital requirement s | RWA | Capital requirement s
1 | VaR (higher of values a and b) | 2,732 | 219 | 1,179 | 94
(a) | Previous day’s VaR (VaRt-1) |  | 49 |  | 21
(b) | Multiplication factor (mc) x average of previous 60 working days (VaRavg) |  | 219 |  | 94
2 | SVaR (higher of values a and b) | 3,427 | 274 | 6,336 | 507
(a) | Latest available SVaR (SVaRt-1)) |  | 70 |  | 112
(b) | Multiplication factor (ms) x average of previous 60 working days (sVaRavg) |  | 274 |  | 507
3 | IRC (higher of values a and b) | 1,934 | 155 | 1,314 | 105
(a) | Most recent IRC measure |  | 76 |  | 94
(b) | 12 weeks average IRC measure |  | 155 |  | 105
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 | 516 | 41 | 200 | 16
6 | Total | 8,609 | 689 | 9,029 | 722

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.

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ING Bank Annual Report 2022 108

Most important foreign exchange year-end trading positions (*)
in € million | 2022 |  | 2021
Foreign exchange |  | Foreign exchange |
US Dollar | -187 | US Dollar | -160
Romanian Leu | 88 | Taiwan Dollar | 42
Japanese Yen | 86 | Romanian Leu | 32
Chinese Yuan | 32 | Japanese Yen | 27
South Korean Won | 28 | South Korean Won | -24

Most important interest rate and credit spread sensitivities at year-end (*)
in € thousand | 2022 |  | 2021
Interest Rate (BPV) 1 |  | Interest Rate (BPV) 1 |
Euro | -334 | Euro | -501
British Pound | -95 | US Dollar | 185
US Dollar | -79 | British Pound | -75
Taiwan Dollar | 67 | Taiwan Dollar | 73
Japanese Yen | 63 | Japanese Yen | -57
Credit Spread (CSO1) 2 |  | Credit Spread (CSO1) 2 |
Netherlands | 162 | Netherlands | 535
United States | 151 | Germany | 408
Japan | 102 | United States | 171
France | 88 | France | 112
Germany | 87 | China | 110

1 Basis Point Value (BPV) measures the impact on value of a 1 basis point increase in interest rates. The figures include commodity risk
in banking books.
2 Credit Spread Sensitivity (CS01) measures the impact on value of a 1 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 (*)
| 2022 | 2021
in € thousand | Corporate | Financial Institutions | Corporate | Financial Institutions
Credit Spread (CSO1) 1 |  |  |  |
Risk classes |  |  |  |
1 (AAA) | 2 | -1 |  | -5
2–4 (AA) | -1 | -7 | -7 | 18
5–7 (A) | 154 | -13 | 141 | 578
8–10 (BBB) | 249 | -11 | 204 | 12
11–13 (BB) | 7 | 7 | 40 | -1
14–16 (B) | 23 | -4 | 52 | -6
17–22 (CCC and NPL) | 3 | -7 | -6 | -12
Not rated |  |  |  |
Total | 437 | -36 | 424 | 584

1 Credit Spread Sensitivity (CS01) measures the impact on value of a 1 basis point increase in credit spreads.

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ING Bank Annual Report 2022 109
Funding and liquidity risk (*)
Introduction (*)
Funding and liquidity (F&L) risk is the risk that ING or one of its subsidiaries cannot meet its financial
liabilities when they are due at a reasonable cost and in a timely manner. ING incorporates funding and
liquidity management in its business strategy and has established a funding and liquidity risk framework to
manage risks within pre-defined boundaries.
A high-level overview of the F&L framework is provided in the following chart.

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ING Bank Annual Report 2022 110
Governance (*)
Funding and liquidity risk management within ING falls under the supervision of the ALCO Bank function that
approves the funding and liquidity risk appetite and subsequently cascades it throughout the organisation.
ALCO Bank has delegated the responsibilities concerning the Internal Capital and Liquidity Adequacy
Assessment Process (ICLAAP) and documents, as per the ICLAAP framework of ING, to the ICLAAP
Committee. The ICLAAP Committee therefore focuses on technical liquidity documents and oversees
business processes and deliverables concerning the Internal Liquidity Adequacy Assessment Process
(ILAAP). The EB, MBB, staff departments from the CRO and CFO domain as well as Group Treasury have
oversight of, and are responsible for, managing funding and liquidity risks.
ING’s funding and liquidity risk governance is based on the three lines of defence structure to set a clear
division of responsibilities as well as an independent risk control challenge process. Group Treasury and the
business lines have the first line of defence functions which include management of ING’s (regulatory)
liquidity and funding position, maintaining access to the professional funding markets and managing the
liquidity buffer. As the second line of defence, Financial Risk is responsible for developing and maintaining
ING’s policies, standards and guidelines on F&L risk management as well as for setting the F&L risk appetite
through stress testing and other risk measurement activities. The Finance function is responsible for
management information and regulatory reporting related to funding and liquidity risk management. For
the third line of defence, Corporate Audit Services is responsible for independently assessing the design,
effectiveness and implementation of the Funding and Liquidity framework.
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 around 50 percent and 25
percent of total funding, respectively. These funding sources provide a relatively 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 (*)
| 2022 | 2021
Funding type |  |
Customer deposits (retail) | 51% | 51%
Customer deposits (corporate) | 28% | 25%
Interbank | 6% | 9%
Lending/repurchase agreements | 6% | 5%
CD/CP | 3% | 3%
Long-term senior debt | 4% | 4%
Subordinated debt | 2% | 2%
Total | 100% | 100%
1 Liabilities excluding trading securities and IFRS equity. |  |

Funding and liquidity adequacy and risk appetite (*)
ING identifies various key drivers of future liquidity and funding needs on an ongoing basis and through the
periodic risk identification process. Taking into consideration the identified drivers, ING regularly assesses its
current and future liquidity adequacy and, if deemed necessary, takes steps to further improve ING’s
liquidity position and to have sufficient counterbalancing capacity. A liquidity adequacy statement is
formulated on at least a quarterly basis to substantiate and reflect the management view on the current
funding and liquidity position as well as the potential future challenges. The quarterly liquidity adequacy
statement is an important part of ING’s ILAAP process.
ING assesses its F&L adequacy through three lenses – stress, economic and normative:
•Through the stress lens, ING evaluates its ability to withstand a period of prolonged F&L stress for both
normative and economic requirements or limits under idiosyncratic, market-related or a combination of
idiosyncratic and market-related scenarios, which lead to customer deposit outflows, deterioration of
access to funding markets, and lower liquidity value of counterbalancing capacity.
•Through the economic lens, ING assesses the extent to which its customers, professional counterparties
and investors are comfortable in providing deposits and funding in 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
forthcoming home and host regulatory requirements.

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ING Bank Annual Report 2022 111
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. These risk appetite statements are summarised in
the next graph.

The F&L risk appetite statements are translated into a number of metrics with appropriate boundaries and
instruments which are used to 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 (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.
The macroeconomic and market environment are also important considerations in ING’s funding and
liquidity framework. The macroeconomic environment comprises various exogenous factors over which ING
has no control, but which may have a material impact on ING’s F&L position. The main macroeconomic
factors analysed on a regular basis include:
•Global and local economic performance e.g. shifts in GDP, inflation rates, unemployment rates and public
deficit/surplus.
•Changing geopolitical trends.
•Monetary policy with a focus on the unconventional monetary measures employed by central banks in
recent years including the measures taken since the start of the Covid-19 crisis and the more recent
period of increased inflation.
•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.
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 Bank, 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 and combined (idiosyncratic and market-
wide) stress scenarios. The design of the framework is based on empirical evidence supplemented by expert
judgement. 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.

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ING Bank Annual Report 2022 112
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.
•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 at least monthly 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 regular 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
2022, this included stress-test scenarios dedicated to the war in Ukraine, inflation, and the impact of
monetary tightening. The internal stress scenarios also serve as input for decision making on additional
contingency measures.
Contingent F&L risks are addressed in the Contingency Capital and Funding Plan with a focus on early
warning indicators as well as organisation and planning of liquidity management in times of stress. The
contingency funding measures are developed in conjunction with the ING Recovery Plan and are tested on a
regular basis.

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ING Bank Annual Report 2022 113
Environmental, social and governance risk
Introduction
Environmental, social and governance (ESG) risk is defined as the risk of losses arising from any negative
financial impact on the institution stemming from the current or prospective impacts of environmental,
social or governance factors on the institution’s counterparties or invested assets.
Governance
The ESG governance is cascaded in the organisation through the ad-hoc ESG committee that is responsible
for supervising ING’s ESG direction, endorsing and monitoring progress, and advising the MBB on dilemmas.
The ESG Sounding Board comprised of senior leaders guides the development and implementation of ESG
topics as well as reporting on progress. Further details on ESG risk governance are provided in the section
below. The overall ESG governance structure is described in the ‘Sustainability at the heart’ section.
Environmental and social risk
ESR is a risk function that is part of the second line of defence of ING. The ESR team is responsible for
developing policies and procedures. The department takes the lead in communicating them internally and
in training internal stakeholders. The ESR team also performs an advisory role to support the deal principals,
senior credit officers and approval authorities on individual transactions. The degree of the ESR team
engagement in transactions is dependent upon (1) the risk profile of the client, project or business
engagement, and (2) ING’s exposure. In some locations an ESR delegated adviser may be appointed if
mutually agreed by the head of ESR and regional head. Such a role would support the senior credit officer
(SCO), who would be responsible for ESR in the region.
Committees involved in managing environmental and social risks include the Global Credit & Trading Risk
Committee (GCTP) and the Global Credit Committee GCC(TA). The GCTP approves the policies,
methodologies, and procedures related to ESR. The GCC(TA) approves transactions that entail taking higher
environmental and social risk.
The ESR function encompasses the following activities:
•Create and maintain policies for sensitive industry sectors.
•Assess transactions for environmental and social risk.
•Monitor high-risk clients to assess compliance with sustainability criteria.
•Spread ESR awareness throughout ING.
•Participate in European and global advisory groups (e.g. OECD advisory group, steering committee to the
Equator Principles, Thun Group of Banks) to help bring all banks to the same high standard.
Climate risk initiative
The Climate Risk Initiative (CRI) is a programme aiming to address climate-related and environmental (C&E)
risks across our organisation in accordance with the ECB’s Guide on C&E risks. It is sponsored by the CRO and
overseen by a Steering Committee. The programme addresses regulatory expectations on the topics of
governance, business strategy, risk identification and assessment, risk appetite, stress testing and
disclosures.
The governance of the programme was strengthened in early 2022 by extending the Steering Committee
with representatives from the Wholesale Banking and Retail Banking business lines, the Risk domain and the
Internal Audit function. In addition, a permanent Climate Risk Centre of Expertise (CoE) was established
within the Global Sustainability department. This team supports workstreams in the establishment of their
roadmaps and reports progress to the Steering Committee, internal and external stakeholders. Furthermore,
the CoE collaborates with the ESG risk department on continuously embedding C&E risk management
practices across the organisation.
ESG Risk Centre of Expertise
After a strategic review of our risk organisational structure, an ESG Risk Centre of Expertise, reporting to
ING’s CRO, was formed within the Integrated Risk department. This team aims to ensure that relevant ESG
regulations are monitored, assessed and implemented in accordance with the expectations of both
supervisors and society. Furthermore, it is responsible for developing the overarching ESG risk framework
and policies, setting risk appetite as well as coordinating internal and regulatory ESG risk stress-testing.
Developments in 2022
External developments
Following the introduction of the EU Taxonomy Regulation in 2020 and the EBA consultation on ESG risks in
2021, global ESG regulation continues to evolve bringing new requirements for companies and also financial
institutions to report on and prevent adverse impacts on climate, the environment, and human rights. Three
of the key regulatory developments that were initiated in 2022 are:
•The European Commission adopted its proposal for the Corporate Sustainability Due Diligence Directive
(CSDDD) in February 2022. However, the proposal is still under debate and needs to be approved in the
trialogue between the EU Parliament, the EU Commission and the Council. The CSDDD is an important
component of the European Green Deal, as well as a long-promised initiative in the EU's human rights
strategy, and will necessitate strategic and operational changes by businesses globally as it aims to
foster sustainable and responsible corporate behaviour and to anchor human rights and environmental

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ING Bank Annual Report 2022 114
considerations in companies' operations and corporate governance. The CSDDD also applies to financial
institutions.
•Earlier elements of the European Green Deal focused on disclosure: in particular, under the Sustainable
Finance Disclosure Regulation, the Taxonomy Regulation and, most recently, the Corporate Sustainability
Reporting Directive (CSRD), which was published in the Official Journal of the European Union on 16
December 2022, having been formally adopted by the European Parliament and Council of the European
Union in November 2022. The CSRD will update and reinforce the EU's Non-Financial Reporting Directive
and operate in tandem with the CSDDD. Member states are required to implement the CSRD, and its
obligations will start to apply in January 2024.
•In March 2022, the US Securities Exchange Commission (SEC) proposed rules to require climate change
disclosure in the annual reports and registration statements of public companies registered with the SEC,
including any company (domestic or foreign) whose stock is listed on a US stock exchange. Hence, it is
yet to be seen whether the proposed rules will eventually be implemented in this respect.
Environmental and Social Risk
The ESR framework
ING’s ESR policy framework helps us make informed choices about how, where and with who we do
business. In 2022, the ESR Framework was updated to reflect several minor amendments following the last
comprehensive review cycle that took place in June 2021. The new release includes among others
amendments to the restrictions applied in the tobacco value chain, additional clarity on some of the
requirements for the ESR client assessment process concerning a specific group of companies and the
required ESR due diligence for public authority entities. For more information please refer to the ESR
Framework on our corporate website ing.com
ESR in practice
The ESR policy framework includes standards and best practice guidance for ESR-sensitive sectors. It
includes explicit restrictions on activities not in line with ING’s values and harmful to people and/or the
environment (for example companies involved in clearance of primary forest), which we do not want to
finance.
The way the ESR framework is applied in practice differs per product type. The largest potential
environmental and social impacts come from large corporates within our Wholesale Banking (WB) segment.
However, we also have screening processes covering the Business Banking segment.
Wholesale Banking is therefore the primary focus of our assessments and where we promote active ESR
dialogue and knowledge sharing. We have been working with wholesale clients for more than 15 years to
support them in understanding and managing their environmental and social impact. A simplified approach,
following the same rationale and principles of the ESR policy framework, applies to ING’s business banking
clients. The ESR framework minimum requirements are also included in ING’s procurement policy and apply
to the screening of suppliers of ING’s global procurement activities.
The ESR policy framework is incorporated in ING’s KYC policy framework, meaning the ESR client assessment
is part of regular client on-boarding and review. The ESR policy framework also triggers a dedicated ESR
transaction assessment to corporate clients, which will indicate if transactions are categorised as ‘ESR high
risk’, and thus require a separate in-depth advice from the ESR team.
While we have a robust ESR policy framework and made progress in enhancing the automation of the
checks and controls in the ESR assessment processes, we acknowledge that we need to improve our
processes to further ensure adequacy of data necessary to steer and manage these risks at the level of
granularity needed.
Of all WB engagements in scope of the ESR policy framework in 2022, 84 percent were considered ESR low-
risk, seven percent ESR medium-risk and nine percent ESR high-risk. ESR high-risk cases require specialised
advice from the global ESR team. The ESR advice assesses the specific product offered and environmental
and social impacts associated with it, the sector, operating context and geography of the engagement and
other relevant factors. Based on this in-depth research, an advice is given that can only be overruled at
Global Credit Committee level. Of the 309 ESR advices given in 2022, which are related to new requests, 48
percent were positive, 35 percent positive subject to conditions and 17 percent negative.
Conditions can play an important role in helping clients improve their environmental and social performance
and transitioning and ensuring their continued compliance with our ESR policy.
The ESR team mainly focuses on policy development and transaction advice. However, the team also
provides training (both in-person and via webinars) to hundreds of colleagues around the world every year
in Risk, front-office, KYC and other teams, so that ESR knowledge is built on and spread.
Apart from above, ESR in cooperation with the KYC Academy has developed a new e-learning course on
Environmental and Social Risk that was launched at the end of 2021. The purpose of this course is to further
increase the awareness and understanding on ESR, outline the risks and the responsibilities of the various
internal stakeholders and their roles in the process throughout the whole organisation. Since the roll out of
the e-earning tool, more than 8,000 employees worldwide completed the course.
Other ESG-related initiatives within the bank
Our ESR approach helps our clients and ING gradually enhance the implementation of key standards like the
UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises.
But beyond stimulating better environmental and social performance in our own portfolio, ING actively

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ING Bank Annual Report 2022 115
collaborates with other institutions, peers and regulators to address the environmental, social and human
rights challenges we face:
•ING and the Equator Principles (EPs): The EPs are an environmental and social risk management
framework adopted by 134 financial institutions worldwide. ING is active in several EP working groups
covering social risks, climate change and scope. ING also co-leads the capacity building and training
workgroup, and was elected as a member of the EP Steering Committee in 4Q 2022.
•Shift Business Learning Programme: is a practitioners group organised and supported by Shift, the
leading centre of expertise on the UN Guiding Principles on Business and Human Rights. The programme
focuses on the corporate responsibility to respect human rights as set out in the UN Guiding Principles.
Under the leadership of Shift, a group of companies active in various business sectors including financial
institutions share challenges and practices through cross-industry workshops and benefit from tailored
strategic support. ING participates in the programme. We are also a member of the Financial Institution
Practitioners’ Circle, a group for selected practitioners in the financial sector to discuss and share
approaches to meeting their responsibility to respect human rights, led by Shift experts.
•Responsible Business Conduct Agreement: following the Dutch Banking Sector Agreement, a new
commitment on responsible business was formed among Dutch banks. Global Sustainability is leading
the initiative for ING and the ESR team is aligned for any policy implications or client interactions.
•Thun Group: was initially established in 2011 to support the integration of the UN Guiding Principles
(UNGP) on Business and Human Rights into banking activities. The group consists of bank representatives
who informally share best practices among participant members to deepen the understanding and
application of the UNGP across the range of different banking activities. ING participated in this year’s
virtual annual meeting. Amongst other topics, the latest developments on human rights due-diligence
obligations and the human rights impacts of climate transition plans were discussed.
By taking part in the above-mentioned initiatives, we aim to contribute our viewpoint and those of our
clients, employees and other stakeholders in support of collective ESG responsibilities that will be driving our
further development and maintenance of guidelines that can serve as a standard for our industry.
Climate-related and environmental risk management
Climate change is increasingly exposing society to a range of physical risks (both acute and chronic) which
are linked to environmental risk. ING's response to combatting climate change and environmental
degradation is comprised of the incorporation of the C&E risks incorporated in the bank's risk management
and client engagement practices.
Managing C&E risks covers both physical risks (e.g. extreme weather events) and transition risks (e.g. policy
changes, shifts in market sentiment and consumer demand). The potential impacts that physical and
transition risks could have on households, businesses as well as on the macroeconomy can translate into a
range of financial risks for ING. The C&E risks can materialise through defaults of businesses and households,
increased volatility in equity and commodity markets, disruptions to bank's and customers' operations, and
litigation procedures. While ING has an inclusive approach for supporting clients in the transition to a net-
zero economy, we also manage the financial impact of C&E risks on our clients' activities.
The C&E risk management practices in ING were subject to the ECB's industry-wide Thematic Review in
2022. ECB published the outcome of their review in a public report and shared their observations with
individual banks. After the finalisation of the Thematic Review, ING updated its roadmap for the
implementation of ECB's expectations to reflect regulatory observations and agreed remediation timelines.
ING endorses the recommendations of the Financial Stability Board’s (FSB) Task Force on Climate-Related
Financial Disclosures (TCFD). We continue to develop our approach for C&E disclosures as we build our
methodology for identifying, measuring and managing these risks. See also ‘The world around us’.
Risk management
Risk identification and assessment
In 2022, we continued to enhance the tools used to identify and assess C&E risks in our portfolio. We
created C&E risk sector heatmaps for both WB and Retail Banking. The heatmaps facilitated the materiality
assessment of C&E risks by means of scores assigned to transition and physical risk drivers. They also
enabled us to understand the magnitude of the C&E risk impact on a sectoral level and pinpointed the
sectors with highest C&E risk exposure.
The C&E risk heatmap is one of the tools used by ING to identify and assess C&E risks. For physical risk, the
heatmap lists 26 individual climate-change-related physical risk hazards (both acute and chronic weather
patterns) and environmental risk drivers (water stress, resource scarcity, biodiversity loss, pollution and
waste). The assessment for transition risk is based on seven risk drivers related to policy and regulatory
changes, technological developments, and shifts in market sentiment/ demand. For each of the factors
under consideration, a low, medium or high score is based on a qualitative assessment taking into account
industry standards following a three to five-year horizon. This assessment is performed at the level of the
individual sectors of ING's WB portfolio. The geographic distribution of ING's clients is therefore implicitly
taken into account but not assessed on an individual client basis.
The heatmap assessment for all WB sectors was completed in 2022. The results of the exercise are
summarised in the following table. Conducting the assessment for medium and long-term horizons and
applying a quantitative counterparty assessment approach, could potentially result in different sector

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ING Bank Annual Report 2022 116
scoring. An assessment for the medium to long term horizons may identify increased exposure to both
physical and transition risks. For the identification of a financial impact on ING, we also need to take the
readiness of ING's counterparties to address these risks into consideration.
Consolidated heatmap scores for Wholesale Banking

Sector | Transition risk | Physical risk | EAD / Total WB EAD
December 2022 |  |  |
Building and construction | Medium | Low | 1.3%
Building materials | Medium | Medium | 0.8%
Mid and downstream oil and gas | Medium | Low | 3.7%
Offshore | High | Low | 0.9%
Upstream oil and gas | High | Low | 1.7%
Real estate holding and development | Medium | Low | 0.3%
Real estate investment | Medium | Low | 3.5%
Real estate property management | Medium | Low | 5.8%
Other sectors | Low | Low | 82.2%

Based on the total exposure at default (EAD), 0.8% of the WB portfolio has a medium/high score for physical
risk (2021: 30.9%) and 17.8% has a medium/high score for transition risk (2021: 30.8%). Aggregated scores
are presented. The decrease of the percentages in 2022 follows from further review of the ING portfolio.
Given the short term horizon of the assessment, a lower financial impact was identified by various sectors
and notably for exposure to physical risk.
The drivers that are considered medium/high risk by most sectors include extreme weather, resource
scarcity, and pollution and waste for physical risk, while changes/adoption of regulatory requirements,
environmental ING policy changes/adoption, and reputational risk are mostly selected with respect to
transition risk.
Moreover, in the last two years we improved our understanding of the physical risk impact of climate events
on our mortgage portfolio. For this assessment we collected granular location data and matched it with
individual climate hazards provided by Royal HaskoningDHV, in partnership with Ambiental, a company of
Royal HaskoningDHV. Applying this methodology, which puts a relative higher weight on the hydrological
risks, we were able to cover 99% of our total residential mortgages book.
Consolidated heatmap scores for Retail Banking

Climate risk | O/S | Summary | Aggregated risk levels | Individual
December 2022 in € million |  |  | Meteorological | Geo-physical | hydrological | Fire |
Netherlands | 113,042 | Very low | Low | Very low | Very low | Very low | 38
Germany | 91,166 | Very low | Low | Very low | Very low | Very low | 1,309
Belgium | 40,367 | Very low | Low | Low | Very low | Very low | 83
Australia | 35,195 | Very low | Medium | Very low | Very low | Very low | 6,642
Spain | 21,598 | Very low | Low | Very low | Very low | Very low | 5,231
Poland | 11,906 | Very low | Low | Very low | Very low | Very low | 13
Italy | 7,711 | Very low | Low | Low | Very low | Very low | 3,181
Romania | 2,628 | Very low | Low | Low | Very low | Very low | 1
Luxembourg | 3,167 | Very low | Low | Very low | Very low | Very low | 69
Other | 146 |  |  |  |  |  |
Total | 326,927 | Very low | Low | Very low | Very low | Very low | 16,568

The column “individual” in the above table represents the total outstanding amount of positions with high
risk exposure to individual physical hazards per country.
The initial assessment was based on the situation per September 2021, of which the outcome was included
in the ING Climate Report 2022. The key insights from this assessment are as follows:
•The aggregated ING global mortgage portfolio is in the very low risk category, <1% of the portfolio has a
high risk score.
•Assessing the portfolio on an individual hazard level, approximately five percent of ING’s mortgage book
has at least one hazard with a high or very high score.
•Considering the medium and long-term horizons (2030, 2050 and 2100), the aggregated summary
climate risk score is expected to increase most for Italy, Romania, and Spain although they will still
remain in ‘low risk’ score category.
Furthermore, the outcome of ING’s bank-wide risk identification and assessment process indicates that
climate risk is an emerging risk considering both its likelihood and impact. That means it has the potential to
significantly affect our performance but its impact on the organisation is more difficult to assess than other
risk drivers. The bottom-up risk identification process in the market risk and funding and liquidity (F&L) risk
areas applies pre-defined financial impact materiality thresholds (CET1 ratio for Market Risk, LCR Surplus for
F&L risk) to assess the significance of risk drivers. Based on these thresholds, it was concluded that climate
change is a financially significant risk driver at ING Bank level for both risk types. The main portion of the
impact is driven by physical risk (extreme weather conditions) for Funding & Liquidity Risk, and by transition
risk (change in policy and regulation due to climate change) for both F&L Risk and Market Risk.

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> Environmental, social and governance risk
ING Bank Annual Report 2022 117
There is growing realisation that nature needs to be an important consideration in corporate decision-
making. The Taskforce on Nature-related Financial Disclosures (TNFD) aims to build a risk management and
disclosure framework that can be used by organisations to identify, assess, manage and disclose nature-
related dependencies, impacts, risks and opportunities. ING supports the TNFD framework and intends to
use it as guidance in processes and reporting. We are currently piloting TNFD’s draft recommendations on
sub-sectors to establish how the framework can be used to manage and report on ING's nature-related
risks.
More detailed information on the risk identification and assessment process can be found in the ING Climate
Report 2022.
Risk appetite
We used the outcomes of the C&E risk heatmap exercise to introduce climate risk elements in the 2022
credit risk appetite. A monitoring mechanism was established for WB at the start of 2022 that limits growth
of sub-sectors with a higher exposure to C&E risks while allowing for growth within the overall sector limit.
As from July 2022, this mechanism has become binding for WB sectors. For Business Banking (BB) sectors a
similar approach was used and the BB credit risk appetite has been in a monitoring period since April 2022.
In addition, climate risk has been incorporated into the 2023 market risk banking book risk appetite with the
introduction of sensitivity metrics per climate risk category.
Stress testing
The regulatory climate risk stress test became part of the biannual ECB Single Supervisory Mechanism (SSM)
stress test in 2022 and ING participated in it. The test consisted of three modules (questionnaire, peer
benchmark, bottom-up stress test) aimed at testing our capabilities for assessing climate risk. The most
significant impact of this scenario is observed in the credit risk area. The ECB shared its assessment of the
climate risk stress test on an aggregated basis in its 2022 Climate Stress Test Report as well as in a bank-
specific report. The key challenges of the stress test were related to data. The required attributes, such as
GHG emissions and energy performance certificates (EPC), were not available for all counterparties and
proxies were used. Other challenges were the modelling of new drivers such as carbon pricing and the long-
term horizon of 30 years.
This regulatory climate stress test, combined with our own climate risk analyses, has been used to enhance
ING’s internal climate risk stress testing through the creation of an internal combined climate risk stress test.
The scenario assumes a prolonged war in Ukraine triggering full stoppage of the Russian gas supply to
Europe. Extreme weather events (i.e. fires in Southern Europe and floods in Northern Europe) create
additional burdens on European economies and energy consumption patterns change. EU governments
step up their efforts to meet the well-below 2° Paris Agreement target by creating a New Green Deal which
leads to soaring carbon taxes. A disorderly transition follows. Moreover, ING faces greenwashing claims in
this stress scenario.
Challenges
Bringing our current work to a more mature level is challenging. To fully understand the financial impact of
any physical risk driver, we need to understand the transmission channels from physical risk to financial
impact. Mapping out the transmission channels is a complex process which deserves better understanding
by both banks and supervisors before making decisions. Another challenge is to translate our insights into
specific actions for both current and future customers. In addition, we need to assess C&E risks on a client
level. To that end we need to be aware of the clients’ readiness to transition to a more sustainable economy
and their capacity to adapt.
Additionally, the key challenge in transitioning from a qualitative to a data-driven approach for the C&E risk
heatmaps is two-fold: sourcing data and interpreting data. Since our clients are active in various sectors and
geographies, we need to consider multiple data sources that often vary in scope, granularity and quality.
Access to real-time, consistent data is a major challenge for risk measurement as definitions and
quantification methodologies are constantly evolving. In the absence of comprehensive company data, the
use of proxies is necessary to assess C&E risks. Due to these limitations, the integration of quantified inputs
into risk modelling has not yet been implemented.
Next steps
In 2023, we will continue our efforts to evaluate both C&E risks and opportunities by further refining our
methodologies. We aim to establish quantitative methodologies for C&E risk identification, materiality
assessment and risk appetite setting. This is supported by the integration of C&E risk considerations in risk
policies and procedures, our C&E risk identification framework as well as the global ESG data management
plan we are developing.
Moreover, access to relevant data is essential to managing nature-related risks. We aim to introduce further
granularity in our biodiversity hotspot analysis. In relation to that we are testing an approach for measuring
biodiversity impact which we expect to give us more detailed insight into the sectors in our portfolio that are
both most dependent on and most impacted by biodiversity.
Furthermore, based on the inventory of training needs of critical functions in front office, risk management,
leadership and support areas, ING will launch tailored learning journeys in the course of 2023 to educate
staff on the C&E risk topic.

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> Environmental, social and governance risk
ING Bank Annual Report 2022 118
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.
Governance
The global head of NFR is responsible for developing the framework of NFR policies and standards within ING,
and for monitoring the quality of non-financial risk management in the ING entities. In addition to the global
steering provided through the framework, the bank's Non Financial Risk Committee (NFRC), chaired by the
Group chief risk officer, is the highest level of the non-financial risk committees within ING and is mandated
by the MBB to opine on and approve non-financial risk matters, to monitor or verify whether appropriate
action is taken by responsible management and endorse the non-financial risk appetite.
Non-financial risk management
Risk categories
ING categorises non-financial risks in the following areas:
•Compliance risk is the risk of ING's integrity being impaired, which can result in reputational damage,
legal or regulatory sanctions, or financial loss, due to a failure (or perceived failure) to comply with
applicable laws, regulations and standards. See more in 'Compliance risk'.
•Information (technology) risk is the risk of financial loss, regulatory sanctions or reputational damage
due to breaches of confidentiality, integrity or availability of information or a lack of information quality
within business processes and/or the supporting IT systems.
•Continuity risk is the risk of financial loss, regulatory sanctions or reputational damage due to business
disruptions (loss of people, processes, systems, data, premises).
•Control risk is the risks of financial loss, regulatory sanctions or reputational damage due to ineffective
organisational structures and governance procedures (including unclear roles and responsibilities and
inadequate reporting structure).
•Processing risk is the risk of financial loss, regulatory sanctions or reputational damage due to failed
(transaction) processing (input, execution, output) or failing process management.
•Unauthorised activity risk is the risk of financial loss, regulatory sanctions or reputational damage due to
employees performing outside the normal course of their business, intentionally giving unauthorised
approvals or overstepping their authority.
•Personal and physical security risk is the risk of financial loss, regulatory sanctions 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 have an impact on ING organisation's confidentiality, integrity or availability.
•Employment practice risk is the risk of financial loss, regulatory sanctions or reputational damage due to
acts that are inconsistent with employment, health and/or safety laws, regulations or agreements, from
payment of personal injury claims, or from diversity/discrimination events.
•Fraud is the deliberate abuse of procedures, systems, assets, data, products and/or services of ING by
those who intend to deceitfully or unlawfully benefit themselves and/or others. This definition of fraud is
specified in the following two categories of fraud.
•Sourcing risk is the risk of financial loss, regulatory sanctions and/or reputational damage resulting from
sourced activities (both IT and non-IT, including intra-group sourcing) not staying within ING’s risk
appetite and not being executed as agreed (with captives or partners), including non-compliance with
internal or external regulations.
Internal fraud: acts of fraud which involves at least one internal party performed by or in collusion with an
ING employee or agent with the consequence of financial loss, regulatory fines, litigation loss, business
disruption and/or reputational damage for ING.
External fraud: acts of fraud or scams by individuals and/or parties excluding ING staff (including
contractors), with the consequence of financial loss, regulatory fines, litigation loss, business disruption and/
or reputational damage for ING.
Measurement approach
ING uses an internal model in line with the Advanced Measurement Approach (AMA) to determine the
regulatory and economic capital amounts that are necessary to cover potential losses resulting from non-
financial risks. This model predicts non-financial risk losses by combining a forward-looking and a backward-
looking view on non-financial risk events. ING reports the outcome of its AMA model quarterly.
Main developments in 2022
Personal and physical security
The war in Ukraine has had a fundamental impact on the lives of the families of more than a 100 Ukrainian
colleagues and the way in which our Ukrainian operations are being conducted. Nevertheless, the impact of
the war on ING’s non-financial risk profile and on operational event losses continues to be limited thanks to
an extensive set of mitigating measures which ING took over the past year.

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ING Bank Annual Report 2022 119
Additionally, from the start of 2022 ING’s focus continued to remain protecting its employees and their
families from the Covid-19 virus by continuing to work partly at home and partly at the office and to
continue servicing its customers as before.
Cybercrime and fraud
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. The continuous
enhancement of the control environment to protect from, and detect and respond to, e-banking fraud,
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 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. See also ‘The world around us’ and ‘How we
make a difference'.
In addition, ING continues to strengthen its global cybercrime and fraud resilience through collaboration
with financial industry peers, law enforcement authorities, government (e.g. National Cyber Security Centre)
and Internet Service Providers (ISPs). Additionally, through ING’s Global Fraud Management team, which
brings together fraud management experts from across domains, there is a central responsibility to ensure
that ING's business and fraud strategy remains aligned on account fraud threats, market best practices,
applicable law and legislation, risk appetite and cost targets.
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, and the implementation of
PSD2 are likely to present ongoing cybercrime-resilience, fraud-management and IT-security challenges,
both in the short and medium-term. Criminal actors are targetting financial and sensitive (payment) data,
such as customer user credentials outside the traditional banking environment. Sensitive (payment) or
personal data can be obtained by criminals via social forums such as WhatsApp and by screen scraping user
credentials when a fallback procedure within PSD2 is allowed. In 2022, these challenges have further
increased with more sophisticated phishing attempts and improved social engineering fraud attempts.
Dealing with current and emerging fraud threats, especially given the ever-increasing use of digital and
online banking, effectively requires continuous improvement of fraud management capabilities such as
real-time transaction monitoring and response capabilities. Furthermore, better alignment and
standardisation is needed for cross-border fraud management across ING and related platforms. With
legislation such as EBA PSD2 and the continuing emphasis on duty of care, financial institutions are
becoming more and more responsible for losses incurred by clients and are taking on more of the burden of
reclaiming those losses.
Data risk management
Data, whether customer, financial, risk or other business, – is core to ING’s purpose. Data leads to insights
and insights empower people to stay a step ahead in life, and in business. In 2022, the ING Data Strategy
was aligned under a new chief data office, next to a newly organised COO/Data Operations domain to better
create a single vision and governance for data, empowering business users with a harmonised foundation.
This encompasses further embedding data functions and improving (bank-wide) data operations in ING’s
way of working, and simplifying, standardising and modernising its technology and data platforms.
Recognising that data risk is an important risk for the bank, ING has created a holistic view and continues to
build awareness of how ING manages risks around data, including personal data protection, data security,
data quality and data ethics.
Identity and access management (IAM)
IAM remains one of the focus areas of ING and an important element in our control framework to prevent
and mitigate the risk of unauthorised access to IT systems and the data processed and stored therein. This
is done by enforcing IAM global processes and controls, which are periodically reviewed and tested. These
processes and controls are supported by technologies, tooling and practices managed by a dedicated IAM
team in the Chief Information Security Office (CISO), which aim to ensure improvements are identified to
address developments both inside and outside ING. In 2022, ING continued to improve, with attention given
to tooling, standardisation and harmonisation of processes, workflows and automation of IAM controls.
Personal data protection
On 25 May 2018, the European General Data Protection Regulation (GDPR) became effective. ING is bound
by the GDPR which affords greater protection to individuals and requires more control on data and
transparency regarding the use of data by companies. In 2022, ING continued to further enhance the data
protection of customers and employees. See also ‘The world around us’.

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ING Bank Annual Report 2022 120
Compliance risk
Introduction
Compliance risk is defined as a threat posed to ING’s standing resulting from failure to act in line with
applicable laws and regulations, internal rules (including ING’s Orange Code and global Code of Conduct)
and/or societal expectations applicable to the bank's services and activities. A failure to adequately mitigate
compliance risk may lead to damage to ING’s reputation and/or legal/regulatory sanctions, and/or financial
loss.
The mission of Compliance is to support ING in conducting its business activities in line with applicable laws
and regulations, taking into account ING’s internal code of conduct and societal expectations. Compliance
wants to drive compliance risk management by desire and design throughout the organisation, unleashing
the power of our data, risk expertise, and ING's workforce to keep the bank safe and sound, and help drive
new and sustainable ways of doing business.
Within ING, compliance risks are defined as those risks that are within the scope of the ING Compliance Risk
Catalogue. The following risk categories apply:
•Financial crime risk refers to the risks of the bank’s products and services being abused for illicit purpose
generating or disguising financial and/or economic crimes (FEC).
•Conduct risk refers to the compliance risks arising from potential or perceived misconduct by ING or its
employees towards its customers, market integrity, business partners, employees and other
stakeholders.
•Organisational risk refers to the compliance risks arising from actual, potential or perceived flaws in the
way that ING is organised and structured including its regulatory and reporting framework.
•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, so as to data retention risk, on having the records being destroyed too soon or
retained too long.
Climate and ESG-related compliance risks are in the process of being added to the Compliance Risk
Catalogue where appropriate in close collaboration with internal stakeholders with the aim of ensuring that
roles and responsibilities with regard to identifying, assessing, managing and overseeing these risks are fully
aligned with ING's organisation globally.
Governance
The Compliance organisation (comprised of three roles: Group Compliance, geographical compliance and
country compliance) is part of ING’s second line of defence. Group Compliance sets the methodologies and
minimum standards for the bank. Geographical compliance (Wholesale Banking/Market Leaders/Challengers
& Growth Markets) together with the functional lines in the countries are responsible for the execution of
these standards, within the risk appetite set. Compliance is tasked with instructing, advising, challenging and
having oversight of the first line of defence in their management of compliance risks and has an active role
in raising awareness (via training and communication), influencing and stimulating a sound compliance risk
culture. The scope of the compliance risks is outlined in the ING Compliance Charter.
Compliance is headed by the chief compliance officer (CCO), who reports directly to the CRO. The CCO has
direct access to the Risk Committee of the Supervisory Board. The CCO and the chairman of the Risk
Committee had regular bilateral consultations in 2022.
OneCompliance strategy
As a global bank in a fast-changing world we want to do the right thing to be safe, secure and compliant for
our customers and for society. We achieve this by living up to the OneCompliance strategy that was
launched in 2019.
The OneCompliance strategy is a multi-year, global compliance strategy and transformation programme
that is based on a framework that aims to help ING manage compliance risks consistently across the
organisation. In 2022, work continued on the following programme goals: a global identity and risk view
allowing people to assess risks in a uniform way; a single, risk-based monitoring methodology to accelerate
improvements in addressing risks; simplified work processes through a uniform framework, to allow people
to focus on what matters; the necessary skills and resources to deliver at the desired quality; intuitive,
actionable and insightful management information and a global dashboard to take smart decisions and
keep oversight on steering within risk appetite and steering our global direction to support everyone in
Compliance. As we operate in a dynamic and challenging environment we are continuously learning and
improving while getting to a more sustainable and mature level within the Compliance department.
Financial crime risk
Financial crime risk results from illicit activity in the form of money laundering, terrorist financing, bribery
and corruption, sanctions evasion, fraud and customer tax offences and other predicate offences to money
laundering such as environmental crimes and human trafficking. It arises in the course of ING’s day-to-day
banking operations if our customers, employees or third parties undertake or facilitate financial crime, or if
our products and services are misused for illicit purposes to generate or disguise financial crime.
We have zero tolerance for deliberately or knowingly facilitating financial crime - keeping ING safe, secure
and compliant remains a top priority to protect our business and society at large from financial crime and
its corrosive effects upon individuals and communities.

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ING Bank Annual Report 2022 121
Financial crime risk management
The bank's NFRC, chaired by ING’s CRO, is the principal risk management forum where, among other things,
financial crime risk is discussed. This committee reviews, where appropriate, escalates key financial crime
topics, threats and risks across ING to the EB and MBB. On KYC (know your customer), the Global KYC
Committee), chaired by ING's COO, is mandated by the MBB to steer, prioritise and approve KYC-related
topics undertaken across ING, and to oversee compliance with the relevant laws and regulations and
internal rules related to KYC. The day-to-day responsibility for the oversight of ING’s compliance with our
legal and regulatory obligations in relation to financial crime risk resides with the global head Financial
Crime Compliance, who reports to ING’s chief compliance officer, with oversight by the CRO.
We believe all of our people have a role to play in the fight against financial crime. Having a robust and
sound risk culture embedded in our day-to-day way of working is a foundational element of our financial
crime risk control environment. We define the accountabilities and responsibilities of our workforce in
accordance with the three lines of defence model, considering our business, geographical and functional
structure.
As an organisation, we’re committed to meeting our legal and regulatory requirements and the standards
we also expect from ourselves. ING remains subject to (regulatory) investigations and scrutiny in certain
jurisdictions, and we’re committed to executing and implementing the identified enhancements required to
our financial crime risk framework in a sustainable way for the longer-term.
Key risk management processes
ING strives to play its part in contributing to the safeguarding of the financial system against illicit financial
activity, in the context of heightened and changing regulatory expectations and as financial crime risks
continue to evolve. To fulfil our responsibility as a global financial institution in combatting financial crime,
we believe it is essential to comply with anti-money laundering and to counter the financing of terrorism
(AML/CFT), establish a reasonable and risk-based control framework to mitigate financial crime risk, and to
seek to provide useful information to relevant government agencies. We also believe it is important to
respond swiftly and proactively to new financial crime threats and techniques (which can be increasingly
sophisticated as financial criminals harness and misuse new technological capabilities) as well as to relevant
media reporting.
To mitigate financial crime risks, we apply a framework of preventative and detective systems and controls,
underpinned by policy, procedures and related control standards across our global business in all locations
where we operate. In 2022, we remained focused on our Financial Economic Crime Controls Maturity
Programme (FCMP) (see also ‘Know your customer (KYC)’) by continuing to strengthen our financial crime
risk management framework and supporting sustainable remediation of known issues. At the same time,
we acknowledge that the continuous maturing of the financial crime risk management framework, as well
as other developments such as regulatory and legislative changes, will continue to require our attention and
commitment in future years.
In 2022, we continued to enhance the annual Systematic Integrity Risk Analysis (SIRA) across our global
footprint, which assesses inherent and residual integrity risks related to financial crime and the
effectiveness of the associated processes and controls ING has in place. This provides insights into the
financial crime integrity risks that ING may be exposed to, so we can appropriately manage these risks in
accordance with our risk appetite. Our risk-based surveillance (screening and monitoring) controls are also
designed to identify activity that may require additional investigation or other risk management actions,
and where appropriate, reporting to the relevant authorities.
We monitor our compliance in relation to financial crime risk and our tolerance levels on a regular basis
against a set of quantitative and qualitative financial crime risk appetite metrics that are approved by the
Non-Financial Risk Committee.
Bribery and corruption
Corruption fuels instability and conflict and curbs economic growth. It undermines business confidence and
corporate integrity, hinders fair business competition and harms international trade. Bribery and corruption
risks are part of our non-financial risk framework and are included in the client and third-party due diligence
and monitoring measures in our financial crime risk management framework. We have continued to
structurally strengthen our response to bribery and corruption risks in key areas as part of our multi-year
enhancement programme and FCMP, and in support of our zero-tolerance approach for bribery and
corruption.
Customer tax compliance
ING remains committed to its reporting obligations under the Foreign Account Tax Compliance Act (FATCA)
and Common Reporting Standards (CRS). Throughout 2022, we have worked to improve the quality of
reports provided to tax authorities and reacted to the implementation of mandatory disclosure rules for EU
jurisdictions (implemented via the amendment to Directive 2011/16 (DAC6)). We also continue to focus on
customer tax integrity, as we do not want to facilitate or be involved in tax-related financial crime through
servicing customers.
Key developments in 2022
War in Ukraine
2022 saw the Russian invasion of Ukraine. As well as the devastating political, social and economic
consequences of the war, it has also had an impact on the nature and scale of FEC-related threats. Since the
outbreak of the war, millions of refugees have fled the country making them vulnerable to exploitation by

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ING Bank Annual Report 2022 122
criminals involved in human trafficking and migrant smuggling. There has also been an increase in the scale
of illegal trafficking of weapons.
During 2022, financial institutions have had to respond to new and complex targeted sanctions, but also
remain vigilant to elevated and increased levels of various other financial crimes threats and risks. We have
produced regular and actionable guidance on evolving financial crime developments resulting from the war
that has been shared across ING, including potential scenarios to identify where these risks may manifest
and datapoints that may detect unusual transactions.
Sanctions related developments
Russia's invasion of Ukraine has fundamentally changed the global and political landscape, resulting in a
world-wide response, whereby new and significant sanctions packages were imposed against Russia and
Belarus since the end of February 2022. More than 3000 new sanctions have been implemented. The
unprecedented velocity and scope of sanctions imposed by the international community has resulted in a
highly complex and changing compliance environment for global financial institutions.
The international community is leveraging their sanction tools in response to the escalation of Russia's
invasion of Ukraine, however sanction measures of the US, UK and EU can differ in their scope and these
differences present complex operational and legal challenges for business that operate globally or facilitate
global trade and payment activities. These complexities and challenging require careful navigation.
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 noncompliance with
applicable sanctions.
Covid-19 and cost of living
Opportunistic criminals were quick to exploit the disruption caused by the Covid-19 pandemic and continue
to do so as economic uncertainty and cost of living increases. During 2022, we continued to focus on
protecting customers from fraud and cyber-related crimes, as well as identifying evolving criminal money
laundering methods.
Evolving external landscape
Financial institutions continue to face considerable regulatory scrutiny in relation to detecting and
preventing financial crime, and increasing costs of compliance. In addition, the complexity of the regulatory
landscape continues to give rise to potential tension between data privacy (GDPR), anti-money laundering/
counter terrorism financing and anti-corruption laws and regulations. This includes requirements for sharing
information within ING in relation to financial crime risks to manage our risk exposure, while also complying
with relevant data legislation (which can differ significantly depending on jurisdiction). Society’s
expectations with regard to financial institutions' accountability for safeguarding the integrity of the
financial system also create an increasingly demanding environment.
We take our gatekeeper responsibility seriously. We believe that by proactively participating in public-
private partnerships and collaborating with other banks, as well as investing in new and innovative
technological capabilities, we can be more effective in the collective fight against financial crime.
Payment service providers
The position of payment service providers (PSPs) in the financial service industry has become prominent and
permanent over the years. PSPs face continuous challenges to demonstrate compliance with industry
standards and recommendations, such as the guidance provided by the Wolfsberg Group and Financial
Action Task Force (FATF) on payment transparency. Having limited transparency on transactions initiated
through the different payment platforms increases the challenge of monitoring whether PSPs and banks are
potentially misused to facilitate tax evasion, money laundering and terrorist financing.
ING will continue to contribute to dialogue with PSPs, regulators and industry bodies on these challenges
and aim to obtain the required transparency on payment information. This supports compliance with the
applicable laws and regulations and internal policies and instructions as well as monitoring to ensure that
ING stays within its financial crime risk appetite.
EU AML/CFT legislative package
In mid-2021 the European Commission adopted a package of legislative proposals aimed at strengthening
anti-money laundering (AML) and countering the financing of terrorism (CFT) rules. This included
amendments to existing legislation to tackle emerging challenges linked to technological innovations, such
as virtual assets, as well as the increasingly global nature of terrorist organisations. It also included
centralisation of EU AML/CFT supervision (the European Anti-Money Laundering Authority) and establishing
a single EU AML/CFT rulebook, which provides financial institutions with harmonised and directly applicable
AML/CFT rules. Though not yet finalised, ING welcomes this harmonisation, which removes a degree of
regulatory complexity. ING has participated in workstreams and analysis prepared by global banking
associations such as the Dutch Banking Association and the European Banking Federations to assist us in
assessing the potential impact of the AML legislative package on the bank.

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DNB, the Dutch central bank, published its report ‘From Recovery to Balance’ on the use of risk-based
approaches. ING actively participates in related DNB workshops to enhance the effectiveness of fighting
financial crime by focusing on higher risks (prioritising these in terms of capacity allocation; i.e. do more
where necessary and less where possible).
Virtual assets
Blockchain technology, which underlies most virtual assets, continued to evolve and be accepted by the
public. Crypto assets can be used for legal and illegal purposes. In 2022, global regulators, private industry
and policy makers continued to focus on where they may be used for illegal activity, including money
laundering, evasion of capital and sanctions, controls and payments in ransomware attacks. While there
has been maturity in understanding how virtual assets ecosystems may be potentially abused for financial
crime purposes, they continue to pose challenges for financial institutions.
We continued to contribute to ongoing dialogue with regulators on this topic throughout 2022. We have
created and shared guidance on the evolving risks to enhance the knowledge and understanding of the
virtual-assets landscape and its convergence with financial crime risk and we strive to ensure that ING
remains a safe and compliant bank.
Environmental crime
Environmental crime is among the most profitable criminal enterprises and covers a wide range of unlawful
activities including the illegal wildlife trade, the illegal extraction and trade of forestry and natural resources
as well as illegal waste and illegal fisheries crime. There is also an increasing interface between
environmental crimes and other crimes, most notably corruption, human trafficking and modern slavery
and trade-based fraud. Throughout 2022, the topic has gained significant attention from regulators, law
enforcement and non-governmental organisations across the globe due to the scale, nature and cost of the
crime as well as the damaging effects they have on society.
In 2022, we examined the risks arising from the illegal trade in wildlife and in waste and how to identify
suspicious financial flows and actors linked to them. We continued our membership of the United for
Wildlife Financial Taskforce, which also covers illegal forestry trade, We work with private, public and third-
sector partners to detect, disrupt and prevent illegal crimes in the wildlife and forestry trade.
Know Your Customer (KYC)
Know your customer and financial crime compliance play a major role in ensuring 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 customers and monitor and screen transactions. Potentially unusual
or suspicious transactions are reviewed and, where applicable, reported to the relevant authorities.
We are continuously working to further strengthen the KYC processes across the bank as and where
required. This includes enhancing customer due diligence files and making structural improvements in
frameworks, processes and systems.
Global approach
ING takes a global approach in its KYC improvement activities. In 2022, ING updated its KYC policies in line
with external regulatory developments in anti-money laundering and financial sanctions and continued
substituting local technology with centralised global technology enabling us to further improve the way we
onboard, monitor and screen customers using a standardised approach across the world. In 2022, among
other things, we progressed with the implementation of Global Transaction Monitoring tooling (with the last
migration planned to take place in 2023), designed and implemented a global standard Quality
Management Frameworks and further centralised operations, bundling expertise in dedicated operational
hubs.
KYC policy framework
The KYC policy and related control standards (the KYC policy framework) set the minimum requirements
and control objectives for all ING entities to guard against involvement in financial crime activity. The KYC
policy framework reflects relevant national and international laws, regulations, guidance documents and
guidelines from national, European and international authorities, (supra)national risk assessments and
industry standards.
Public-private partnerships
To continue to be more effective in our efforts to counter financial economic crime, we work closely with our
peers, regulators and law enforcement.
Throughout 2022, ING continued to work in a consortium of Dutch banks on Transaction Monitoring
Netherlands (TMNL). The initiative, which monitors transactions within a combined database, is operational
and intersecting with thematic areas of focus for law enforcement, enabling us to better understand
potential criminal money flows, and improve our detection controls in response to these insights. In the
Netherlands, ING also works with the government’s Financial Intelligence Unit and three other banks in the
Fintell Alliance.
In Germany, ING joined the public-private partnership Anti-Financial Crime Alliance (AFCA) in 2020 to foster
mutual exchange of information within the financial system. The alliance consists of approximately 30
members, among them BaFin as regulator, the FIU, other public authorities, the largest financial institutions
as well as representatives from the non-financial sector. ING in Germany continues to contribute in various

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> Compliance risk
ING Bank Annual Report 2022 124
forums to the further development of industry-wide standards (e.g. related to digitalisation and information
sharing as well as to SAR filing (suspicious activity report) obligations.
Knowledge and behaviour
We believe all our people play a role in keeping ING safe, secure and compliant and that a sound risk culture
requires us to act with integrity above all. We want to empower our workforce with the skills and knowledge
they need to fight financial crime and encourage them to speak up if they have concerns relating to
financial crime risk management.
In 2022, our (mandatory) training programme for KYC staff continued, including our partnership with the
Association of Certified Anti-Money Laundering Specialists (ACAMS) to develop and provide tailored, certified
training. The ACAMS training portfolio focuses on learning paths that provide professional foundational skills
or advance expertise in a range of topics including customer due diligence, screening, transaction
monitoring and sanctions. Over 27,000 ACAMS trainings were enrolled in 2022. Our internal training
programme for 2022 included additional focus on further strengthening our risk management mindset.
Following work in 2021, bottom-up initiatives have been further developed into scalable solutions that
address behavioural challenges related to decision-making, ownership and group dynamics. Examples are
the ‘feedback loop’ and ‘discover and connect’, which is a way to connect employees across the different
functions through department visits. Furthermore, as part of a top-down approach, senior leadership came
together to discuss drivers and behavioural changes needed to improve decision making and collaboration
throughout the entire KYC chain.
Read more on behavioural risk in ‘Risk culture’.
Conduct compliance and ethics
Conduct risk is defined by anything we do that can result either in customer detriment or an impact to
market integrity. Conduct compliance and ethics includes client protection and transparency (treating
customers fairly), market conduct (including market manipulation), anti-competitive conduct, conflicts of
interest and ethics. Ethics risk includes the Orange Code, global Code of Conduct, as well as our
Whistleblower framework.
Treating customers fairly
Improvements to our framework around Markets in Financial Services Directive (MiFID) have continued as
planned allowing a more effective client protection and product approval committee (CPAC) framework
focussing on investment and financial markets products to both WB and Retail clients. The Capital Markets
Recovery Package (CMRP) with regards to MiFID, new ESMA Guidelines on appropriateness and execution-
only requirements as well as ESMA's statement on payment for order flow (PFOF) have been implemented.
Client protection and product approval governance was simplified to support a global and consistent
application of risk appetite when offering investment products and services to our customers whether WB or
Retail, while removing overlap from the MiFID implementation. A particular focus this year for CPAC has
been to strengthen central guidance on cryptocurrencies and crypto-linked financial products.
Alongside direct consumer protection requirements as laid down in specific regulations (e.g. MiFID II) ING is
bound by local consumer protection laws and has adopted its own minimum standards, such as the
Customer Golden Rules. These rules were updated and rolled out globally providing further standardisation
across all products, services and jurisdictions. This is further enforced by recent market developments such
as increased inflation and interest rates, which require also requiring specific focus on customers in
vulnerable positions. The range of products and services in scope will include mortgages and consumer
lending.
Transaction reporting activities continued to improve both in terms of reporting quality and scope through a
group-wide governance framework and controls. The upload of the main transaction reporting backlog is
now completed. Preparations for future transaction reporting changes are being made, including the
European Market Infrastructure Regulation (EMIR) Refit.
In relation to insurance products, global policy and controls are in place to align with the EU's Insurance
Distribution Directive (IDD).
In response to the increasing importance of sustainable products for our clients and the need for ESG
considerations to form an integral part of our products and services to clients, alongside the development
and roll-out of policy on SFDR and ESG-related MiFID II and IDD amendments, measures on developing,
selling and promoting sustainable products are being strengthened. Compliance is not an exception and ESG
continues to be embedded within the ING organisation across all three lines of defence, strengthening
compliance with both regulatory requirements and internal standards.
Market conduct
Market conduct risk stems from behaviour that can impact market integrity. Public confidence in smooth
functioning markets is crucial for economic growth and wealth. As part of our work in 2022 to strengthen
our market conduct framework, global procedures on maintaining information barriers, insider lists and
communicating inside information were further improved across ING. Steps have been made towards
automating, standardising and centralising our approach to personal account dealing rules across the
group. Furthermore, two new e-learnings have been designed on inside information and detecting
suspicious orders and transactions, with one already rolled out to targeted employees.

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ING Bank Annual Report 2022 125
Conflicts of interest
The Conflicts of Interest policy sets the obligation to identify, assess and manage conflicts of interest when
personal or organisational interests are in conflict over the interest of our customers, employees or other
stakeholders. In 2022, the Conflicts of Interest policy was revised and implemented to further align with the
standards as defined by enterprise risk management. The policy incorporates key requirements for both
personal and organisational conflicts of interest in line with European Bank Authority Guidelines on Internal
Governance. Next to the updated policy, mandatory instructions on conflict-of-interest registers are
implemented which provides instructions to identify, assess, mitigate or prevent and record all structural
and incidental conflicts of interest.
Whistleblower
The programme launched in 2021 to enhance the global whistleblower process has been concluded. In
2022, whistleblowing enhancement activities continued with an emphasis on increasing employee
awareness on misconduct reporting. Sanitised whistleblowing data has been shared within the organisation
to provide more transparency on the types of concerns employees report and the rapidity of our response.
Innovation, analytics and digitalisation
In 2022, we took the strategic decision to adapt our innovation approach and unwind ING Neo. This will bring
initiatives closer to our core business and functions, in line with our strategic focus of providing a superior
customer experience and putting sustainability at the heart of what we do.
We continue to harness new and innovative technological capabilities to keep customers safer and to
enhance their digital journey with ING. To this end, the Blacksmith solution for KYC has become our default
tool for financial institutions and the CoorpID platform, which digitalises the KYC process for corporate
clients, is now used in nine countries. Further, our Ventures team has also closed an investment in Sardine
which provides AI-enabled KYC, compliance and fraud detection platforms to financial services firms. The
initiatives and investments help us to respond swiftly and effectively to the changing regulatory landscape
and underlying policies in relation to financial crime.

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> Compliance risk
ING Bank Annual Report 2022 126
Model risk
Introduction
Model risk is the risk that the financial or reputational position of ING is negatively impacted as a
consequence of the use of models. Model risk can arise from errors in the development, implementation,
use or interpretation of models, or from incomplete or wrong data etc., leading to inaccurate, non-
compliant or misinterpreted model outputs.
A model is defined as a quantitative method, system, or approach that applies statistical, economic,
financial or mathematical theories, techniques, and assumptions to process input data into quantitative
estimates or whose inputs are partially or wholly qualitative or based on expert judgement.
Governance (*)
The head of Model Risk Management (MoRM) reports to the ING chief risk officer. The Model Risk
Management Committee (MoRMC) is the dedicated authority within ING for model risk management. It is a
committee designated by the MBB. It is chaired by the ING chief risk officer and co-chaired by the head of
MoRM.
Model lines of defence (*)
ING’s model risk and control structure is based on the three model lines of defence (MLoD) approach. This
approach aims to provide a sound governance framework for model risk management by defining and
implementing three different management layers with distinct roles and oversight responsibilities.

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ING Bank Annual Report 2022 127
The composition and main activities within the three model lines of defence (MLoD):
•The first MLoD is composed of the model owners, model users, data management and model
development, and is accountable for the implementation of model risk controls which encompass model
development, implementation and use of the models as well as monitoring of models’ performance.
•The second MLoD is composed of model validation and model risk oversight, which owns the model risk
management framework, proposes the model risk appetite, provides challenge to model risk
identification and assessment and provides an independent validation of models used within ING.
•The third MLoD is the internal audit, reviewing the quality of model risk management execution in all
lines of defence and providing assurance over the first and second line model risk management
activities.
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. Current model RAS metrics are focused on the most important models for ING: credit
risk and other models with elevated supervisory attention. These metrics are reported to the MBB on a
quarterly basis.
Model risk management (MoRM) (*)
The MoRM policy framework comprises the total set of measures and tools put in place to manage model
risk.To enable setting model risk management standards that are proportionate to a model’s importance,
ING classifies models based on their materiality and reputational risk. The classification determines the
depth and extent of the applied model risk management activities, including model validation. During 2022,
the MoRM policy framework was updated and enhanced, incorporating ING model data-ethics principles and
integrating a risk-based approach to model validation. Next to the generic MoRM policy framework,
dedicated model validation frameworks are in place. These set the validation standards for the key model
types such as credit, market, liquidity, operational risk, IRRBB, KYC, and other model categories. These
frameworks are continuously being enhanced to keep up-to-date with regulatory and technical
developments.
On an aggregated level model risk is monitored via analysis of data from the global model inventory. The
insights, from aggregated data analysis, are reported to the MoRMC and to the MBB so that senior
management can take well-informed decisions on acceptance or further mitigation of model risk.
Model lifecycle (*)
The next figure provides a schematic overview of the model lifecycle, where orange represents the activities
of the first MLoD, grey represents the second MLoD and light grey is the third MLoD. The objectives of the
different processes are outlined below.
Initiation or change: The initiation of the development of a new model or change in an existing model can
be triggered by internal or external factors, such as business needs, regulation changes and/or model
validation findings.
Data collection is the process of defining and collecting data that meets the requirements for model
development. The process includes the definition of the data needed and assessment of data availability
and data quality.
Model development is a structured process that leads to a model that is consistent with the model owner
requirements, bank policy and relevant regulation where applicable.

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> Model risk
ING Bank Annual Report 2022 128
Pre-approval validation is an independent assessment to determine whether a newly developed or
materially changed model is valid for its intended use. The approach to model validation is proportional to
the model risk as reflected in the ING model risk classification.
The objective of the model approval stage is to ensure models are formally approved bye the designated
approval authority prior to deployment.
During the implementation stage, the model is deployed in a production environment, after completion of
required model testing and corresponding approval.
In the model use stage the model is applied by the users for the specific purpose for which it was designed.
The model may only be used after formal approval.
The objective of model monitoring is to determine if the model is performing as expected by regularly
assessing model accuracy and/or predictive ability, considering internal or external developments that may
influence model performance. Model performance monitoring begins when a model is deployed for use and
continues until the model has officially been decommissioned.
Periodic validation assesses, on a regular basis, whether a model is still valid for its intended use and if the
model is used as intended, taking into consideration any internal or external changes since the last
validation. The frequency of periodic validation depends on the model risk, model type and applicable
regulation.
A model that is/will no longer be used must be decommissioned.

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> Model risk
ING Bank Annual Report 2022 129
Business risk
Introduction
Business risk for ING has been defined as the exposure to value loss due to fluctuations in volumes/margins,
net fee and commission income as well as expenses. It is the risk inherent to strategy decisions, internal
efficiency and the business environment. Business risk economic capital is calculated via the variance-
covariance methodology for these risks, covering the risk that volume/margins, net fee and commission
income, and operating expenses will deviate from the expected expenses and incomes over the horizon of
the relevant activities.
Governance and risk management
ING applies an explicit risk appetite statement regarding business risk, focusing on earnings stability and
diversification of the business mix. Diversification reduces the risk that volumes and/or margins will suddenly
drop due to unexpected changes in the business environment for certain markets and products.
Furthermore, the underlying risk types (expense risk, volume-margin risk, and net fee and commission
income risk) are mitigated and managed differently. Expense risk is monitored and managed via the
financial performance of the bank and the local units, whereby the reported expense numbers are
compared quarterly with the projected cost/income ratio. Deviations from this ambition are monitored as
part of the financial projections that are discussed continuously within different parts of the organisation.

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> Business risk
ING Bank Annual Report 2022 130
Contents
Consolidated financial statements

Consolidated statement of financial position | 133 |
Consolidated statement of profit or loss | 134 |
Consolidated statement of comprehensive income | 135 |
Consolidated statement of changes in equity | 136 |
Consolidated statement of cash flows | 139 |

Notes to the consolidated financial statements

1 | Basis of preparation and significant accounting policies | 141 |

Notes to the consolidated statement of financial position

2 | Cash and balances with central banks | 162 |
3 | Loans and advances to banks | 162 |
4 | Financial assets at fair value through profit or loss | 162 |
5 | Financial assets at fair value through other comprehensive income | 164 |
6 | Securities at amortised cost | 165 |
7 | Loans and advances to customers | 166 |
8 | Investments in associates and joint ventures | 167 |
9 | Property and equipment | 168 |
10 | Intangible assets | 169 |
11 | Other assets | 169 |
12 | Deposits from banks | 170 |
13 | Customer deposits | 170 |
14 | Financial liabilities at fair value through profit or loss | 171 |
15 | Provisions | 172 |
16 | Other liabilities | 172 |

17 | Debt securities in issue | 173 |
18 | Subordinated loans | 173 |
19 | Equity | 174 |

Notes to the consolidated statement of profit or loss

20 | Net interest income | 177 |
21 | Net fee and commission income | 178 |
22 | Valuation results and net trading income | 178 |
23 | Investment income | 179 |
24 | Net result on derecognition of financial assets measured at amortised cost | 180 |
25 | Other net income | 180 |
26 | Staff expenses | 180 |
27 | Other operating expenses | 181 |

Notes to the consolidated statement of cash flows

28 | Net cash flow from operating activities | 182 |
29 | Changes in liabilities arising from financing activities | 182 |
30 | Cash and cash equivalents | 182 |

Segment reporting

31 | Segments | 183 |
32 | Information on geographical areas | 187 |

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ING Bank Annual Report 2022 131
Additional notes to the consolidated financial statements

33 | Pension and other post-employment benefits | 189 |
34 | Taxation | 192 |
35 | Fair value of assets and liabilities | 195 |
36 | Derivatives and hedge accounting | 206 |
37 | Assets by contractual maturity | 214 |
38 | Liabilities and off-balance sheet commitments by maturity | 216 |
39 | Transfer of financial assets, assets pledged and received as collateral | 219 |
40 | Offsetting financial assets and liabilities | 220 |
41 | Contingent liabilities and commitments | 225 |
42 | Legal proceedings | 225 |
43 | Consolidated companies and businesses acquired and divested | 228 |
44 | Principal subsidiaries, investments in associates and joint ventures | 229 |
45 | Structured entities | 230 |
46 | Related parties | 231 |
47 | Capital management | 234 |
48 | Subsequent events | 235 |

Parent company financial statements

Parent company statement of financial position | 237 |
Parent company statement of profit or loss | 238 |
Parent company statement of changes in equity | 239 |
Notes to the parent company financial statements | 241 |

Other information and appendices

Independent auditor’s report | 258 |
Articles of Association – Appropriation of results | 266 |
Risk factors | 267 |

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ING Bank Annual Report 2022 132
Consolidated statement of financial position
As at 31 December

in EUR million | 2022 | 2021 |  |  | 2022 | 2021
Assets |  |  |  | Liabilities |  |
Cash and balances with central banks 2 | 87,614 | 106,520 |  | Deposits from banks 12 | 56,632 | 85,092
Loans and advances to banks 3 | 35,103 | 23,591 |  | Customer deposits 13 | 686,341 | 657,831
Financial assets at fair value through profit or loss 4 |  |  |  | Financial liabilities at fair value through profit or loss 14 |  |
– Trading assets | 56,875 | 51,389 |  | – Trading liabilities | 39,088 | 27,113
– Non-trading derivatives | 3,893 | 1,536 |  | – Non-trading derivatives | 3,048 | 2,120
– Designated as at fair value through profit or loss | 6,159 | 6,355 |  | – Designated as at fair value through profit or loss | 50,883 | 41,808
– Mandatorily at fair value through profit or loss | 46,844 | 42,684 |  | Current tax liabilities | 324 | 271
Financial assets at fair value through other comprehensive income 5 | 31,625 | 30,635 |  | Deferred tax liabilities 34 | 257 | 603
Securities at amortised cost 6 | 48,160 | 48,319 |  | Provisions 15 | 1,030 | 973
Loans and advances to customers 7 | 635,557 | 627,550 |  | Other liabilities 16 | 13,344 | 12,695
Investments in associates and joint ventures 8 | 1,500 | 1,587 |  | Debt securities in issue 17 | 58,075 | 57,443
Property and equipment 9 | 2,446 | 2,515 |  | Subordinated loans 18 | 15,789 | 16,719
Intangible assets 10 | 1,102 | 1,156 |  | Total liabilities | 924,811 | 902,668
Current tax assets | 349 | 533 |  |  |  |
Deferred tax assets 34 | 1,796 | 957 |  | Equity 19 |  |
Other assets 11 | 8,839 | 5,991 |  | Share capital and share premium | 17,067 | 17,067
|  |  |  | Other reserves | -984 | 1,069
|  |  |  | Retained earnings | 26,462 | 29,778
|  |  |  | Shareholders’ equity (parent) | 42,546 | 47,914
|  |  |  | Non-controlling interests | 504 | 736
|  |  |  | Total equity | 43,050 | 48,650
Total assets | 967,861 | 951,317 |  | Total liabilities and equity | 967,861 | 951,317

References relate to the accompanying notes. These are an integral part of the Consolidated financial statements.

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ING Bank Annual Report 2022 133
Consolidated statement of profit or loss
for the years ended 31 December

in EUR million | 2022 | 2021 | 2020 |  |  | 2022 | 2021 | 2020
Continuing operations |  |  |  |  |  |  |  |
Interest income using effective interest rate method | 24,541 | 18,657 | 20,865 |  | Addition to loan loss provisions | 1,861 | 516 | 2,675
Other interest income | 3,935 | 2,474 | 1,846 |  | Staff expenses 26 | 6,152 | 5,938 | 5,817
Total interest income | 28,476 | 21,131 | 22,711 |  | Other operating expenses 27 | 5,040 | 5,257 | 5,344
|  |  |  |  | Total expenses | 13,053 | 11,711 | 13,835
Interest expense using effective interest rate method | -10,969 | -5,550 | -7,507 |  |  |  |  |
Other interest expense | -3,761 | -1,966 | -1,603 |  | Result before tax | 5,493 | 6,774 | 3,810
Total interest expense | -14,730 | -7,516 | -9,110 |  |  |  |  |
|  |  |  |  | Taxation 34 | 1,723 | 1,876 | 1,317
Net interest income 20 | 13,745 | 13,615 | 13,600 |  | Net result | 3,769 | 4,898 | 2,493
Fee and commission income | 5,085 | 5,004 | 4,514 |  | Net result (before non-controlling interests) | 3,769 | 4,898 | 2,493
Fee and commission expense | -1,499 | -1,487 | -1,503 |  | Net result attributable to Non-controlling interests | 102 | 128 | 78
Net fee and commission income 21 | 3,586 | 3,517 | 3,011 |  | Net result attributable to Shareholder of the parent | 3,667 | 4,770 | 2,415
Valuation results and net trading income 22 | 1,503 | 847 | 852 |  |  |  |  |
Investment income 23 | 181 | 167 | 152 |  |  |  |  |
Share of result from associates and joint ventures 8 | 92 | 141 | 66 |  |  |  |  |
Impairment of associates and joint ventures 8 | -192 | -3 | -235 |  |  |  |  |
Result on disposal of group companies | 6 | -29 | -3 |  |  |  |  |
Net result on derecognition of financial assets measured at amortised cost 24 | -5 | 0 | 189 |  |  |  |  |
Other net income 25 | -369 | 230 | 12 |  | Dividend per ordinary share | 13.50 | 6.72 | 0.09
Total income | 18,546 | 18,485 | 17,645 |  | Total amount of dividend paid (in million euros) | 6,277 | 3,125 | 43

References relate to the accompanying notes. These are an integral part of the Consolidated financial statements.

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ING Bank Annual Report 2022 134
Consolidated statement of comprehensive income
for the years ended 31 December

in EUR million | 2022 | 2021 | 2020
Net result (before non-controlling interests) | 3,769 | 4,898 | 2,493
Other comprehensive income |  |  |
Items that will not be reclassified to the statement of profit or loss: |  |  |
Realised and unrealised revaluations property in own use | 15 | -2 | -7
Remeasurement of the net defined benefit asset/liability 33 | -19 | 95 | 28
Net change in fair value of equity instruments at fair value through other comprehensive income | -126 | 96 | -335
Change in fair value of own credit risk of financial liabilities at fair value through profit or loss | 165 | 37 | -19
Items that may subsequently be reclassified to the statement of profit or loss: |  |  |
Net change in fair value of debt instruments at fair value through other comprehensive income | -428 | -178 | 36
Realised gains/losses on debt instruments at fair value through other comprehensive income reclassified to the statement of profit or loss | -26 | -42 | -34
Changes in cash flow hedge reserve | -3,158 | -1,955 | 355
Exchange rate differences 1 | 436 | 143 | -1,620
Share of other comprehensive income of associates and joint ventures and other income | 0 | -3 | 7
Total comprehensive income | 629 | 3,089 | 904
Comprehensive income attributable to: |  |  |
Non-controlling interests | -190 | -247 | 133
Shareholders of the parent | 819 | 3,336 | 770
| 629 | 3,089 | 904

1 Includes impact of application of hyperinflation accounting under IAS 29.
References relate to the accompanying notes. These are an integral part of the Consolidated financial
statements.
For the disclosure on the income tax effects on each component of the other comprehensive income
reference is made to Note 34 'Taxation'.

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ING Bank Annual Report 2022 135
Consolidated statement of changes in equity

in EUR million | Share capital and share premium | Other reserves | Retained earnings | Shareholders' equity (parent) | Non- controlling interests | Total equity
Balance as at 31 December 2021 | 17,067 | 1,069 | 29,778 | 47,914 | 736 | 48,650
Impact IAS 29 on opening balance |  | 627 | -563 | 64 |  | 64
Balance as at 1 January 2022 | 17,067 | 1,696 | 29,215 | 47,978 | 736 | 48,714
Net change in fair value of equity instruments at fair value through other comprehensive income |  | -95 | -23 | -118 | -7 | -126
Net change in fair value of debt instruments at fair value through other comprehensive income |  | -406 |  | -406 | -22 | -428
Realised gains/losses on debt instruments at fair value through other comprehensive income reclassified to the statement of profit or loss |  | -25 |  | -25 | -1 | -26
Changes in cash flow hedge reserve |  | -2,901 |  | -2,901 | -257 | -3,158
Realised and unrealised revaluations property in own use |  | -12 | 26 | 15 | 0 | 15
Remeasurement of the net defined benefit asset/liability 33 |  | -19 |  | -19 | 1 | -19
Exchange rate differences and other |  | 442 |  | 442 | -5 | 436
Share of other comprehensive income of associates and joint ventures and other income |  | 26 | -26 |  |  | 0
Change in fair value of own credit risk of financial liabilities at fair value through profit or loss |  | 150 | 15 | 165 |  | 165
Total amount recognised directly in other comprehensive income net of tax |  | -2,840 | -8 | -2,848 | -292 | -3,140
Net result |  | 161 | 3,506 | 3,667 | 102 | 3,769
Total comprehensive income net of tax |  | -2,679 | 3,498 | 819 | -190 | 629
Dividends |  |  | -6,277 | -6,277 | -41 | -6,319
Employee stock option and share plans |  |  | 27 | 27 | 0 | 27
Changes in the composition of the group and other changes |  |  | -1 | -1 | 0 | -1
Balance as at 31 December 2022 | 17,067 | -984 | 26,462 | 42,546 | 504 | 43,050

References relate to the accompanying notes. These are an integral part of the Consolidated financial statements.
Changes in individual Reserve components are presented in Note 19 'Equity'.

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ING Bank Annual Report 2022 136
Consolidated statement of changes in equity - continued

in EUR million | Share capital and share premium | Other reserves | Retained earnings | Shareholders' equity (parent) | Non- controlling interests | Total equity
Balance as at 31 December 2020 | 17,067 | 2,334 | 28,273 | 47,675 | 1,022 | 48,697
Net change in fair value of equity instruments at fair value through other comprehensive income |  | 101 | -6 | 94 | 2 | 96
Net change in fair value of debt instruments at fair value through other comprehensive income |  | -164 |  | -164 | -13 | -178
Realised gains/losses on debt instruments at fair value through other comprehensive income reclassified to the statement of profit or loss |  | -40 |  | -40 | -1 | -42
Changes in cash flow hedge reserve |  | -1,603 |  | -1,603 | -352 | -1,955
Realised and unrealised revaluations property in own use |  | -13 | 11 | -2 | 0 | -2
Remeasurement of the net defined benefit asset/liability 33 |  | 95 |  | 95 |  | 95
Exchange rate differences and other |  | 153 |  | 153 | -10 | 143
Share of other comprehensive income of associates and joint ventures and other income |  | -21 | 18 | -3 |  | -3
Change in fair value of own credit risk of financial liabilities at fair value through profit or loss |  | 37 |  | 37 |  | 37
Total amount recognised directly in other comprehensive income net of tax |  | -1,456 | 23 | -1,433 | -375 | -1,809
Net result |  | 191 | 4,579 | 4,770 | 128 | 4,898
Total comprehensive income net of tax |  | -1,265 | 4,601 | 3,336 | -247 | 3,089
Dividends |  |  | -3,125 | -3,125 | -40 | -3,165
Employee stock option and share plans |  |  | 28 | 28 |  | 28
Changes in the composition of the group and other changes |  |  |  |  | 0 | 0
Balance as at 31 December 2021 | 17,067 | 1,069 | 29,778 | 47,914 | 736 | 48,650

References relate to the accompanying notes. These are an integral part of the Consolidated financial
statements. Changes in individual Reserve components are presented in Note 19 'Equity'.

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ING Bank Annual Report 2022 137
Consolidated statement of changes in equity - continued

in EUR million | Share capital and share premium | Other reserves | Retained earnings | Shareholders' equity (parent) | Non- controlling interests | Total equity
Balance as at 31 December 2019 | 17,067 | 4,000 | 25,857 | 46,924 | 893 | 47,817
Net change in fair value of equity instruments at fair value through other comprehensive income |  | -399 | 62 | -337 | 2 | -335
Net change in fair value of debt instruments at fair value through other comprehensive income |  | 31 |  | 31 | 5 | 36
Realised gains/losses on debt instruments at fair value through other comprehensive income reclassified to the statement of profit or loss |  | -33 |  | -33 | -1 | -34
Changes in cash flow hedge reserve |  | 242 |  | 242 | 112 | 355
Realised and unrealised revaluations property in own use |  | -33 | 26 | -7 | 0 | -7
Remeasurement of the net defined benefit asset/liability 33 |  | 28 |  | 28 |  | 28
Exchange rate differences and other |  | -1,557 |  | -1,557 | -63 | -1,620
Share of other comprehensive income of associates and joint ventures and other income |  | -37 | 44 | 7 |  | 7
Change in fair value of own credit risk of financial liabilities at fair value through profit or loss |  | -3 | -16 | -19 |  | -19
Total amount recognised directly in other comprehensive income net of tax |  | -1,760 | 115 | -1,644 | 55 | -1,589
Net result |  | 94 | 2,321 | 2,415 | 78 | 2,493
Total comprehensive income net of tax |  | -1,666 | 2,436 | 770 | 133 | 904
Dividends |  |  | -43 | -43 | -3 | -46
Employee stock option and share plans |  |  | 23 | 23 | 0 | 23
Changes in the composition of the group and other changes |  |  |  |  | -1 | -1
Balance as at 31 December 2020 | 17,067 | 2,334 | 28,273 | 47,675 | 1,022 | 48,697

References relate to the accompanying notes. These are an integral part of the Consolidated financial
statements. Changes in individual Reserve components are presented in Note 19 'Equity'.

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ING Bank Annual Report 2022 138
Consolidated statement of cash flows
for the years ended 31 December

in EUR million |  | 2022 | 2021 | 2020 |  |  |  | 2022 | 2021 | 2020
Cash flows from operating activities 28 |  |  |  |  | Disposals and redemptions: | – Associates and joint ventures | 58 | 57 | 24
Result before tax |  | 5,493 | 6,774 | 3,810 |  |  | – Disposal of subsidiaries, net of cash disposed | 7 | 27 | -3
Adjusted for: | – Depreciation and amortisation | 711 | 834 | 829 |  |  | - Financial assets at fair value through other comprehensive income | 14,526 | 17,750 | 14,571
| – Addition to loan loss provisions | 1,861 | 516 | 2,675 |  |  | - Securities at amortised cost | 23,943 | 46,933 | 31,918
| – Other non-cash items in Result before tax | 5,519 | 413 | 1,259 |  |  | – Property and equipment | 83 | 39 | 75
Taxation paid |  | -1,489 | -1,871 | -1,735 |  |  | – Loans sold |  |  |
Changes in: | – Net change in Loans and advances to/from banks, not available/payable on demand | -32,813 | 8,700 | 53,076 |  |  | – Other investments | 10 | 0 | 12
| – Net change in Trading assets and Trading liabilities | 6,490 | -5,624 | 2,571 |  | Net cash flow from/(used in) investing activities | -5,307 | 6,220 | -8,487
| – Loans and advances to customers | -19,306 | -27,772 | 2,888 |  |  |  |  |  |
| – Customer deposits | 34,005 | 18,339 | 40,576 |  | Cash flows from financing activities 29 |  |  |
| – Other 28 | -3,241 | -8,179 | -2,770 |  | Proceeds from debt securities | 81,636 | 77,298 | 63,269
Net cash flow from/(used in) operating activities | -2,769 | -7,869 | 103,179 |  | Repayments of debt securities | -78,609 | -76,150 | -99,212
|  |  |  |  |  | Proceeds from issuance of subordinated loans | 983 | 3,169 | 2,138
Cash flows from investing activities |  |  |  |  | Repayments of subordinated loans | -1,090 | -2,538 | -2,608
|  |  |  |  |  | Repayments of principal portion of lease liabilities | -296 | -301 | -273
Investments and advances: | - Associates and joint ventures | -48 | -91 | -24 |  | Dividends paid |  | -6,319 | -3,165 | -46
| - Financial assets at fair value through other comprehensive income | -18,806 | -13,186 | -16,949 |  | Net cash flow from/(used in) financing activities | -3,694 | -1,686 | -36,732
| - Securities at amortised cost | -24,651 | -44,945 | -37,522 |  |  |  |  |  |
| – Property and equipment | -231 | -184 | -287 |  | Net cash flow |  | -11,770 | -3,335 | 57,960
| – Other investments | -198 | -179 | -300 |  |  |  |  |  |
|  |  |  |  |  | Cash and cash equivalents at beginning of year 30 | 107,664 | 111,565 | 54,029
|  |  |  |  |  | Effect of exchange rate changes on cash and cash equivalents | -505 | -565 | -425
|  |  |  |  |  | Cash and cash equivalents at end of year 30 | 95,390 | 107,664 | 111,565

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ING Bank Annual Report 2022 139
Consolidated statement of cash flows - continued
As at 31 December 2022, Cash and cash equivalents includes cash and balances with central banks of EUR
87,614 million (2021: EUR 106,520 million; 2020: EUR 111,087 million). Reference is made to Note 33 'Cash
and cash equivalents'.
References relate to the accompanying notes. These are an integral part of the Consolidated financial
statements.
The table below presents the Interest and dividend received and paid.

in EUR million | 2022 | 2021 | 2020
Interest received | 28,110 | 21,515 | 23,365
Interest paid | -14,201 | -8,723 | -9,690
| 13,909 | 12,792 | 13,675
Dividend received 1 | 229 | 172 | 144
Dividend paid | -6,319 | -3,165 | -46

1 Includes dividends received as recognized within Investment Income, from equity securities included in the Financial assets at fair
value through profit or loss, Financial assets at fair value through OCI, and from Investments in associates and joint ventures. Dividend
paid and received from trading positions have been included.
Dividends received from associates and joint ventures are included in investing activities, interest received,
interest paid and other dividends received are included in operating activities and dividend paid is included
in financing activities in the Consolidated statement of cash flows.

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ING Bank Annual Report 2022 140
Notes to the Consolidated financial statements
1 Basis of preparation and significant accounting policies
1.1 Reporting entity and authorisation of the Consolidated financial statements
ING Bank N.V. (Naamloze vennootschap) is a company domiciled in Amsterdam, the Netherlands.
Commercial Register of Amsterdam, number 33031431. ING Bank N.V. is a wholly-owned subsidiary of ING
Groep N.V. domiciled in Amsterdam, the Netherlands. These Consolidated financial statements, as at and for
the year ended 31 December 2022, comprise ING Bank N.V. (the Parent company) and its subsidiaries,
together referred to as ING Bank. ING Bank is a global financial institution with a strong European base,
offering a wide range of retail and wholesale banking services to customers in over 40 countries.
The ING Bank Consolidated financial statements, as at and for the year ended 31 December 2022, were
authorised for issue in accordance with a resolution of the Management Board Banking on 6 March 2023.
The General Meeting of the Shareholder may decide not to adopt the financial statements, but may not
amend these.
1.2 Basis of preparation of the Consolidated financial statements
The ING Bank Consolidated financial statements have been prepared in accordance with International
Financial Reporting Standards (IFRS) as adopted by the European Union (EU) and the relevant articles of Part
9 of Book 2 of the Dutch Civil Code.
IFRS as adopted by the EU are IFRS Standards and IFRS Interpretations as issued by the International
Accounting Standards Board (IASB) and the IFRS Interpretations Committee (IFRIC) with some limited
modifications such as the temporary ‘carve-out’ from IAS 39 ‘Financial Instruments: Recognition and
Measurement’ (herein, referred to as IFRS).
Under the EU carve-out, ING Bank applies fair value hedge accounting to portfolio hedges of interest rate risk
(macro hedging). For further information, reference is made to paragraph 1.7.4 ‘Derivatives and hedge
accounting’ of this note and to Note 36 'Derivatives and hedge accounting'.
The ING Bank Consolidated financial statements have been prepared on a going concern basis and there are
no significant doubts about the ability of ING Bank to continue as a going concern.
The Consolidated financial statements are presented in euros and rounded to the nearest million, unless
stated otherwise. Amounts may not add up due to rounding.
1.2.1 Presentation of Risk management disclosures
To improve transparency, reduce duplication and present related information in one place, certain
disclosures of the nature and extent of risks related to financial instruments required by IFRS 7 ‘Financial
instruments: Disclosures’ are included in the ‘Risk management’ section of the Annual Report.
These disclosures are an integral part of ING Bank Consolidated financial statements and are indicated in the
‘Risk management’ section by the symbol (*). Chapters, paragraphs, graphs or tables within the risk
management section that are indicated with this symbol in the respective headings or table header are
considered to be an integral part of the Consolidated financial statements.
1.3 Impact of Russian invasion in Ukraine
The war in Ukraine had, besides an immense impact on the lives of millions of people, a negative impact on
the global economy. While businesses and households were still recovering from the economic
consequences of Covid-19, developments in Ukraine further distorted supply chains, caused higher energy
costs and aggravated an already high inflation rate environment. This, in combination with central bank
rate hikes, worsened the macroeconomic outlook.
As a result of the economic effects of Russian invasion and second order effects uncertainty and level of
management judgement remains at an elevated level in 2022, particularly in the estimation of loan loss
provisions (including the need for management adjustments), the determination of fair values and
impairment assessment of an investment in an associate.
Reference is made to the notes of the financial statements as well as Risk Management chapter for further
information on the impact of the Russian invasion of Ukraine and second order impact s.
.

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> 1 Basis of preparation and significant accounting policies
ING Bank Annual Report 2022 141
1.4 Changes to accounting policies and presentation
ING Bank has consistently applied its accounting policies to all periods presented in these Consolidated
financial statements.
In 2022, ING Bank updated the presentation in note 7 ‘Loans and advances to customers’ to improve
consistency and comparability. Comparative figures for 2021 have been updated accordingly.
1.4.1 Changes in IFRS effective in 2022
The following amended standards became effective in 2022:
•Amendments to IFRS 3 ‘Business Combinations’: Reference to the Conceptual Framework (issued in May
2020).
•Amendments to IAS 16 ‘Property, Plant and Equipment’: Proceeds before Intended Use (issued in May
2020).
•Amendments to IAS 37 ‘Provisions, Contingent Liabilities and Contingent Assets’: Onerous Contracts —
Cost of Fulfilling a Contract (issued in May 2020).
•Annual improvements to IFRS Standards 2018-2020 Cycle: Amendments to IFRS 1 ‘First-time Adoption of
International Financial Reporting Standards’, amendments to IFRS 9 ‘Financial Instruments’ and
amendments to IFRS 16 ‘Leases’ (issued in May 2020).
The above changes did not have significant impact on ING Bank’s Consolidated financial statements. ING
Bank has not early adopted any standard, interpretation or amendment in 2022 which has been issued, but
is not yet effective.
1.4.2 Upcoming changes in IFRS after 2022
The following published amendments are not mandatory for 2022 and have not been early adopted by ING
Bank
Effective in 2023 (endorsed by the EU):
•IFRS 17 'Insurance Contracts' (issued in May 2017), including amendments to IFRS 17 (issued in June
2020).
IFRS 17 ‘Insurance Contracts’ is a new accounting standard for insurance contracts covering recognition and
measurement, presentation and disclosure. Once effective, IFRS 17 will replace IFRS 4 ‘Insurance Contracts’,
which allowed diversity in accounting practices for insurance contracts. In June 2020, the IASB published
amendments to IFRS 17 including a scope exclusion for credit card contracts and similar contracts that
provide insurance coverage, and an optional scope exclusion for loans with death waivers. ING does not
have an insurance business, but on a limited basis sells insurance products as a broker where it does not run
the insurance risk. ING Bank performed an impact assessment which revealed that a portfolio of loans with
death waivers in the Netherlands with a net carrying amount of approximately of EUR 750 million might be
in scope of IFRS 17. Following the above mentioned amendments to IFRS 17 in 2020 which allow an
accounting policy choice, ING Bank intends to account for assets in this portfolio in their entirety, including
death waiver features, using IFRS 9 ’Financial Instruments’ and not IFRS 17. As a result, this portfolio will no
longer meet the ‘solely payments of principal and interest’ (SPPI) criterion, causing the portfolio to no longer
be recognised at amortised cost but rather at fair value through profit or loss. This reclassification is not
expected to have a material impact on equity or result of ING Bank, as the fair value is expected not to differ
materially from the current book value. Hence, the financial impact of IFRS 17 on ING Bank is expected to be
limited.
The following amendments will also be effective in 2023. However, the implementation of these
amendments is expected to have no significant impact on NG Bank's Consolidated financial statements.
•Amendments to IAS 1 ‘Presentation of Financial Statements’: Disclosure of Accounting Policies (issued in
February 2021).
•Amendments to IAS 8 ‘Accounting Policies, Changes in Accounting Estimates and Errors’: Definition of
Accounting Estimates (issued in February 2021).
•Amendments to IAS 12 ‘Income Taxes’: Deferred Tax Related to Assets and Liabilities Arising From a
Single Transaction (issued in May 2021).
Effective in 2024 (not yet endorsed by the EU):
•Amendments to IFRS 16 'Leases': Lease Liability in a Sale and Leaseback (issued in September 2022).
•Amendments to IAS 1 ‘Presentation of Financial Statements’: Classification of Liabilities as Current or
Non-current (issued in January 2020).
1.5 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.

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> 1 Basis of preparation and significant accounting policies
ING Bank Annual Report 2022 142
ING Bank has identified areas that require management to make significant judgements and use critical
accounting estimates and assumptions based on the information and financial data that may or may not
change in future periods. These areas are:
•Loan loss provisions (financial assets);
•The determination of the fair values of financial assets and liabilities;
•Impairment assessment of an investment in associate;
•Provisions; and
•Accounting for Targeted Longer-Term Refinancing Operations (TLTRO).
For further discussion of the significant judgements and critical accounting estimates and assumptions in
these areas, reference is made to the relevant parts in paragraph 1.7 ‘Financial instruments’ (specifically
1.7.8 ‘Impairment of financial assets’, 1.7.3 for ‘Fair values of financial assets and liabilities’, 1.11
‘Investments in associates and joint ventures’, 1.18 ‘Provisions, contingent liabilities and contingent assets’
and 1.7.9 ‘Accounting for Targeted Longer-Term Refinancing Operations (TLTRO)’) of this note and the
applicable notes to the Consolidated financial statements.
1.6 Other developments
Application of IAS 29 ‘Financial Reporting in Hyperinflationary Economies’
During the second quarter of 2022 Turkey became a hyperinflationary economy for accounting purposes.
As ING Bank has a subsidiary in Turkey, ING Bank applied IAS 29 ‘Financial Reporting in Hyperinflationary
Economies’ to its operations as if the economy in Turkey had always been hyperinflationary. Given that ING
Bank presents its results in EUR, comparatives were not restated and IAS 29 was applied from 1 January
2022 with the impact of the first-time application and the effect for the period both shown in these
Consolidated financial statements for the year ended 31 December 2022.
Under IAS 29, the results of the operations in Turkey 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 development of the CPI during the year ended 31 December 2022 was as follows (2003=100):
1 January 2022 686.95
31 December 2022 1,128.45
Change for the period 64.27%
To state all the items in the financial statements in terms of their current purchasing power at the reporting
date, ING Bank restated the non-monetary items of ING Turkey (such as properties and equipment,
intangibles, right-of use assets and shareholder’s equity) for the changes in CPI up to the reporting date.
Monetary items (such as cash and balances with banks, loans and advances and deposits) are not restated
as they are already expressed in the current purchasing power. Furthermore, all items in the statement of
comprehensive income were also restated for the effects of inflation based on the developments in CPI
during the 12 month period to reflect the purchasing power as at 31 December 2022.
The effect of such restatement of the statement of comprehensive income and the balance sheet for
inflation in the current period 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
Turkey.
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 Turkey are translated and presented in EUR at the exchange rate on 31
December 2022. For the statement of comprehensive income this is in contrast with the usual translation
procedures where items of comprehensive income are translated at the exchange rate at the date of
transaction. Furthermore, ING Bank selected to present both the restatement effect resulting from restating
ING Bank’s interest in the equity of ING Turkey 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.
Refer to Note 19 ‘Equity’ for the impact of applying IAS 29 during the year ended 31 December 2022.
1.7 Financial instruments
ING Bank applies IFRS 9 ‘Financial Instruments’ to the recognition, classification and measurement, and
derecognition of financial assets and financial liabilities and the impairment of financial assets. The Group
applies the requirements of IAS 39 ‘Financial Instruments: Recognition and Measurement’ for hedge
accounting purposes.
1.7.1 Recognition and derecognition of financial instruments
Recognition of financial assets
Financial assets are recognised in the balance sheet when ING Bank becomes a party to the contractual
provisions of the instrument. For a regular way purchase or sale of a financial asset, trade date and
settlement date accounting is applied depending on the classification of the financial asset.
Derecognition of financial assets
Financial assets are derecognised when the rights to receive cash flows from the financial assets have
expired or where ING Bank has transferred the rights to receive the cash flows from the financial asset or
assumed an obligation to pass on the cash flows and has transferred substantially all the risks and rewards

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> 1 Basis of preparation and significant accounting policies
ING Bank Annual Report 2022 143
of the asset. If ING Bank neither transfers nor retains substantially all the risks and rewards of ownership of a
financial asset, it derecognises the financial asset if it no longer has control over the asset. The difference
between the carrying amount of a financial asset that has been derecognised and the consideration
received is recognised in profit or loss.
Recognition of financial liabilities
Financial liabilities are recognised on the date that the entity becomes a party to the contractual provisions
of the instrument.
Derecognition of financial liabilities
Financial liabilities are derecognised when the obligation specified in the contract is discharged, cancelled or
expired. The difference between the carrying amount of a financial liability that has been extinguished and
the consideration paid is recognised in profit or loss.
1.7.2 Classification and measurement of financial instruments
Financial assets
ING Bank classifies its financial assets in the following measurement categories:
•those to be measured subsequently at fair value (either through OCI, or through profit or loss); and
•those to be measured at amortised cost (AC).
At initial recognition, ING Bank measures a financial asset at its fair value plus, in the case of a financial
asset not at FVPL, transaction costs that are directly attributable to the acquisition of the financial asset.
Transaction costs of financial assets carried at fair value through profit or loss (FVPL) are expensed in the
statement of profit or loss.
Financial assets - Debt instruments
The classification depends on the entity’s business model for managing the financial assets and the
contractual terms of the cash flows at initial recognition.
Business models
Business models are classified as Hold to Collect (HtC), Hold to Collect and Sell (HtC&S) or Other depending
on how a portfolio of financial instruments as a whole is managed. ING Bank’s business models are based on
the existing management structure of the bank, and refined based on an analysis of how businesses are
evaluated and reported, how their specific business risks are managed and on historic and expected future
sales. Sales are permissible in a HtC business model when these are due to an increase in credit risk, take
place close to the maturity date (where the proceeds from the sales approximate the collection of the
remaining contractual cash flows), are insignificant in value (both individually and in aggregate) or are
infrequent.
Contractual cash flows Solely Payments of Principal and Interest (SPPI)
The contractual cash flows of a financial asset are assessed to determine whether they represent SPPI.
Interest includes consideration for the time value of money, credit risk and for other basic lending risks such
as consideration for liquidity risk and costs associated with holding the financial asset for a particular period
of time. In addition, interest can include a profit margin that is consistent with a basic lending arrangement.
Financial assets with embedded derivatives are considered in their entirety when determining whether their
cash flows are SPPI.
In assessing whether the contractual cash flows are SPPI, ING Bank considers the contractual terms of the
instrument. This includes assessing whether the financial asset contains a contractual term that could
change the timing or amount of contractual cash flows such that it would not meet this condition.
Based on the entity’s business model for managing the financial assets and the contractual terms of the
cash flows, there are three measurement categories into which ING Bank classifies its debt instruments:
•Amortised Cost (AC):
Debt instruments that are held for collection of contractual cash flows under a HtC business model where
those cash flows represent SPPI are measured at AC. Interest income from these financial assets is
included in Interest income using the Effective Interest Rate (EIR) method. Any gain or loss arising on
derecognition is recognised directly in profit or loss. Impairment losses are presented as a separate line
item in the statement of profit or loss.
•FVOCI:
Debt instruments that are held for collection of contractual cash flows and for selling the financial assets
under a HtC&S business model, where the assets’ cash flows represent SPPI, are measured at FVOCI.
Movements in the carrying amount are recognised in OCI, except for the recognition of impairment gains
or losses, interest revenue and foreign exchange gains and losses which are recognised in profit or loss.
When the financial asset is derecognised, the cumulative gain or loss previously recognised in OCI is
reclassified from equity to profit or loss and presented in Investment income or Other net income, based
on the specific characteristics of the business model. Interest income from these financial assets is
included in Interest income using the EIR method. Impairment losses are presented as a separate line
item in the statement of profit or loss.
•FVPL:
Debt instruments that do not meet the criteria for AC or FVOCI are measured at FVPL. This includes debt
instruments that are held-for-trading (presented separately as Trading assets) and all other debt
instruments that do not meet the criteria for AC or FVOCI (presented separately as Mandatorily at FVPL).

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> 1 Basis of preparation and significant accounting policies
ING Bank Annual Report 2022 144
ING Bank may in some cases, on initial recognition, irrevocably designate a financial asset as classified
and measured at FVPL. This is the case where doing so eliminates or significantly reduces an accounting
mismatch that would otherwise arise on assets measured at AC or FVOCI. Fair value movements on
trading securities, trading loans and deposits (mainly reverse repo’s) 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 Interest income or 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
Interest income or Interest expense in the period in which it arises.
ING Bank reclassifies debt instruments if, and only if, its business model for managing those financial assets
changes. Such changes in business models are expected to be very infrequent. There have been no
reclassifications during the reporting period.
Financial assets - Equity instruments
All equity investments are measured at fair value. ING Bank applies the fair value through OCI option to
investments which are considered strategic, consisting of investments that add value to ING Bank’s core
banking activities.
There is no subsequent recycling of fair value gains and losses to profit or loss following the derecognition of
investments if elected to be classified and measured as FVOCI. However, the cumulative gain or loss is
transferred within equity to retained earnings on derecognition of such equity instruments. Dividends from
such investments continue to be recognised in profit or loss as Investment income when ING’s right to
receive payments is established. Impairment requirements are not applicable to equity investments
classified and measured as FVOCI.
Other remaining equity investments are measured at FVPL. All changes in the fair value are recognised in
Valuation result and Net trading income in the Consolidated statement of profit or loss.
Financial liabilities
Financial liabilities are classified and subsequently measured at AC, except for financial guarantee contracts,
derivatives and liabilities designated at FVPL. Financial liabilities classified and measured at FVPL are
presented as follows:
•the amount of change in the fair value that is attributable to changes in own credit risk of the liability
designated at FVPL is presented in OCI. Upon derecognition this Debit Valuation Adjustment (DVA) impact
does not recycle from OCI to profit or loss; and
•the remaining amount of change in the fair value is presented in profit or loss in ‘Valuation results and
net trading income’. Interest on financial liabilities at FVPL is also recognised in the valuation result,
except for items voluntarily designated as FVPL for which interest is presented within ‘Interest income
(expense).
A financial guarantee contract is a contract that requires ING Bank to make specified payments to
reimburse the holder for a loss it incurs because a specified debtor fails to make payment when due in
accordance with the original or modified terms of a debt instrument. Such a contract is initially recognised
at fair value and is subsequently measured at the higher of (a) the amount determined in accordance with
impairment provisions of IFRS 9 ‘Financial instruments’ (see section “Impairment of financial assets”) and (b)
the amount initially recognised less, when appropriate, cumulative amortisation recognised in accordance
with the revenue recognition principle of IFRS 15 ‘Revenue from contracts with customers’.
1.7.3 Fair values of financial assets and liabilities
All financial assets and liabilities are recognised initially at fair value. The fair value of a financial instrument
on initial recognition is generally its transaction price (that is, the fair value of the consideration given or
received). However, if there is a material difference between the transaction price and the fair value of
financial instruments whose fair value is based on a valuation technique using significant unobservable
inputs, the entire day one difference (a ‘Day One Profit or Loss’) is deferred. ING Bank defers the Day One
Profit or Loss relating to financial instruments classified as Level 3 and financial instruments with material
unobservable inputs into CVA which are not necessarily classified as Level 3. The deferred Day One Profit or
Loss is recognised in the statement of profit or loss over the life of the transaction until the transaction
matures, or until the significant unobservable inputs become observable, or until the significant
unobservable inputs become non-significant. In all other cases, ING Bank recognises the difference as a gain
or loss at inception.
Subsequently, except for financial assets and financial liabilities measured at amortised cost, all the other
financial assets and liabilities are measured at fair value.
Fair value is defined as the price that would be received to sell an asset or paid to transfer a liability in an
orderly transaction between market participants at the measurement date. It assumes that market
participants would use and take into account the characteristics of the asset or liability when pricing the
asset or liability. Fair values of financial assets and liabilities are based on unadjusted quoted market prices
where available. Such quoted market prices are primarily obtained from exchange prices for listed financial
instruments. Where an exchange price is not available, quoted prices in an active market may be obtained
from independent market vendors, brokers, or market makers. In general, positions are valued at the bid
price for a long position and at the offer price for a short position or are valued at the price within the bid-
offer spread that is most representative of fair value in the circumstances. In some cases where positions
are marked at mid-market prices, a fair value adjustment is calculated.

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> 1 Basis of preparation and significant accounting policies
ING Bank Annual Report 2022 145
For certain financial assets and liabilities, quoted market prices are not available. For such instruments, fair
value is determined using valuation techniques. These range from discounting of cash flows to various
valuation models, where relevant pricing factors including the market price of underlying reference
instruments, market parameters (volatilities, correlations and credit ratings), and customer behaviour are
taken into account. ING Bank maximises the use of market observable inputs and minimises the use of
unobservable inputs in determining the fair value. It can be subjective dependent on the significance of the
unobservable input to the overall valuation. All valuation techniques used are subject to internal review and
approval. Most data used in these valuation techniques are validated on a daily basis when possible.
When a group of financial assets and liabilities are managed on the basis of their net risk exposures, the fair
value of a group of financial assets and liabilities are measured on a net portfolio level.
To include credit risk in fair value, ING Bank applies both Credit and Debit Valuation Adjustments (CVA, DVA,
also known as Bilateral Valuation Adjustments or BVA). Own issued debt and structured notes that are
designated at FVPL are adjusted for ING Bank’s own credit risk by means of a DVA. Additionally, derivatives
valued at fair value are adjusted for credit risk by a BVA. The BVA is of a bilateral nature as both the credit
risk on the counterparty (CVA) as well as the credit risk on ING Bank (DVA) are included in the adjustment. All
input data that is used in the determination of the BVA is based on market implied data. Additionally,
wrong-way risk (when exposure to a counterparty is increasing and the credit quality of that counterparty
deteriorates) and right-way risk (when exposure to a counterparty is increasing and the credit quality of
that counterparty improves) are taken into account in the measurement of the valuation adjustment.
To include the funding risk, ING Bank applies an additional ‘Funding Valuation Adjustment’ (FVA) to the
uncollateralised derivatives based on the market price of funding liquidity. ING Bank also applies to certain
positions other valuation adjustments to arrive at the fair value: 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 Bank categorises its financial instruments that are either measured in the statement of financial position at fair value or of which the fair value is disclosed, into a three level hierarchy based on the observability and significance of the valuation inputs. The use of different approaches to assess whether a market is active, whether an input is observable, and whether an unobservable input is significant could produce different classification within the fair value hierarchy as well as potentially different deferral of the Day One Profit or Loss. •Reference is made to Note 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.

1.7.4 Derivatives and hedge accounting
IFRS 9 includes an accounting policy choice to defer the adoption of IFRS 9 hedge accounting and to
continue with hedge accounting under IAS 39. ING Bank decided to exercise this accounting policy choice
and did not adopt IFRS 9 hedge accounting as of 1 January 2018. Furthermore, ING Bank applies fair value
hedge accounting for portfolio hedges of interest rate risk (macro fair value hedges) in accordance with the
EU carve-out version of IAS 39.
Derivatives are initially recognised at fair value on the date on which a derivative contract is entered into
and are subsequently measured at fair value. Fair values are obtained from quoted market prices in active
markets, including market transactions and valuation techniques (such as discounted cash flow models and
option pricing models), as appropriate. All derivatives are carried as assets when their fair value is positive
and as liabilities when their fair value is negative. Fair value movements on derivatives are presented in
profit or loss in Valuation result and net trading income, except for derivatives in either a formal hedge
relationship and so-called economic hedges that are not in a formal hedge accounting relationship where a
component is presented separately in interest result in line with ING Bank’s risk management strategy.

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> 1 Basis of preparation and significant accounting policies
ING Bank Annual Report 2022 146
Embedded derivatives are separated from financial liabilities and other non-financial contracts and
accounted for as a derivative if, and only if:
1.the economic characteristics and risks of the embedded derivative are not closely related to the
economic characteristics and risks of the host contract;
2.a separate instrument with the same terms as the embedded derivative would meet the definition of a
derivative; and
3.the combined instrument is not measured at fair value with changes in fair value reported in profit or
loss.
If an embedded derivative is separated, the host contract is accounted for as a similar free-standing
contract.
The method of recognising the resulting fair value gain or loss depends on whether the derivative is
designated as a hedging instrument, and if so, the nature of the item being hedged. ING Bank designates
certain derivatives as hedges of the fair value of recognised assets or liabilities or firm commitments (fair
value hedge), hedges of highly probable future cash flows attributable to a recognised asset or liability or a
forecast transaction (cash flow hedge), or hedges of a net investment in a foreign operation. Hedge
accounting is used for derivatives designated in this way provided certain criteria are met.
At the inception of the transaction ING Bank documents the relationship between hedging instruments and
hedged items, its risk management objective, together with the methods selected to assess hedge
effectiveness. ING Bank also documents its assessment, both at hedge inception and on an ongoing basis, of
whether the derivatives that are used in hedging transactions are highly effective in offsetting changes in
fair values or cash flows of the hedged items.
Fair value hedges
Changes in the fair value of derivatives that are designated and qualify as fair value hedges are recognised
in the statement of profit or loss, together with fair value adjustments to the hedged item attributable to
the hedged risk. If the hedge relationship no longer meets the criteria for hedge accounting, the cumulative
adjustment of the hedged item is, in the case of interest bearing instruments, amortised through the
statement of profit or loss over the remaining term of the original hedge or recognised directly when the
hedged item is derecognised. For non-interest bearing instruments, the cumulative adjustment of the
hedged item is recognised in the statement of profit or loss only when the hedged item is derecognised.
Cash flow hedges
The effective portion of changes in the fair value of derivatives that are designated and qualify as cash flow
hedges are recognised in the Other Comprehensive Income. The gain or loss relating to the ineffective
portion is 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.
IBOR Transition - specific policies applicable from 1 January 2019 for hedges directly
affected by IBOR reform
As further explained in the ‘IBOR Transition’ paragraph of the ‘Risk management’ section, the financial
markets are going through a significant reform of interbank offered rates (IBOR) and financial institutions
are obligated to implement a replacement of major interest rate reference rates.
Given that IBOR reform may have various accounting implications, the International Accounting Standards
Board (IASB) has undertaken a two phase project. Phase 1 addresses those issues that affect financial
reporting before the replacement of an existing benchmark. Phase 1 amendments to IFRS were issued by
the IASB in 2019. Phase 2 focuses on issues that may affect financial reporting when the existing benchmark
rate is reformed or replaced. Phase 2 amendments to IFRS were issued by the IASB in 2020.
Phase 1 amendments to IFRS allow ING Bank to apply a set of temporary exceptions to continue hedge
accounting even when there is uncertainty about contractual cash flows arising from the reform. Under
these temporary exceptions, interbank offered rates are assumed to continue unaltered for the purposes of
hedge accounting until such time as the uncertainty is resolved.
More specifically, the following temporary reliefs are part of the Phase 1 amendments:
•Highly probable requirement for cash flow hedges
When determining whether a forecast transaction is highly probable, it is assumed that the interest rate
benchmark on which the hedged cash flows are based is not altered as a result of the reform.

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> 1 Basis of preparation and significant accounting policies
ING Bank Annual Report 2022 147
•Prospective assessment of hedge effectiveness
When performing the prospective assessment it is assumed that the interest rate benchmark on which
the hedged cash flows are based is not altered as a result of the reform.
•Retrospective assessment of hedge effectiveness
When performing the retrospective assessment hedges are allowed to pass the assessment even if
actual results are outside the 80-125% range, during the period of uncertainty arising from the IBOR
reform.
•Designation of a component of an item as a hedged item
For hedges of the benchmark component of interest rate risk affected by the reform, the separately
identifiable requirement only needs to be demonstrated at the inception of such hedging relationships
(including macro hedges).
The amendments are relevant given that ING Bank hedges and applies hedge accounting to benchmark
interest rate exposure part of IBOR reform. ING Bank hedges are being progressively amended, where
necessary, to incorporate the new benchmark rates. Temporary exceptions under Phase 1 continued to be
relevant for ING Bank as at 31 December 2022 (for USD and WIBOR).
ING Bank will completely cease to apply the amendments when this uncertainty is no longer present or
when the hedging relationship is discontinued. Refer to Note 36 'Derivatives and hedge accounting' for the
disclosures relating to the application of the amendments as part of Phase 1. Refer to note ‘Risk
management/ IBOR Transition’ for more information regarding the end of Phase 1 reliefs for ING Bank’s
hedging relationships.
Phase 2 amendments require that hedge accounting continues on transition to risk free rates provided that
the modifications made to financial instruments are those necessary to implement the IBOR Reform and
that the new basis for calculating cash flows is ‘economically equivalent’ to the previous basis. Particularly,
Phase 2 amendments allow the continuation of hedging relationships, subject to amending their
documentation to reflect changes in hedged instruments, hedging instruments, hedged risk, and/or the
method for measuring effectiveness during the transition to the new benchmark rates. During 2022, Phase 2
continued to be relevant for ING Bank when ING actually transitioned its financial instruments (designated in
hedge accounting relationships) to the new benchmark rates (mainly, USD LIBOR).
More specifically, the following temporary reliefs are part of the Phase 2 amendments:
Relief from discontinuing hedging relationships
•Amendments in the hedge documentation as a consequence of changes required by the IBOR reform do
not result in the discontinuation of the hedge relationship nor the designation of a new hedge
relationship. The changes can be in form of designating an alternative benchmark rate as a hedged risk,
the description of the hedging instrument, the description of the hedged item, or the method to measure
the effectiveness.
•When the hedged item is amended as a consequence of the IBOR reform (or if the hedge has previously
been discontinued), amounts accumulated in the cash flow hedge reserve are deemed to be based on
the Risk-Free Rate (RFR). This results in the release of the cash flow hedge reserve to profit or loss in the
same period or periods in which the hedged cash flows that are now based on the RFR affect profit or
loss.
•When the items within a designated group of hedged items are amended as a consequence of the IBOR
reform, the hedging strategy remains and is not discontinued. As items within the hedged group
transition at different times from IBORs to RFRs, they are transferred to sub-groups of instruments that
reference RFRs as the hedged risk. The existing IBORs remain designated as the hedged risk for the other
sub-group of hedged items, until they are also updated to reference the new RFR. The usual hedge
accounting requirements are applied to the hedge relationship in its entirety.
•For the assessment of retrospective hedge effectiveness, the cumulative fair value changes may be reset
to zero when the exception to the retrospective assessment of the Phase 1 reliefs ends. This election is
made separately for each hedging relationship (i.e., on a hedge-by-hedge basis).
•Temporary relief from having to meet the separately identifiable requirement: a RFR is considered a
separately identifiable risk component if it is reasonably expected to meet the separately identifiable
requirement within 24 months from the date it is first designated as a non-contractually specified risk
component (i.e. when the entity first designates the RFR as a non-contractually specified risk
component). This relief applies to each RFR on a rate-by-rate basis.
Non-trading derivatives that do not qualify for hedge accounting
Derivative instruments that are used by ING Bank as part of its risk management strategies, but which do
not qualify for hedge accounting under ING Bank’s accounting policies, are presented as non-trading
derivatives. Non-trading derivatives are measured at fair value with changes in the fair value taken to the
statement of profit or loss.
1.7.5 Offsetting of financial assets and financial liabilities
Financial assets and financial liabilities are offset, and the net amount is reported in the statement of
financial position when ING Bank has a current legally enforceable right to set off the recognised amounts
and intends to either settle on a net basis or to realise the asset and settle the liability simultaneously.
Offsetting is applied to certain interest rate swaps for which the services of a central clearing house are
used.
1.7.6 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. The counterparty liability is

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> 1 Basis of preparation and significant accounting policies
ING Bank Annual Report 2022 148
measured at FVPL (designated) and included in Other financial liabilities at FVPL if the asset is measured at
FVPL. Otherwise, the counterparty liability is included in Deposits from banks, Customer deposits, or Trading,
as appropriate.
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the Consolidated statement of financial position. The consideration paid
to purchase securities is recognised as Loans and advances to customers, Loans and advances to banks,
Other financial assets at FVPL or Trading assets, as appropriate. The difference between the sale and
repurchase price is treated as interest and amortised over the life of the agreement using the effective
interest method for instruments that are not measured at FVPL.
1.7.7 Credit risk management classification and maximum credit risk exposure
C redit risk management disclosures are provided in the ‘Credit risk’ paragraph ‘Credit risk categories’ of the
‘Risk management’ section in the Annual Report.
The maximum credit risk exposure for items in the statement of financial position is generally the carrying
value for the relevant financial assets. For the off-balance sheet items, the maximum credit exposure is the
maximum amount that could be required to be paid. Reference is made to Note 41 ‘Contingent liabilities
and commitments’ for these off-balance sheet items. Collateral received is not taken into account when
determining the maximum credit risk exposure.
Credit risk management disclosures are provided in the ‘Credit risk’ paragraph ‘Credit risk categories’ of the
‘Risk management’ section in the Annual Report. The manner in which ING Bank manages credit risk and
determines credit risk exposures for that purpose is explained in the Credit risk paragraph ‘Credit Risk
Appetite and Concentration Risk Framework’ of the ‘Risk management’ section in the Annual Report.
1.7.8 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 Bank calculates the expected credit losses (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. ING Bank’s approach leverages the Advanced Internal Ratings Based (AIRB)
models that are used for regulatory purposes. Adjustments are applied to make these models suitable for
determining ECL. 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 Bank established a framework, incorporating quantitative and qualitative indicators, to identify and
assess significant increases in credit risk (SICR). This is used to determine the appropriate ECL Stage for each
financial asset.
The main determinate of SICR is a quantitative test, whereby the lifetime Probability of Default (PD) of an
asset at each reporting date is compared against its lifetime PD determined at the date of initial recognition.
If the delta is above pre-defined absolute or relative thresholds the item is considered to have experienced a
SICR. Furthermore, any facility which shows an increase of 200% 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. Refer to ‘Criteria for
identifying a significant increase in credit risk’ in the ‘Risk Management’ section of the Annual Report for
more details on relative and absolute PD thresholds, including quantitative disclosures on those thresholds.
Consequently, if the above quantitative SICR thresholds are exceeded, the item moves from Stage 1 to Stage
2 (unless the item is credit-impaired). In these instances, items are no longer assigned a 12 month ECL and
instead are assigned a lifetime ECL. Items can return to Stage 1 if there is sufficient evidence that there is no
longer a significant increase in credit risk.
ING Bank also relies on a number of qualitative indicators to identify and assess SICR. These include:

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ING Bank Annual Report 2022 149
•Forbearance status;
•Watch List status;
•Intensive care management;
•Collective SICR assessment;
•Substandard Internal rating; and
•Arrears status (including 30 days past due used as a backstop).
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 30 days past due trigger, then the
asset is moved back to Stage 1 only after three months from when the trigger no longer applies.
Credit-impaired financial assets (Stage 3)
Financial assets are assessed for credit-impairment at each reporting date and more frequently when
circumstances warrant further assessment. Evidence of credit-impairment includes arrears of over 90 days
on any material credit obligation, indications that the borrower is experiencing significant financial difficulty,
a breach of contract, bankruptcy or distressed restructuring. The definition of credit-impaired under IFRS 9
(Stage 3) is aligned with the definition of default used by ING Bank for internal risk management purposes,
which is also the definition used for regulatory purposes.
An asset (other than a POCI asset) that is in Stage 3 will move back to Stage 2 when, as at the reporting
date, it is no longer considered to be credit-impaired subject to certain probation periods. The asset will
migrate back to Stage 1 when its credit risk at the reporting date is no longer considered to have increased
significantly since initial recognition.
Macroeconomic scenarios
ING Bank has established a quarterly process whereby forward-looking macroeconomics scenarios and
probability weightings are developed for the purpose of ECL. ING Bank applies data predominantly from a
leading service provider (Oxford Economics (OE)) enriched with the internal ING Bank view. A baseline, up-
scenario and a down-scenario are determined to reflect an unbiased and probability-weighted ECL amount.
As a baseline scenario, ING Bank applies the market-neutral view combining consensus forecasts for
economic variables such as unemployment rates, GDP growth, house prices, commodity prices, and short-
term interest rates. Applying market consensus in the baseline scenario ensures unbiased estimates of the
expected credit losses.
The alternative scenarios are based on observed forecast errors in the past, adjusted for the risks affecting
the economy today and the forecast horizon. The probabilities assigned are based on the likelihoods of
observing the three scenarios and are derived from confidence intervals on a probability distribution. The
forecasts for the economic variables are adjusted on a quarterly basis.
Measurement of ECL
ING Bank applies a collective assessment method to measure ECL for Stage 1, Stage 2, and certain Stage 3
assets. Other credit-impaired assets subject to ECL measurement apply the individual assessment method.
Collectively assessed assets (Stages 1 to 3)
For collective assessed assets, ING Bank applies a model-based approach. ECL is determined by, expressed
simplistically, multiplying the probability of default (PD) with the loss given default (LGD) and exposure at
default (EAD), adjusted for the time value of money. Assets that are collectively assessed are grouped on
the basis of similar credit risk characteristics, taking into account 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 purpose of ECL, ING Bank’s expected credit loss models (PD, LGD, EAD) used for regulatory purposes
have been adjusted. These adjustments include removing embedded prudential conservatism (such as
floors) and converted through-the-cycle estimates to point-in-time estimates. The models assess ECL on the
basis of forward-looking macroeconomic forecasts and other inputs. For most financial assets, the expected
life is limited to the remaining maturity. For overdrafts and certain revolving credit facilities, such as credit
cards, the maturity is estimated based on historical data as these do not have a fixed term or repayment
schedule.
Individually assessed assets (Stage 3)
ING Bank estimates ECL for individually significant credit-impaired financial assets within Stage 3 on an
individual basis. ECL for these Individually assessed assets are determined using the discounted expected
future cash flow method. To determine expected future cash flows, one or more scenarios are used. Each
scenario is analysed based on the probability of occurrence and includes forward looking information.
In determining the scenarios, all relevant factors impacting the future cash flows are taken into account.
These include expected developments in credit quality, business and economic forecasts, and estimates of
if/when recoveries will occur taking into account ING Bank’s restructuring/recovery strategy.

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> 1 Basis of preparation and significant accounting policies
ING Bank Annual Report 2022 150
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 others, 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 is no longer recognised based on the accrual income
based on the gross carrying amount of the asset. Rather, interest income is calculated by applying the
original EIR to the AC 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 even if the lifetime ECL at the reporting date is lower than the estimated lifetime ECL at
origination.
Modifications
In certain circumstances ING Bank grants borrowers postponement, reduction of loan principal and/or
interest payments on a temporary period of time to maximise collection opportunities, and if possible, avoid
default, foreclosure, or repossession. When such postponement, reduction of loan principal and/or interest
payments is executed based on credit concerns it is also referred to as forbearance (refer to the ‘Risk
Management’ section of the Annual Report for more details). In such cases, the net present value of the
postponement, reduction of loan principal and/or interest payments is taken into account in the
determination of the appropriate level of ECL. If the forbearance 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. ING Bank determines whether there has been a substantial modification using both
quantitative and qualitative factors.
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;
•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 additionally involves the forgiveness of a legal
obligation, in whole or in part. This means that ING Bank forfeits the legal right to recover the debt. As a
result, the financial asset needs to be derecognised. Distinction is made in situations where ING Bank ends
the relationship with the client and situations where ING Bank (partially) continues the financing of the
client.
Presentation of ECL
ECL for financial assets measured at AC are deducted from the gross carrying amount of the assets. For
debt instruments at FVOCI, the ECL is recognised in OCI, instead of deducted 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, are recognised as liabilities and presented in Other provisions.
ECL are presented in profit or loss in Addition to loan loss provision.

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Significant judgements and critical accounting estimates and assumptions: Considerable management judgement is exercised in determining the amount of ECL for financial assets assessed on both a collective and an individual basis. In particular, this judgement requires ING Bank to make various assumptions about the risk of default, the credit loss rates in case of a default and expected future cash flows. These assumptions are based on a combination of ING Bank’s past history, existing market conditions and forward-looking estimates at the end of each reporting period. Changes in these assumptions may lead to changes in the ECL over time. Given they are subjective and complex in nature, and because the ECL and the underlying exposures subject to ECL are material, these assumptions are considered critical accounting assumptions. The sensitivity of these assumptions is assessed in the credit risk section of the ‘Risk Management’ section in the Annual Report. •The use of forward-looking macroeconomic scenarios in both collective and individual impairment assessments Forward-looking macroeconomic scenarios are uncertain in nature. The process ING Bank follows involves two internal groups, the Macroeconomics Scenarios Team and the Macroeconomics Scenarios Expert Panel. The latter team consists of senior management representatives from the Business, Risk and Finance. These groups review inputs obtained from a third party provider and subject these to internal expert challenge to ensure the inputs used in the models reflect ING Bank’s view on the macro economy. 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. •The probability weights applied to each of the three scenarios ING Bank uses three macroeconomic scenarios when determining IFRS 9 ECL (baseline, upside and downside). Management judgement is applied in the design of the approach used to determine the weights of each scenario and in selecting the parts of the distribution of forecast errors from which the weights are derived. Reference is made to the ‘Alternative scenarios and probability weights’ and the sensitivity analysis in the ‘Risk Management’ section of the Annual Report for further details.

•The criteria for identifying a significant increase in credit risk When determining whether the credit risk on a financial asset has increased significantly, ING Bank considers reasonable and supportable information to compare the risk of default occurring at reporting date with the risk of a default occurring at initial recognition of the financial asset. Whilst judgement is required in applying a PD rating to each financial asset, there is significant judgement used in determining the Stage allocation PD banding thresholds. The process of comparing a financial asset’s PD with the PD banding thresholds determines its ECL Stage. Assets in Stage 1 are allocated a 12 month ECL, and those in Stage 2 are allocated a lifetime ECL, and the difference is often significant. As such, the judgement made in assigning financial asset PDs and the PD banding thresholds constitute a significant judgement. Analysis of the sensitivity associated with the assessment of significant increase in credit risk is presented in the ‘Risk Management’ section of the Annual Report. •The definition of default Judgement is exercised in management’s evaluation of whether there is objective evidence that larger exposures are credit-impaired. Management judgement is required in assessing evidence of credit- impairment. •Management adjustments applied as at 31 December 2022 To reflect the risks that are not properly captured by the ECL models, a number of management adjustments to the model-based ECL were necessary as at 31 December 2022. Reference is made to the ‘Management adjustments applied this year’ paragraph in the ‘Risk management’ section of the Annual Report.

1.7.9 Accounting for Targeted Longer-Term Refinancing Operations (TLTRO)
ING Bank participates in Targeted Longer-Term Refinancing Operations (TLTRO III), reference is made to Note
12 ‘Deposits from banks’.
ING Bank considers 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 is considered to be a market conforming rate and TLTRO funding is
recognized fully as a financial liability.
ING Bank interprets 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 results in discrete rates for discrete interest

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periods over the life of TLTRO. The change in the applicable rate between interest periods is seen as a
change in the floating rate and is accounted for prospectively. Similarly, if the ECB announces changes in
the rate for the amounts already drawn under the existing TLTRO, then such changes also represent a
change in a floating rate. Following this, such changes lead 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 relates to the
periods already passed, the impact for those past periods is recognised in profit or loss immediately.
Furthermore, the change in the TLTRO rate driven by changes in expectations of meeting the targets
impacts interest income. As a result, interest income which relates to the period that already passed until
the moment when the change in expectations occurs, is recognised as a catch up adjustment in
Consolidated statement of profit or loss. This change occurs only when ING Bank has a reasonable
expectation that the lending targets will be met.
ING Bank views ‘reasonable expectation’ in case of TLTRO funding as a high hurdle. This is the moment when
it becomes highly probable, i.e. the probability of meeting the lending targets is substantially greater than
the probability that it will not. As a result, if interest income is recognised during the period based on the
expectation of meeting the targets, there should only be a limited possibility that the interest may need to
be reversed in future reporting periods. Reference is made to note 12 ‘Deposits from banks’ and to note 20
‘Net interest income’ for the presentation of ING Bank’s participation in TLTRO programmes.

Significant judgements: Significant management judgement is exercised in determining the accounting treatment of TLTRO transactions. In particular, ING Bank applied judgement in: •assessing and concluding that in ING Bank'’s view the rate under TLTRO is considered to be a market conforming rate and, hence, accounting for TLTRO in accordance with IFRS 9; and •selecting accounting policies regarding the calculation of the effective interest rate under TLTRO. Treatment of changes in expectations of meeting the lending targets was an area of significant judgment in the comparative periods but no longer relevant in 2022.

1.8 Consolidation
ING Bank comprises ING Bank N.V. (the Parent Company) and all other subsidiaries. Subsidiaries are entities
controlled by ING Bank N.V. Control exists if ING Bank N.V. is exposed or has rights to variable returns and
has the ability to affect those returns through the power over the subsidiary. Control is usually achieved
through situations including, but not limited to:
•Ownership, directly or indirectly, of more than half of the voting power;
•Ability to appoint or remove the majority of the board of directors;
•Power to govern operating and financial policies under statute or agreement; and
•Power over more than half of the voting rights through an agreement with other investors.
The existence and effect of potential voting rights that are currently exercisable or convertible are
considered in assessing whether ING Bank controls another entity.
For interests in structured entities, the existence of control requires judgement as these entities are
designed so that voting or similar rights are not the dominant factor in deciding who controls the entity. This
judgement includes, for example, the involvement in the design of the structured entity, contractual
arrangements that give rights to direct the structured entities relevant activities and commitment to ensure
that the structured entity operates as designed.
A list of principal subsidiaries is included in Note 44 ‘Principal subsidiaries’ and a description of ING's activities
involving structured entities is included in Note 45 '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.
The results of the operations and the net assets of subsidiaries are included in the statement of profit or loss
and the statement of financial position from the date control is obtained until the date control is lost. On
disposal, the difference between the sales proceeds, net of directly attributable transaction costs, and the
net assets is included in net result.
A subsidiary which ING Bank has agreed to sell but is still legally owned by ING Bank may still be controlled
by ING Bank at the balance sheet date and therefore, still be included in the consolidation. Such a subsidiary
may be presented as a held for sale disposal group if certain conditions are met.
All intercompany transactions, balances and unrealised surpluses and deficits on transactions between
group companies are eliminated. Where necessary, the accounting policies used by subsidiaries are
changed to ensure consistency with group policies. In general, the reporting dates of subsidiaries are the
same as the reporting date of ING Bank N.V.
ING Bank N.V. and its Dutch group companies are subject to legal restrictions regarding the amount of
dividends they can pay to their shareholders. The Dutch Civil Code contains the restriction that dividends
can only be paid up to an amount equal to the excess of the company’s own funds over the sum of the
paid-up capital and reserves required by law. Certain Group companies are also subject to other restrictions

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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 in respect of minimum capital requirements that are imposed by
industry regulators in the countries in which the subsidiaries operate, other limitations exist in certain
countries.
1.9 Segment reporting
An operating segment is a distinguishable component of ING Bank, engaged in providing products or
services, whose operating results are regularly reviewed by the Management Board Banking of ING Bank
(the Chief Operating Decision Maker (CODM)) to make decisions about resources to be allocated to the
segments and assess its performance. A geographical area is a distinguishable component of ING Bank
engaged in providing products or services within a particular economic environment that is subject to risks
and returns that differ from those of segments operating in other economic environments.
The CODM examines ING Bank’s performance both by line of business and geographic perspective and has
identified five reportable segments by line of business. The geographical analyses are based on the location
of the office from which the transactions are originated.
1.10 Foreign currency translation
Functional and presentation currency
Items included in the financial statements of each of ING Bank’s entities are measured using the currency of
the primary economic environment in which the entity operates (the functional currency). The Consolidated
financial statements are presented in euros, which is ING Bank’s presentation currency.
Transactions and balances
Foreign currency transactions are translated into the functional currency using the exchange rate prevailing
at the date of the transactions. Exchange rate differences resulting from the settlement of such
transactions and from the translation at year-end exchange rates of monetary assets and liabilities
denominated in foreign currencies are recognised in the statement of profit or loss, except when deferred in
equity as part of qualifying cash flow hedges or qualifying net investment hedges.
Non-monetary items that are measured in terms of historical cost in a foreign currency are translated using
the exchange rate at the date of the transaction.
Exchange rate differences on non-monetary items, measured at fair value through profit or loss, are
reported as part of the fair value gain or loss. Non-monetary items are retranslated at the date the fair
value is determined. Exchange rate differences on non-monetary items measured at fair value through
other comprehensive income are included in other comprehensive income and get accumulated in the
revaluation reserve in equity.
Exchange rate differences in the statement of profit or loss are generally included in ‘Valuation results and
net trading income’. Reference is made to Note 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 and expenses are translated at the dates of the transactions). However, under hyperinflation
accounting, income and expenses of ING Turkey 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.
1.11 Investments in associates and joint ventures
Associates are all entities over which ING Bank has significant influence but not control. Significant influence
is the ability to participate in the financial and operating policies of the investee. It generally results from a
shareholding of between 20% and 50% of the voting rights or through situations including, but not limited
to one or more of the following:

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•Representation on the board of directors;
•Participation in the policymaking process; and
•Interchange of managerial personnel.
Joint ventures are entities over which ING Bank has joint control. Joint control is the contractually agreed
sharing of control over an arrangement or entity, which exists only when decisions about the relevant
activities require the unanimous consent of the parties sharing control. Joint control means that no party to
the agreement is able to act unilaterally to control the activity of the entity. The parties to the agreement
must act together to control the entity and therefore exercise the joint control.
Investments in associates and joint ventures are initially recognised at cost and subsequently accounted for
using the equity method of accounting.
ING Bank’s investment in associates and joint ventures (net of any accumulated impairment loss) includes
goodwill identified on acquisition. ING Bank’s share of its associates and joint ventures post-acquisition
profits or losses is recognised in the statement of profit or loss, and its share of post-acquisition changes in
reserves is recognised in equity. The cumulative post-acquisition changes are adjusted against the carrying
amount of the investment. When ING Bank’s share of losses in an associate or joint venture equals or
exceeds its interest in the associate or joint venture, including any long-term interests in the associate like
uncollateralised loans that are neither planned nor likely to be settled in the foreseeable future, ING Bank
does not recognise further losses, unless it has incurred obligations or made payments on behalf of the
associate or joint venture.
Unrealised gains on transactions between ING Bank and its associates and joint ventures are eliminated to
the extent of ING Bank’s interest in the associates and joint ventures. Unrealised losses are also eliminated
unless they provide evidence of an impairment of the asset transferred. Accounting policies of associates
and joint ventures have been changed where necessary to ensure consistency with the policies adopted by
ING Bank.
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. 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. An impairment loss is reversed to the extent that the recoverable
amount exceeds its carrying amount, but cannot exceed the original impairment loss.
The reporting dates of certain associates and joint ventures can differ from the reporting date of the Group,
but by no more than three months.

Significant judgements and critical accounting estimates and assumptions: The most significant estimates and assumptions relate to the assessment of (reversal of) impairment of the investment in TMBThanachart Bank Public Company Limited (hereafter: TTB) which involves estimation of value in use. Management's best estimate of the expected future earnings of TTB is based on forecasts derived from broker consensus over the short to medium term and reasonable and supportable assumptions capturing a combination of TTB specific and market data points for longer term and steady state expectations into perpetuity. 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. Both of these factors are subject to a high degree of uncertainty. Key assumptions used in estimating TTB’s value in use and the sensitivity of the value in use calculations to different assumptions are described in note 8 ‘Investments in associates and joint ventures’.

1.12 Property and equipment
Property in own use
Land and buildings held for own use are stated at fair value at the balance sheet date. Increases in the
carrying amount arising on revaluation of land and buildings held for own use are credited to the
revaluation reserve in shareholders’ equity. Decreases in the carrying amount that offset previous increases
of the same asset are charged against the revaluation reserve directly in equity; all other decreases are
charged to the statement of profit or loss. Increases that reverse a revaluation decrease on the same asset
previously recognised in net result are recognised in the statement of profit or loss. Depreciation is
recognised based on the fair value and the estimated useful life (in general 20–50 years). Depreciation is
calculated on a straight-line basis. On disposal, the related revaluation reserve is transferred to retained
earnings.
In principle, the fair values of land and buildings are appraised annually by independent qualified valuers.
Subsequent expenditure is included in the asset’s carrying amount when it is probable that future economic
benefits associated with the item will flow to ING Bank and the cost of the item can be measured reliably.
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:
for data processing equipment two to five years, and four to ten years for fixtures and fittings. Expenditure
incurred on maintenance and repairs is recognised in the statement of profit or loss as incurred. Expenditure
incurred on major improvements is capitalised and depreciated.

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Disposals of property and equipment
The difference between the proceeds on disposal and net carrying value is recognised in the statement of
profit or loss under Other net income.
Right-of-use assets
ING Bank as the lessee
A lessee is required to recognise a right-of-use asset representing its right to use the underlying leased asset
and a corresponding liability representing its obligation to make lease payments at the date at which the
leased asset is available for use by ING Bank. Each lease payment is allocated between the repayment of
the liability and finance cost. The finance costs are charged to profit or loss over the lease period so as to
produce a constant periodic rate of interest on the remaining balance of the liability for each period. The
right-of-use asset is depreciated over the shorter of the asset’s useful life and the lease term on a straight-
line basis.
Assets and liabilities arising from a lease are initially measured on a present value basis. Lease liabilities
include the net present value of the following lease payments:
•Fixed payments (including in-substance fixed payments), less any lease incentives receivable;
•Variable lease payments that are based on an index or a rate;
•Amounts expected to be payable by the lessee under residual value guarantees;
•The exercise price of a purchase option if the lessee is reasonably certain to exercise that option; and
•Payments of penalties for terminating the lease, if the lease term reflects the lessee exercising that
option.
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. This rate is approximated by using the risk free rate applicable to the
lease term, the currency of the lease payment and jurisdiction, with the Fund Transfer Pricing (FTP) rate as
an add-on. The FTP rate is used to transfer interest rate risk and funding and liquidity risk positions between
the ING Bank business and treasury departments. It is determined by either ING Bank or Local Asset and
Liability Committee (ALCO). Reference is made to the ‘Risk management’ section of the Annual Report.
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.
Payments associated with short-term leases and leases of low-value assets are recognised on a straight-
line basis as an expense in profit or loss. Short-term leases are leases with a lease term of 12 months or less.
Low-value assets comprise mainly IT-equipment (for example mobile phones or laptops) and small items of
office furniture.
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
decrease when payments are made. Any remeasurement of the lease liability due to a lease modification
or other reassessment results in a corresponding adjustment to the carrying amount of the right-of-use
asset.
1.13 ING Bank as lessor
When ING Bank acts as a lessor, a distinction should be made between finance leases and operating leases.
For ING Bank as a lessor these are mainly finance leases and are therefore not included in 'Property and
equipment'. Instead, the present value of the lease payments is recognised as a receivable under Loans and
advances to customers or Loans and advances to banks. The difference between the gross receivable and
the present value of the receivable is unearned finance lease income. Lease income is recognised over the
term of the lease using the net investment method (before tax), which reflects a constant periodic rate of
return.
1.14 Acquisitions, goodwill and other intangible assets
Goodwill resulting from a business combination
ING Bank’s business combinations are accounted for using the acquisition method of accounting. The
consideration for each business combination is measured at the aggregate of the fair values (at the date of
exchange) of assets given, liabilities incurred or assumed, and equity instruments issued in exchange for
control of the acquiree. Goodwill, being the difference between the cost of the acquisition (including
assumed debt) and the Group’s interest in the fair value of the investee's identifiable assets, liabilities and
contingent liabilities as at the date of acquisition, is capitalised as an intangible asset. Goodwill is only
recognised separately on acquisitions. The results of the operations of the acquired companies are included
in the statement of profit or loss from the date control is obtained.
Where applicable, the consideration for the business combination includes any asset or liability resulting
from a contingent consideration arrangement, the contingent consideration is measured at its acquisition-
date fair value. Contingent consideration arrangements classified as an asset or a liability, are subsequently

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measured at fair value and the changes in fair value are recognised in the statement of profit or loss.
Changes in the fair value of the contingent consideration classified as equity, are not recognised.
Where a business combination is achieved in stages, ING Bank’s previously held interests in the assets and
liabilities of the acquired entity are remeasured to fair value at the acquisition date (i.e. the date ING Bank
obtains control) and the resulting gain or loss, if any, is recognised in the statement of profit or loss.
Amounts arising from interests in the acquiree prior to the acquisition date that have previously been
recognised in other comprehensive income are reclassified to the statement of profit or loss, where such
treatment would be appropriate if that interest were disposed of. Acquisition related costs are recognised in
the statement of profit or loss as incurred and presented in the statement of profit or loss as Other
operating expenses.
The initial accounting for the fair value of the net assets of the companies acquired during the year may be
determined only provisionally as the determination of the fair value can be complex and the time between
the acquisition and the preparation of the Financial statements can be limited. The initial accounting shall
be completed within a year after acquisition. Adjustments to the fair value as at the date of acquisition of
acquired assets and liabilities, that are identified within one year after acquisition are recognised as an
adjustment to goodwill; any subsequent adjustment is recognised as income or expense. On disposal of
group companies where control is lost, the difference between the sale proceeds and carrying value
(including goodwill) and the unrealised results (including the currency translation reserve in equity) is
included in the statement of profit or loss.
Impairment of goodwill and other non-financial assets
ING Bank assesses at each reporting period, whether there is an indication that a non-financial asset may be
impaired. Irrespective of whether there is an indication of impairment, intangible assets with an indefinite
useful life, including goodwill acquired in a business combination, and intangible assets not yet available for
use, are tested annually for impairment. Goodwill is allocated to groups of cash generating units (CGUs) for
the purpose of impairment testing. These groups of CGUs represent the lowest level at which goodwill is
monitored for internal management purposes. Goodwill is tested for impairment by comparing the carrying
value of the group of CGUs to the recoverable amount of that group of CGUs. The carrying value is
determined on a basis that is consistent with the way in which the recoverable amount of the CGU is
determined. The recoverable amount is estimated as the higher of fair value less costs of disposal and value
in use. 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. This period will generally not exceed five years. Amortisation is included in Other operating expenses.
Other intangible assets
Other intangible assets are capitalised and amortised over their expected economic life, which is generally
between three and ten years.
1.15 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.
Deferred income tax
Deferred income tax is provided in full, using the liability method, for temporary differences arising between
the tax basis of assets and liabilities and their carrying amounts in the Consolidated statement of financial
position. Deferred income tax is determined using tax rates (and laws) that have been enacted or
substantively enacted at the balance sheet date and are expected to apply when the related deferred
income tax asset is realised or the deferred income tax liability is settled. Deferred tax assets and liabilities
are not discounted.
Deferred tax assets are recognised when it is probable that future taxable profit will be available against
which the temporary differences can be utilised. Deferred income tax is provided for temporary differences
arising from investments in subsidiaries and associates, except where the timing of the reversal of the
temporary difference is controlled by ING Bank and it is probable that the difference will not reverse in the
foreseeable future. The tax effects of income tax losses available for carry forward are recognised as an
asset where it is probable that future taxable profits will be available against which these losses can be
utilised.
Fair value remeasurements of debt and equity instruments measured at FVOCI and cash flow hedges are
recognised directly in equity. Deferred tax related to this fair value remeasurement is also recognised
directly in equity and is subsequently recognised in the statement of profit or loss together with the
deferred gain or loss.
Uncertain tax positions are assessed continually by ING Bank and in case it is probable that there will be a
cash outflow, a current tax liability is recognised.
1.16 Other assets
Investment property
Investment properties are recognised at fair value at the balance sheet date. The fair values of investment
properties are appraised annually by independent qualified valuers. Changes in the carrying amount

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ING Bank Annual Report 2022 157
resulting from revaluations are recognised in the statement of profit or loss. On disposal, the difference
between the sale proceeds and carrying value is recognised in the statement of profit or loss.
Property obtained from foreclosures
Property obtained from foreclosures is stated at the lower of cost and net realisable value. Net realisable
value is the estimated selling price, less applicable variable selling expenses. Property obtained from
foreclosures is included in Other assets - Property development and obtained from foreclosures.
Property development
Property developed and under development is included in Other assets – Property development and
obtained from foreclosures. Depending on the intention of ING Bank after completion of the development,
the property is measured as follows:
•Intention to sell: at the lower of cost and net realisable value;
•Intention to use as a real estate investment: at fair value.
1.17 Disposal groups held for sale and discontinued operations
Disposal groups (and non-current assets) are classified as held for sale if their carrying amount will be
recovered principally through a sale transaction rather than through continuing use. This is only the case
when the sale is highly probable and the disposal group (or non-current assets) is available for immediate
sale in its present condition; including management must be committed to the sale, which is expected to
occur within one year from the date of classification as held for sale.
Upon classification as held for sale, the disposal group is measured at the lower of its carrying amount and
fair value less costs to sell, except where specifically exempt from IFRS 5 ‘Non-current Assets Held for Sale
and Discontinued Operations. An impairment loss is recognised for any initial or subsequent write-down of
the disposal group to fair value less costs to sell. A gain is recognised for any subsequent increases in fair
value less costs to sell of the disposal group, but not in excess of any cumulative impairment loss previously
recognised. A gain or loss not previously recognised by the date of the sale of the disposal group is
recognised at the date of derecognition. Assets within the disposal group are not depreciated or amortised
while they are classified as held for sale. Interest and other net income/expenses attributable to the
liabilities of a disposal group classified as held for sale continue to be recognised. The assets of the disposal
group classified as held for sale are presented separately from the other assets in the balance sheet. The
liabilities of a disposal group classified as held for sale are presented separately from other liabilities in the
balance sheet.
When a group of assets that is classified as held for sale represents a major line of business or geographical
area the disposal group is classified as discontinued operations. Upon classification of a business as held for
sale and discontinued operations the individual income and expenses are presented within the Total net
result from discontinued operations instead of being presented in the usual line items in the Consolidated
statement of profit or loss. All comparative years in the Consolidated statement of profit or loss are restated
and presented as discontinued operations for all periods presented. Furthermore, the individual assets and
liabilities are presented in the Consolidated statement of financial position as Assets and liabilities held for
sale and are no longer included in the usual line items in the Consolidated statement of financial position.
Changes in assets and liabilities as a result of classification as held for sale are included in the notes in the
line ‘Changes in composition of the group and other changes’.
1.18 Provisions, contingent liabilities and contingent assets
A provision is a present obligation arising from past events, the settlement of which is expected to result in
an outflow of resources embodying economic benefits, however the timing or the amount is uncertain.
Provisions are discounted when the effect of the time value of money is significant using a pre-tax discount
rate.
Reorganisation provisions include employee termination benefits when ING Bank is demonstrably
committed to either terminate the employment of current employees according to a detailed formal plan
without possibility of withdrawal, or providing termination benefits as a result of an offer made to
encourage voluntary redundancy.
A liability is recognised for a levy when the activity that triggers payment, as identified by the relevant
legislation, occurs. For a levy that is triggered upon reaching a minimum threshold, the liability is recognised
only upon reaching the specified minimum threshold.
A contingent liability is a possible obligation that arises from past events and whose existence will be
confirmed only by the occurrence or non-occurrence of one or more uncertain future events not wholly
within the control of ING Bank; or a present obligation that arises from past events but is not recognised
because it is either not probable that an outflow of economic benefits will be required to settle the
obligation or the amount of the obligation cannot be measured reliably. Contingent liabilities are not
recognised in the statement of financial position, but are rather disclosed in the notes unless the possibility
of the outflow of economic benefits is remote.
A contingent asset is a possible asset that arises from past events and whose existence will be confirmed
only by the occurrence or non-occurrence of one or more uncertain future events not wholly within the
control of ING Bank. Contingent assets are recognised in the statement of financial position only when
realisation of the income that arises from such an asset is virtually certain. Contingent assets are disclosed
in the notes when an inflow of economic benefits is probable.

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ING Bank Annual Report 2022 158

Significant judgements and critical accounting estimates and assumptions: The recognition and measurement of provisions is an inherently uncertain process involving using judgement to determine when a present obligation exists and estimates regarding probability, amounts and timing of cash flows. ING Bank may become involved in governmental, regulatory, arbitration and legal proceedings and investigations and may be subject to third party claims. With or without reference to the above, ING Bank may also offer compensation to certain of its customers. Judgement is required to assess whether a present obligation exists and to estimate the probability of an unfavourable outcome and the amount of potential loss. The degree of uncertainty and the method of making the accounting estimate depends on the individual case, its nature and complexity. Such cases are usually one of a kind. For the assessment of related provisions ING Bank consults with internal and external legal experts. Even taking into consideration legal experts’ advice, the probability of an outflow of economic benefits can still be uncertain and the provision recognised can remain sensitive to the assumptions used. Reference is made to Note 15 'Provisions'. For proceedings where it is not possible to make a reliable estimate of the expected financial effect, that could result from the ultimate resolution of the proceedings, no provision is recognised, however disclosure is included in the financial statements, where relevant. Reference is made to Note 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'.

1.19 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.
Plan assets are measured at fair value at the balance sheet date. For determining the pension expense, the
return on plan assets is determined using a high quality corporate bond rate identical to the discount rate
used in determining the defined benefit obligation.
Changes in plan assets that effect Shareholders’ equity and/or Net result, include mainly:
•Return on plan assets using a high quality corporate bond rate at the start of the reporting period which
are recognised as staff costs in the statement of profit or loss; 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. The actuarial assumptions may differ
significantly from the 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 the defined
benefit plan obligation and future pension costs.
Changes in the defined benefit obligation that effect Shareholders’ equity and/or Net result, include mainly:
•Service cost which is recognised as staff costs in the statement of profit or loss;
•Interest expenses using a high quality corporate bond rate at the start of the period which are
recognised as staff costs in the Statement of profit or loss; and
•Remeasurements which are recognised in Other comprehensive income (equity).
Remeasurements recognised in other comprehensive income are not recycled to 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. Gains and losses on curtailments and settlements are recognised in the statement of profit or
loss when the curtailment or settlement occurs.
The recognition of a net defined benefit asset in the Consolidated statement of financial position is limited
to the present value of any economic benefits available in the form of refunds from the plans or reductions
in future contributions to the plans.
Defined contribution plans
For defined contribution plans, ING Bank pays contributions to publicly or privately administered pension
insurance plans on a mandatory, contractual or voluntary basis. ING Bank has no further payment
obligations once the contributions have been paid. The contributions are recognised as staff expenses in the
profit or loss when they are due. Prepaid contributions are recognised as an asset to the extent that a cash
refund or a reduction in the future payments is available.
Other post-employment obligations
Some group companies provide other post-employment benefits to former employees. The entitlement to
these benefits is usually conditional on the employee remaining in service up to retirement age and the

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ING Bank Annual Report 2022 159
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.
1.20 Income recognition
Interest
Interest income and expense are recognised in the statement of profit or loss using the effective interest
method. The effective interest method is a method of calculating the amortised cost of a financial asset or a
financial liability and of allocating the interest income or interest expense over the relevant period. The
effective interest rate is the rate that exactly discounts estimated future cash payments or receipts through
the expected life of the financial instrument or, when appropriate, a shorter period to the net carrying
amount of the financial asset or financial liability. When calculating the effective interest rate, ING Bank
estimates cash flows considering all contractual terms of the financial instrument (for example, prepayment
options) but does not consider future credit losses.
The calculation includes all fees and points paid or received between parties to the contract that are an
integral part of the effective interest rate, transaction costs and all other premiums or discounts. Once a
financial asset or a group of similar financial assets has been written down as a result of an impairment loss,
interest income is recognised using the rate of interest used to discount the future cash flows for the
purpose of measuring the impairment loss.
Interest results on instruments classified at Amortised Cost, assets measured at FVOCI and derivatives in a
formal hedge accounting relationship is 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 Bank has retained
no part of the loan package for itself or has retained a part at the same effective interest rate as the other
participants. Commission and fees arising from negotiating, or participating in the negotiation of, a
transaction for a third party – such as the arrangement of the acquisition of shares or other securities or the
purchase or sale of businesses – are recognised on completion of the underlying transaction. Portfolio and
other management advisory and service fees are recognised based on the applicable service contracts as
the service is provided. Asset management fees related to investment funds and investment contract fees
are recognised on a pro-rata basis over the period the service is provided. The same principle is applied for
wealth management, financial planning and custody services that are continuously provided over an
extended period of time. Fees received and paid between banks for payment services are classified as
commission income and expenses.
Lease income
The proceeds from leasing out assets under operating leases are recognised on a straight-line basis over the
life of the lease agreement. Lease payments received in respect of finance leases when ING Bank is the
lessor are divided into an interest component (recognised as interest income) and a repayment component
based on a pattern reflecting a constant periodic rate of return on the lessor’s net investment in the lease.
1.21 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 are generally a result from a contract with ING service
providers in order to perform the service for ING Bank’s customers. Costs are generally presented as
‘Commission expenses’ if they are specific, incremental, directly attributable and identifiable to generate
commission income.
Share-based payments
ING Bank only engages in share-based payment transactions with its staff and directors. Share-based
payment expenses are recognised as a staff expense over the vesting period. A corresponding increase in
equity is recognised for equity-settled share-based payment transactions. A liability is recognised for cash-
settled share-based payment transactions. The fair value of equity-settled share-based payment
transactions are measured at the grant date, and the fair value of cash-settled share-based payment
transactions are measured at each balance sheet date. Rights granted will remain valid until the expiry
date, even if the share based payment scheme is discontinued. The rights are subject to certain conditions,
including a pre-determined continuous period of service.
1.22 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 comprise balances with less
than three months’ maturity from the date of acquisition, including cash and balances with central banks,
treasury bills and other eligible bills, amounts due from other banks, and deposits from banks. Investments

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ING Bank Annual Report 2022 160
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 accounts
The parent company accounts of ING Bank N.V. are prepared in accordance with the financial reporting
requirements included in Part 9 of Book 2 of the Dutch Civil Code. In accordance with subsection 8 of section
362, Book 2 of the Dutch Civil Code, the recognition and measurement principles applied in the Parent
company accounts are the same as those applied in the Consolidated financial statements.

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ING Bank Annual Report 2022 161
Notes to the Consolidated statement of financial position
2 Cash and balances with central banks

Cash and balances with central banks
in EUR million | 2022 | 2021
Amounts held at central banks 1 | 85,934 | 104,870
Cash and bank balances | 1,681 | 1,650
| 87,614 | 106,520

1 Amounts held at central banks include an amount of EUR -12 million (2021: EUR -6 million) of Loan loss provisions.
The movement in Cash and balances with central banks reflects ING’s active liquidity management.
Amounts held at central banks reflect on demand balances.
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 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Loans and advances to banks | 23,462 | 7,018 | 11,679 | 16,595 | 35,140 | 23,613
Loan loss provisions | -12 | -10 | -26 | -13 | -37 | -22
| 23,450 | 7,009 | 11,653 | 16,582 | 35,103 | 23,591

Loans include balances (mainly reverse repos) with central banks amounting to EUR 19,395 million (2021:
EUR 3,403 million). 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 2022 and at 31 December 2021, 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 | 2022 | 2021
Trading assets | 56,875 | 51,389
Non-trading derivatives | 3,893 | 1,536
Designated at fair value through profit or loss | 6,159 | 6,355
Mandatorily measured at fair value through profit or loss | 46,844 | 42,684
| 113,770 | 101,964

(Reverse) repurchase transactions
Financial assets at fair value through profit or loss includes securities lending and sales and repurchase
transactions which were not derecognised, because ING Bank continues to be exposed to substantially all
risks and rewards of the transferred financial asset. For repurchase agreements the gross amount of assets
must be considered together with the gross amount of related liabilities, which are presented separately on
the statement of financial position since IFRS does not always allow netting of these positions in the
statement of financial position.
ING Bank’s exposure to (reverse) repurchase transactions is included in the following lines in the statement
of financial position:

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> 2 Cash and balances with central banks
ING Bank Annual Report 2022 162

Exposure to (reverse) repurchase agreements
in EUR million | 2022 | 2021
Reverse repurchase transactions |  |
Loans and advances to banks | 19,395 | 3,403
Loans and advances to customers | 1,306 | 71
Trading assets, loans and receivables | 9,732 | 8,026
Loans and receivables mandatorily measured at fair value through profit or loss | 43,153 | 39,823
| 73,587 | 51,322
Repurchase transactions |  |
Deposits from banks | 3,809 | 4,138
Trading liabilities, funds on deposit | 5,715 | 7,127
Funds entrusted designated and measured at fair value through profit or loss | 43,131 | 34,608
| 52,654 | 45,873

Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the consolidated statement of financial position. 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, Other financial assets 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. The counterparty liability is
measured at FVPL (designated) and included in Other financial liabilities at FVPL if the asset is measured at
FVPL. Otherwise, the counterparty liability is included in Deposits from banks, or Trading, as appropriate.
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.
Trading assets

Trading assets by type
in EUR million | 2022 | 2021
Equity securities | 11,741 | 17,574
Debt securities | 4,189 | 5,319
Derivatives | 30,841 | 19,764
Loans and receivables | 10,103 | 8,733
| 56,875 | 51,389

Trading assets include assets that are classified under IFRS as Trading, but are closely related to servicing
the needs of the clients of ING Bank. ING offers institutional clients, corporate clients, and governments,
products that are traded on the financial markets. A significant part of the derivatives in the trading portfolio
is related to servicing corporate clients in their risk management to hedge for example currency or interest
rate exposures. In addition, ING provides its customers access to equity and debt markets for issuing their
own equity or debt securities (securities underwriting).
Reference is made to Note 14 'Financial liabilities at fair value through profit or loss' for information on
trading liabilities.
Non-trading derivatives

Non-trading derivatives by type
in EUR million | 2022 | 2021
Derivatives used in |  |
- fair value hedges | 836 | 365
- cash flow hedges | 814 | 300
- hedges of net investments in foreign operations | 119 | 18
Other non-trading derivatives | 2,124 | 852
| 3,893 | 1,536

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 and foreign exchange 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 | 2022 | 2021
Debt securities | 5,437 | 5,870
Loans and receivables | 722 | 485
| 6,159 | 6,355

‘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’

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> 4 Financial assets at fair value through profit or loss
ING Bank Annual Report 2022 163
approximates its carrying value and amounts to EUR 6,159 million (2021: EUR 6,355 million). The cumulative
change in fair value of the loans and debt securities attributable to changes in credit risk is EUR 345 million
(2021: EUR 99 million)
The notional value of the related credit derivatives is EUR 3,370 million (2021: EUR 2,640 million). The
cumulative change in fair value of the credit derivatives attributable to changes in credit risk since the
financial assets were first designated, amounts to EUR 3 million (2021: EUR -69 million) and the change for
the current year is EUR 72 million (2021: EUR -53 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 | 2022 | 2021
Equity securities | 203 | 161
Debt securities | 821 | 787
Loans and receivables | 45,820 | 41,735
| 46,844 | 42,684

Equity securities are individually insignificant for ING Bank. For debt securities ING Bank total exposure
reference is made to Note 6 'Securities at amortised cost'. 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 | 2022 | 2021
Equity securities | 1,887 | 2,457
Debt securities 1 | 29,095 | 27,340
Loans and advances 1 | 643 | 838
| 31,625 | 30,635

1 Debt securities include an amount of EUR -21 million (2021: EUR -12 million) and the Loans and advances includes EUR
-1 million(2021: EUR -1 million) of Loan loss provisions.
Exposure to equity securities

Equity securities designated as at fair value through other comprehensive income |
| Carrying value | Carrying value | Dividend income | Dividend income
in EUR million | 2022 | 2021 | 2022 | 2021
Investment in Bank of Beijing | 1,614 | 1,700 | 111 | 97
Other Investments | 273 | 757 | 38 | 25
| 1,887 | 2,457 | 149 | 122

For strategic equity securities, ING decided to apply the option to irrevocably designate these investments
at fair value through other comprehensive income, instead of the IFRS 9 default measurement of fair value
through profit or loss.
As at 31 December 2022 ING holds approximately 13% (2021: 13%) of the shares of Bank of Beijing, a bank
listed on the stock exchange of Shanghai. As per regulatory requirements set by China Banking and
Insurance Regulatory Commission, ING, as a shareholder holding more than 5% or more of the shares, is
required to supply additional capital when necessary. No request for additional capital was received in 2022
(2021: nil).
Changes in fair value through other comprehensive income
The following table presents changes in financial assets at fair value through other comprehensive income.

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> 4 Financial assets at fair value through profit or loss
ING Bank Annual Report 2022 164

Changes in fair value through other comprehensive income financial assets
| FVOCI equity securities | FVOCI debt instruments 1 | Total
in EUR million | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Opening balance | 2,457 | 1,862 | 28,178 | 34,033 | 30,635 | 35,895
Additions | 17 | 518 | 18,789 | 12,669 | 18,806 | 13,186
Amortisation |  |  | -18 | -46 | -18 | -46
Transfers and reclassifications | 10 | -7 |  |  | 10 | -7
Changes in unrealised revaluations 2 | -65 | -88 | -3,230 | -1,209 | -3,295 | -1,296
Impairments |  |  |  | -5 |  | -5
Reversals of impairments |  |  | 3 | 4 | 3 | 4
Disposals and redemptions | -492 | -19 | -14,034 | -17,730 | -14,526 | -17,750
Exchange rate differences | -39 | 191 | 49 | 460 | 10 | 651
Changes in the composition of the group and other changes |  |  | 1 | 2 | 1 | 2
Closing balance | 1,887 | 2,457 | 29,739 | 28,178 | 31,625 | 30,635

1 Fair value through other comprehensive income debt instruments includes both debt securities and loans and advances.
2 Changes in unrealized revaluations of FVOCI debt instruments include changes on hedged items which are recognized in the
statement of profit or loss. Reference is made to .Note 19 'Equity' for details on the changes in revaluation reserve.
FVOCI equity securities
In 2022, disposals of EUR 492 million mainly relate to the sale in the second quarter of HQLA eligible equity
instruments triggered by the changing interest rate environment and deteriorating market sentiment. This
portfolio was built up in early 2021 (additions in 2021: EUR 499 million) and was a relatively small part of the
HQLA portfolio. This was a diversified buy-and-hold portfolio aimed at generating stable dividend income
stream.
In 2022, exchange rate differences of EUR -39 million are mainly related to the stake in Bank of Beijing
following the depreciation of CNY vs EUR. Furthermore, changes in unrealised revaluations of equity
securities are mainly related to negative revaluation of the stake in Bank of Beijing following a decline in
share price (EUR -49 million).
FVOCI debt instruments
In 2022, changes in unrealised revaluations of EUR -3,230 million relate to increased yield curves.
Reference is made to Note 6 'Securities at amortised cost' for details on ING Bank’s total exposure to debt
securities.
6 Securities at amortised cost
Securities at amortised cost fully consist of Debt securities. ING Bank’s exposure to debt securities is
included in the following lines in the statement of financial position:

Exposure to debt securities
in EUR million | 2022 | 2021
Debt securities at fair value through other comprehensive income | 29,095 | 27,340
Debt securities at amortised cost | 48,160 | 48,319
Debt securities at fair value through other comprehensive income and amortised cost | 77,255 | 75,659
Trading assets | 4,189 | 5,319
Debt securities at fair value through profit or loss | 6,258 | 6,658
Total debt securities at fair value through profit or loss | 10,447 | 11,976
| 87,703 | 87,635

ING Bank’s total exposure to debt securities (excluding debt securities held in the trading portfolio) of EUR
83,513 million (31 December 2021: EUR 82,316 million) is specified as follows:

Debt securities by type of exposure
| Debt Securities at FVPL | Debt Securities at FVOCI | Debt Securities at AC | Total
in EUR million | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Government bonds | 63 | 48 | 16,016 | 16,271 | 24,629 | 26,588 | 40,708 | 42,908
Sub-sovereign, Supranationals and Agencies | 2,343 | 3,115 | 8,529 | 7,587 | 14,210 | 13,752 | 25,082 | 24,454
Covered bonds |  |  | 2,663 | 1,729 | 5,543 | 5,063 | 8,206 | 6,792
Corporate bonds | 857 | 778 | 108 | 156 | 26 | 90 | 991 | 1,024
Financial institutions' bonds | 2,237 | 1,993 | 772 | 798 | 2,551 | 1,932 | 5,561 | 4,724
ABS portfolio | 758 | 723 | 1,028 | 810 | 1,217 | 913 | 3,003 | 2,445
| 6,258 | 6,658 | 29,116 | 27,352 | 48,177 | 48,338 | 83,551 | 82,347
Loan loss provisions |  |  | -21 | -12 | -17 | -19 | -39 | -31
Debt securities portfolio | 6,258 | 6,658 | 29,095 | 27,340 | 48,160 | 48,319 | 83,513 | 82,316

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> 5 Financial assets at fair value through other comprehensive income
ING Bank Annual Report 2022 165
7 Loans and advances to customers

Loans and advances to customers by type 1
| Netherlands | Rest of the world | Total
in EUR million | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Loans to public authorities | 837 | 1,153 | 11,840 | 9,672 | 12,677 | 10,824
Residential mortgages | 107,952 | 110,283 | 205,511 | 203,529 | 313,463 | 313,813
Other personal lending | 5,835 | 6,551 | 30,345 | 31,511 | 36,180 | 38,063
Corporate Lending | 68,128 | 68,104 | 211,092 | 202,020 | 279,220 | 270,124
| 182,752 | 186,091 | 458,789 | 446,733 | 641,541 | 632,824
Loan loss provisions | -993 | -1,119 | -4,990 | -4,156 | -5,984 | -5,274
| 181,759 | 184,972 | 453,798 | 442,577 | 635,557 | 627,550

1 2021 presentation has been updated to improve consistency and comparability
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 2022 EUR 635,361 million (2021: EUR 627,390 million) of loans and advances to
customers are non-subordinated.
No individual loan or advance has terms and conditions that significantly affect the amount, timing or
certainty of the consolidated cash flows of ING Bank.
Loans and advances to customers and to banks include finance lease receivables and are detailed as
follows:

Finance lease receivables 1
in EUR million | 2022 | 2021
Maturities of gross investment in finance lease receivables |  |
- within 1 year | 3,452 | 3,204
- between 1-2 years | 2,463 | 2,311
- between 2-3 years | 1,870 | 1,716
- between 3-4 years | 1,294 | 1,178
- between 4-5 years | 747 | 734
- more than 5 years | 1,423 | 1,495
| 11,251 | 10,637
Unearned future finance income on finance leases | -792 | -525
Net investment in finance leases | 10,459 | 10,112
Included in Loans and advances to banks | 6 | 5
Included in Loans and advances to customers | 10,453 | 10,106
| 10,459 | 10,112

1 The total loan loss provision of EUR 160 million (2021: EUR 167 million) for finance lease receivables is classified into the following loan
loss provision stages: Stage 1: EUR 9 million (2021: EUR 8 million), Stage 2: EUR 28 million (2021: EUR 30 million) and Stage 3: EUR 123
million (2021: EUR 129 million).
The finance lease receivables mainly relate to the financing of equipment and are mainly part of corporate
lending. To a lesser extent, the finance lease receivables relate to real estate for third parties, where ING is
the lessor. Interest income in 2022 on finance lease receivables amounts to EUR 292 million (2021: EUR 217
million).

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> 7 Loans and advances to customers
ING Bank Annual Report 2022 166
8 Investment in associates and joint ventures

Investments in associates and joint ventures
in EUR million 2022 | Interest held (%) | Fair value of listed invest- ments | Balance sheet value | Total assets | Total liabilities | Total income | Total expenses
TMBThanachart Bank Public Company Limited | 23% | 849 | 1,109 | 49,506 | 43,677 | 1,303 | 957
Other investments in associates and joint ventures |  |  | 391 |  |  |  |
|  |  | 1,500 |  |  |  |

Investments in associates and joint ventures
in EUR million 2021 | Interest held (%) | Fair value of listed invest- ments | Balance sheet value | Total assets | Total liabilities | Total income | Total expenses
TMBThanachart Bank Public Company Limited | 23% | 866 | 1,208 | 46,478 | 40,957 | 1,286 | 1,038
Other investments in associates and joint ventures |  |  | 379 |  |  |  |
|  |  | 1,587 |  |  |  |

TMBThanachart Bank Public Company Limited
ING Bank has a 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 shareholding and representation on the Board.
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 represents a number of
associates and joint ventures that are individually not significant to ING Bank.
Significant influence for associates in which the interest held is below 20%, is based on the combination of
ING Bank’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, rating agency and regulatory
views, which can change over time.

Changes in Investments in associates and joint ventures
in EUR million | 2022 | 2021
Opening balance | 1,587 | 1,475
Additions | 48 | 91
Revaluations | -8 | -24
Share of results | 92 | 141
Dividends received | -48 | -34
Disposals | -10 | -23
Impairments | -192 | -3
Exchange rate differences | 27 | -31
Other | 4 | -5
Closing balance | 1,500 | 1,587

Share of results from associates and joint ventures of EUR 92 million (2021: EUR 141 million) as included in
the table above is mainly attributable to results of TTB of EUR 81 million (2021: EUR 61 million). In 2021,
share of results from associates includes additional EUR 28 million gain on our stake in Ebusco.
Impairments
In 2022, Impairments of EUR 192 million is predominantly attributable to TTB of EUR 165 million. TTB is part
of the Retail Other segment.
Impairment testing TTB
The fair value of TTB has been below the purchase cost of the investment for a prolonged period of time
(since 1Q 2020). This is considered to be objective evidence of impairment. As a result ING performed
quarterly impairment tests that led to impairment loss of EUR 165 million (2021: EUR nil).
The impairment test performed in 2022 led to an impairment at 31 March 2022 of EUR 150 million and EUR
15 million at 30 September 2022, as the recoverable amount as determined by a Value in Use calculation,
was below the carrying amount at that point in time. The impairment test at year end resulted in no further
impairments.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use
(‘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

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> 8 Investment in associates and joint ventures
ING Bank Annual Report 2022 167
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 2022 (and as at 30 September 2022
resulting in impairment)
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): 9.71% (30 September 2022: 10.54%), based on the capital asset pricing
model (CAPM) calculated for TTB using current market data.
•Terminal growth rate: 3.05% (30 September 2022: 3.82%) consistent with current long term government
bond yield in Thailand as a proxy for a risk-free rate;
To assess the risk of further impairment at 31 December 2022, 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. Holding the other key assumptions constant, a reduction in all of the forecasted
annual cash flows, including terminal value, of 836 bps would reduce the recoverable amount to the carrying
amount. An increase of 55 bps in terminal growth rate and discount rate would cause the VIU to equal the
carrying amount.
Reversal of the impairment loss recognised was not considered appropriate as at 31 December 2022 mainly
due to the lack of sufficiently positive changes observed in the underlying performance of TTB since the
impairment loss as reflected in the broker consensus. Furthermore, the share price remains below the
original cost of the investment for a prolonged period of time.
9 Property and equipment

Property and equipment by type |  |
in EUR million | 2022 | 2021
Property in own use | 681 | 702
Equipment: |  |
- Data processing equipment | 213 | 207
- Other equipment | 476 | 493
Right- of- use assets: |  |
- ROU property | 1,000 | 1,009
- ROU cars | 64 | 83
- ROU other leases | 12 | 21
| 2,446 | 2,515

Changes in property and equipment |  |  |  |  |
| Property in own use | Equipment | Right-of-use assets | Total
in EUR million | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Opening balance | 702 | 745 | 699 | 842 | 1,113 | 1,255 | 2,515 | 2,841
Additions | 2 | 9 | 229 | 175 | 173 | 164 | 404 | 348
Transfers | -1 | -5 | -1 | 1 | -4 | -20 | -5 | -24
Depreciation | -13 | -15 | -220 | -287 | -252 | -271 | -485 | -573
Impairments 1 | -9 | -10 | -16 | -8 | -9 | -15 | -35 | -33
Reversals of impairments | 16 | 6 |  |  |  | 1 | 16 | 7
Remeasurements | 15 | 17 |  |  | 67 | 6 | 81 | 24
Disposals | -67 | -24 | -15 | -15 | -15 | -10 | -98 | -49
Exchange rate differences | 36 | -21 | 13 | -7 | 3 | 4 | 52 | -25
Closing balance | 681 | 702 | 688 | 699 | 1,076 | 1,113 | 2,446 | 2,515
Costprice | 847 | 910 | 3,554 | 3,581 | 1,680 | 1,738 | 6,081 | 6,229
Accumulated depreciation | -362 | -373 | -2,853 | -2,871 | -714 | -644 | -3,929 | -3,888
Accumulated impairments | -107 | -134 | -12 | -10 | -21 | -29 | -140 | -173
Accumulated revaluation surplus | 304 | 299 |  |  |  |  | 304 | 299
Accumulated remeasurement |  |  |  |  | 130 | 48 | 130 | 48
Net carrying value | 681 | 702 | 688 | 699 | 1,076 | 1,113 | 2,446 | 2,515

1 Impairments of property and equipment are presented within Other operating expenses in the statement of Profit or Loss.

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> 8 Investment in associates and joint ventures
ING Bank Annual Report 2022 168
ING considers valuations from third party experts in determining the fair values of property in own use.
Property in own use purchase costs amounted to EUR 847 million (2021: EUR 910 million). Cost or the
purchase price less accumulated depreciation and impairments would have been EUR 368 million (2021:
EUR 403 million) had property in own use been valued at cost instead of at fair value.
The reported impairment losses of EUR -35 million (2021: EUR -33 million) mainly result from a change in the
post-pandemic way of working through downscaling of physical office spaces.
10 Intangible assets

Changes in intangible assets
| Goodwill | Software | Other | Total
in EUR million | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Opening balance | 472 | 533 | 682 | 846 | 2 | 15 | 1,156 | 1,394
Opening balance adjustment | 25 |  |  |  |  |  | 25 |
Additions |  |  | 54 | 44 |  |  | 54 | 44
Capitalised expenses |  |  | 144 | 135 |  |  | 144 | 135
Amortisation |  |  | -226 | -260 |  | -1 | -226 | -261
Impairments 1 | -32 |  | -22 | -82 |  | -12 | -54 | -94
Reversal of impairment |  |  |  |  |  |  |  |
Exchange rate differences | -1 | -61 | 4 |  |  |  | 2 | -62
Disposals |  |  | -3 |  |  |  | -3 |
Changes in the composition of the group and other changes |  |  | 3 | -1 |  |  | 3 |
Closing balance | 464 | 472 | 636 | 682 | 2 | 2 | 1,102 | 1,156
Gross carrying amount | 464 | 472 | 2,491 | 2,521 | 8 | 59 | 2,962 | 3,052
Accumulated amortisation |  |  | -1,787 | -1,710 | -4 | -9 | -1,790 | -1,719
Accumulated impairments |  |  | -69 | -129 | -2 | -48 | -70 | -177
Net carrying value | 464 | 472 | 636 | 682 | 2 | 2 | 1,102 | 1,156

1 Impairments of intangible assets are presented within Other operating expenses in the statement of Profit or Loss.
Goodwill
Following a change in monitoring from a centralised towards a de-centralised approach for Retail as from
the beginning of 2022, goodwill related to the group of cash generating units (CGUs) 'Retail Growth Markets'
was re-allocated to the underlying CGUs Retail Romania, Retail Poland and Retail Turkey using a relative
value approach.
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 | Goodwill
Group of CGU’s |  |  |  | 2022 | 2021
Retail Netherlands | Value in use | 8.46% | 2.04% | 30 | 30
Retail Germany | Value in use | 8.35% | 1.82% | 349 | 349
Retail Poland | Value in use | 10.31% | 2.50% | 69 | 70
Retail Romania | Value in use | 12.32% | 2.60% | 15 | 15
Retail Turkey |  |  |  |  | 7
|  |  |  | 464 | 472

Impairment testing
Goodwill is tested for impairment annually in the fourth quarter by comparing the recoverable amount of
each goodwill-carrying CGU with its carrying amount. The key assumptions used in the calculation of the
recoverable amounts are included in the table above. Furthermore, ING Bank tests goodwill whenever a
triggering event is identified, as with the re-allocation from Group of CGUs to country level CGUs on 1
January 2022. The re-allocated goodwill to Turkey CGU, after first being adjusted for hyperinflation
accounting for EUR 25 million, was fully impaired for the amount of EUR 32 million (based on discount rate
24.04% and terminal growth rate 10.40% as per 1 January 2022). Turkey is part of the Retail Other segment.
At the annual impairment test in the fourth quarter, the recoverable amount exceeds the carrying value of
the CGUs as at 31 December 2022 and therefore no impairment is required.
Methodology
In line with IFRS, the recoverable amount is determined as the higher of the fair value less costs of disposal
and Value in Use (VIU). The VIU calculation is based on a Dividend Discount model using three year
management approved plans, updated for expected changes in the macroeconomic environment. When
estimating the VIU of a CGU, local conditions and requirements determine the capital requirements,
discount rates, and terminal growth rates. These local conditions and requirements determine the ability to
upstream excess capital and profits to ING Bank. The discount rate calculation includes other inputs such as
equity market premium, country risk premium, and long term inflation which are based on market sources
and management’s judgement. The long term growth rate for EU-countries is based on long term risk-free
rate by reference to the yield of a composite index consisting of Euro generic government bonds, with a
maturity of 30 years . For other countries, the growth rate includes long term inflation rate obtained from
market sources.

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> 9 Property and equipment
ING Bank Annual Report 2022 169
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 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.
Other changes
Other changes in goodwill in 2022 relate to changes in currency exchange rates of Retail Poland and Retail
Romania goodwill.
Software
Software includes internally developed software amounting to EUR 540 million (2021: EUR 573 million).
Software is reviewed for indicators of impairment. Irrespective of whether there is an indication of
impairment, software under development is tested annually for impairment. In 2022, individually
immaterial items were impaired for an amount of EUR 22 million. In 2021, an impairment of EUR 51 million
with regard to software in the payments and cash management business was recognised. The remaining
software impairments in 2021 related to various, individually immaterial items.
11 Other assets

Other assets by type
in EUR million | 2022 | 2021
Net defined benefit assets | 617 | 783
Investment properties | 18 | 26
Property development and obtained from foreclosures | 34 | 52
Accrued assets | 913 | 795
Amounts to be settled | 5,190 | 2,424
Other | 2,067 | 1,910
| 8,839 | 5,991

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 transaction 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, amongst others, short term
receivables relating to mortgage issuance and other amounts receivable from customers.
12 Deposits from banks
Deposits from banks includes non-subordinated deposits and repurchase agreements from banks.

Deposits from banks by type
| Netherlands | Rest of the world | Total
in EUR million | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Non-interest bearing | 86 | 570 | 315 | 321 | 400 | 891
Interest bearing | 32,858 | 51,893 | 23,374 | 32,307 | 56,232 | 84,201
| 32,943 | 52,463 | 23,689 | 32,629 | 56,632 | 85,092

Deposits from banks includes ING’s participation in the Targeted Longer-Term Refinancing Operations
(TLTRO) of EUR 36.0 billion (2021: EUR 65.5 billion). 2022 includes the impact of an early repayment of EUR
29.5 billion of ING's TLTRO III participation. For the details of the applicable rates and impact on net interest
income reference is made to Note 20 'Net interest income'.
13 Customer deposits

Customer deposits
in EUR million | 2022 | 2021
Savings accounts | 321,005 | 314,893
Credit balances on customer accounts | 283,886 | 280,028
Corporate deposits | 43,308 | 28,183
Other | 38,143 | 34,727
| 686,341 | 657,831

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> 10 Intangible assets
ING Bank Annual Report 2022 170

Customer deposits by type
| Netherlands | Rest of the world | Total
in EUR million | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Non-interest bearing | 2,332 | 1,860 | 24,307 | 27,712 | 26,639 | 29,573
Interest bearing | 277,379 | 254,752 | 382,324 | 373,507 | 659,703 | 628,258
| 279,711 | 256,612 | 406,630 | 401,219 | 686,341 | 657,831

Savings accounts relate to the balances on savings accounts, savings books, savings deposits, and time
deposits of private individuals.
In 2022 Customer deposits includes EUR 48,410 million (2021: EUR 39,759 million) of deposits received from
ING Group.
14 Financial liabilities at fair value through profit or loss

Financial liabilities at fair value through profit or loss
in EUR million | 2022 | 2021
Trading liabilities | 39,088 | 27,113
Non-trading derivatives | 3,048 | 2,120
Designated at fair value through profit or loss | 50,883 | 41,808
| 93,019 | 71,042

Trading liabilities

Trading liabilities by type
in EUR million | 2022 | 2021
Equity securities | 935 | 322
Debt securities | 1,291 | 753
Funds on deposit | 5,993 | 7,513
Derivatives | 30,869 | 18,525
| 39,088 | 27,113

Non-trading derivatives

Non-trading derivatives by type
in EUR million | 2022 | 2021
Derivatives used in: |  |
- fair value hedges | 244 | 270
- cash flow hedges | 1,275 | 485
- hedges of net investments in foreign operations | 83 | 88
Other non-trading derivatives | 1,446 | 1,278
| 3,048 | 2,120

Reference is made to Note 36 'Derivatives and hedge accounting' for information on derivatives used for
hedge accounting.
Other non-trading derivatives mainly includes interest rate swaps and foreign currency swaps for hedging
purposes, but 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 | 2022 | 2021
Debt securities | 6,069 | 5,585
Funds entrusted | 44,731 | 35,993
Subordinated liabilities | 82 | 230
| 50,883 | 41,808

As at 31 December 2022, 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 -75 million (2021: EUR 95 million) on a cumulative
basis. This change has been determined as the amount of change in fair value of the financial liability that is
not attributable to changes in market conditions that gave rise to market risk (i.e. mainly interest rate risk
based on yield curves).
The amount that ING Bank is contractually required to pay at maturity to the holders of financial liabilities
designated at fair value through profit or loss excluding repurchase agreements (part of funds entrusted) is
EUR 8,408 million (2021: EUR 6,853 million).
Funds entrusted include mainly repurchase agreements. In 2022, the balance increased to EUR 44,731
million as a result of rising customer demand.

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> 13 Customer deposits
ING Bank Annual Report 2022 171
15 Provisions

Provisions by type
in EUR million | 2022 | 2021
Reorganisation provisions | 418 | 421
Litigation provisions | 150 | 132
Other provisions | 462 | 420
| 1,030 | 973

Changes in provisions
| Reorganisation | Litigation | Other | Total
in EUR million | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Opening balance | 421 | 381 | 132 | 105 | 420 | 180 | 973 | 666
Additions | 217 | 310 | 59 | 50 | 227 | 354 | 503 | 715
Interest |  |  |  |  | -2 | -2 | -2 | -2
Releases | -46 | -96 | -8 | -11 | -166 | -79 | -221 | -186
Utilised | -170 | -172 | -33 | -18 | -15 | -25 | -218 | -215
Exchange rate differences |  |  |  | -3 |  | -2 | -1 | -4
Other changes | -4 | -3 |  | 9 | -1 | -7 | -4 | -1
Closing balance | 418 | 421 | 150 | 132 | 462 | 420 | 1,030 | 973

In 2022 and 2021 the additions to the reorganisation provisions mainly relate to the discontinuation of retail
banking activities in France and the restructuring of the branch network and retail advice organisation in the
Netherlands, as well as to restructuring activities in Belgium in 2022.
These initiatives are implemented over a period of several years and the estimate of the reorganisation
provisions is inherently uncertain.
Reference is made to Note 42 'Legal proceedings' for developments in litigation provisions.
The additions to the Other provisions in 2022 include EUR 75 million which relates to the provision for the
compensation of Dutch retail customers for past interest charges that did not sufficiently track market rates
and largely reflects the impact of interest-on-interest compensation. This is in addition to the provision of
EUR 180 million recognised in 2021.
In 2022, Other provisions include provisions of EUR 29 million (2021: EUR 34 million) that relate to credit
replacement facilities and EUR 109 million (2021: EUR 114 million) that relate to non-credit replacement off
balance facilities. The additions and releases in 2022 include EUR 138 million (2021: EUR 109 million) and
EUR 141 million (2021: EUR 66 million) respectively related to these off balance facilities.
As at 31 December 2022, amounts expected to be settled within twelve months in provisions amount to EUR
815 million (2021: EUR 740 million). The amounts included are based on best estimates with regard to
amounts and timing of cash flows required to settle the obligation.
Additions to provisions and unused amounts released are presented in Note 27 'Other operating expenses'.
16 Other liabilities

Other liabilities by type
In EUR million | 2022 | 2021
Net defined benefit liability | 139 | 227
Other post-employment benefits | 29 | 72
Other staff-related liabilities | 633 | 612
Other taxation and social security contributions | 365 | 409
Rents received in advance | 30 | 19
Costs payable | 2,014 | 2,015
Amounts to be settled | 6,714 | 5,082
Lease liabilities | 1,174 | 1,220
Other | 2,247 | 3,038
| 13,344 | 12,695

Disclosures in respect of Net defined benefit liabilities are provided in Note 33 'Pensions and other post-
employment benefits'.
Other staff-related liabilities includes vacation leave provisions, variable compensation provisions, jubilee
provisions, and disability/illness provisions.
Amounts to be settled includes 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.
Lease liabilities relate to right-of-use assets. Disclosures in respect to right-of-use assets are provided in
Note 9 'Property and equipment'. The total cash outflow for leases in 2022 was EUR 296 million (2021: EUR
301 million).

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> 15 Provisions
ING Bank Annual Report 2022 172
The line Other relates mainly to balances on margin accounts or amounts payable to customers.
17 Debt securities in issue
Debt securities in issue relates to debentures and other issued debt securities with either fixed interest rates
or interest rates based on floating interest rate levels, such as certificates of deposit and accepted bills
issued by ING Bank, except for subordinated items. Debt securities in issue does not include debt securities
presented as Financial liabilities at fair value through profit or loss. ING Bank does not have debt securities
that are issued on terms other than those available in the normal course of business.

Debt securities in issue – maturities
In EUR million | 2022 | 2021
Fixed rate debt securities |  |
Within 1 year | 18,044 | 31,785
More than 1 year but less than 2 years | 1,217 | 3,135
More than 2 years but less than 3 years | 4,702 | 1,235
More than 3 years but less than 4 years | 2,903 | 1,729
More than 4 years but less than 5 years | 2,880 | 2,914
More than 5 years | 13,221 | 13,133
Total fixed rate debt securities | 42,969 | 53,930
Floating rate debt securities |  |
Within 1 year | 13,856 | 2,266
More than 1 year but less than 2 years | 307 | 130
More than 2 years but less than 3 years | 256 | 137
More than 3 years but less than 4 years | 494 | 194
More than 4 years but less than 5 years | 97 | 192
More than 5 years | 96 | 593
Total floating rate debt securities | 15,106 | 3,513
Total debt securities | 58,075 | 57,443

Reference is made to Note 29 'Changes in liabilities arising from financing activities' for further information
on issuances, redemptions and non-cash movements.
18 Subordinated loans

Subordinated loans
In EUR million | 2022 | 2021
Subordinated loans | 15,789 | 16,719
| 15,789 | 16,719

Subordinated loans relate to subordinated capital debentures and private loans which may be included in
the calculation of the capital ratio.
Subordinated loans include loans that qualify as Tier 1 and Tier 2 (CRD IV eligible) capital. Subordinated loans
of E UR 16,364 million (2021: EUR 15,879 million) have been placed with ING Bank N.V. by ING Groep N.V.
Reference is made to Note 39 'Derivatives and hedge accounting' for details on fair value hedge accounting.
In 2022 ING Groep N.V. issued in August EUR 1 billion 4.13% Fixed Rate Subordinated Tier 2 Green Notes. This
issuance was subsequently placed by ING Groep N.V. with ING Bank N.V. against the same conditions.
ING Bank N.V. redeemed with ING Group N.V. in April 2022 USD 1 billion 6.875% Perpetual Additional Tier 1
Contingent Convertible Capital Securities and in May 2022 JPY 10 billion 1.10% Subordinated Tier 2 Notes on
the first call dates.
Reference is made to Note 32 'Changes in liabilities arising from financing activities' for further information
on issuances and redemptions.
The average interest rate on subordinated loans is 4.00% (2021: 3.74%). The interest expense during the
year 2022 was EUR 646 million (2021: EUR 573 million).

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> 16 Other liabilities
ING Bank Annual Report 2022 173
19 Equity

Total equity
In EUR million | 2022 | 2021 | 2020
Share capital and share premium |  |  |
- Share capital | 525 | 525 | 525
- Share premium | 16,542 | 16,542 | 16,542
| 17,067 | 17,067 | 17,067
Other reserves |  |  |
- Revaluation reserve: Equity securities at FVOCI | 1,187 | 1,282 | 1,181
- Revaluation reserve: Debt instruments at FVOCI | -339 | 92 | 296
- Revaluation reserve: Cash flow hedge | -3,055 | -153 | 1,450
- Revaluation reserve: Credit liability | 70 | -80 | -117
- Revaluation reserve: Property in own use | 176 | 208 | 221
- Net defined benefit asset/liability remeasurement reserve | -232 | -212 | -307
- Currency translation reserve | -2,395 | -3,483 | -3,636
- Share of associates and joint ventures and other reserves | 3,604 | 3,416 | 3,246
| -984 | 1,069 | 2,334
Retained earnings | 26,462 | 29,778 | 28,273
Shareholders’ equity (parent) | 42,546 | 47,914 | 47,675
Non-controlling interests | 504 | 736 | 1,022
Total equity | 43,050 | 48,650 | 48,697

Adjustments for hyperinflation
In 2022 Turkey was deemed a hyperinflationary economy for accounting purposes and ING started applying
IAS 29 ‘Hyperinflation’ on its investment in Turkey. The IAS 29 indexation impact on equity was EUR 100
million in total including EUR 1,011 million in currency translation reserve, EUR -563 million in retained
earnings, EUR -17 million in revaluation reserves and EUR -331 million in profit or loss.
Share capital and share premium
Share capital

Share capital
| Ordinary shares (par value EUR 1.13)
| Number x 1,000 | Amount
| 2022 | 2021 | 2020 | 2022 | 2021 | 2020
Authorised share capital | 1,600,000 | 1,600,000 | 1,600,000 | 1,808 | 1,808 | 1,808
Unissued share capital | 1,134,965 | 1,134,965 | 1,134,965 | 1,283 | 1,283 | 1,283
Issued share capital | 465,035 | 465,035 | 465,035 | 525 | 525 | 525

No change occurred in the issued share capital and share premium in 2022, 2021 and 2020.
All ordinary shares are in registered form. No share certificates have been issued. Ordinary shares may be
transferred by means of a deed of transfer, subject to the approval of the general meeting of ING Bank. The
par value of ordinary shares is EUR 1.13.
The authorised ordinary share capital of ING Bank N.V. consists of 1,600 million shares of which as at
31 December 2022, 465 million ordinary shares were issued and fully paid.
I NG Bank has 50 authorised preference shares with par value of EUR 1.13 per preference share. As at
31 December 2022, 7 preference shares were issued and fully paid (2021: 7 preference shares; 2020: 7
preference shares) amounting to EUR 8 (2021: EUR 8 and 2020: EUR 8).
Dividend restrictions
ING Bank N.V. and its Dutch group companies are subject to legal restrictions regarding the amount of
dividends they can pay to their shareholders. The Dutch Civil Code contains the restriction that dividends
can only be paid up to an amount equal to the excess of the company’s own funds over the sum of the
paid-up capital and reserves required by law. Additionally, certain Bank companies are subject to restrictions
on the amount of funds they may transfer in the form of dividends or otherwise to the parent company.
Furthermore, in addition to the restrictions in respect of minimum capital requirements that are imposed by
industry regulators in the countries in which subsidiaries operate, other limitations exist in certain countries.

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> 19 Equity
ING Bank Annual Report 2022 174
Other reserves
Revaluation reserves

Changes in revaluation reserve: Equity securities and Debt instruments at FVOCI
| Equity securities at FVOCI | Debt instruments at FVOCI
In EUR million | 2022 | 2021 | 2020 | 2022 | 2021 | 2020
Opening balance | 1,282 | 1,181 | 1,580 | 92 | 296 | 299
Unrealised revaluations | -118 | 94 | -337 | -406 | -164 | 31
Realised gains/losses transferred to the statement of profit or loss |  |  |  | -25 | -40 | -33
Realised revaluations transferred to retained earnings | 23 | 6 | -1 |  |  |
Other changes |  |  | -62 |  |  |
Closing balance | 1,187 | 1,282 | 1,181 | -339 | 92 | 296

Equity securities at FVOCI
In 2022, the unrealised revaluation of EUR -118 million (2021: 94 million and 2020: -337 million) includes
revaluation of shares in Bank of Beijing for EUR -86 million(2021: 38 million and 2020: -339 million).
In 2020, Other changes of EUR -62 million is related to prior years revaluations of Visa shares, which are
reclassified to Financial assets at fair value through profit or loss and for which the unrealised revaluation up
until 2020 is transferred to retained earnings.
Cash flow hedge
ING mainly hedges floating rate lending with interest rate swaps. Due to an increase in yield curves in 2022
the interest rate swaps had a negative revaluation of EUR -2,901 million which is recognised in the cash flow
hedge reserve.

Changes in cash flow hedge and credit liability reserve
| Cash flow hedge | Credit liability
In EUR million | 2022 | 2021 | 2020 | 2022 | 2021 | 2020
Opening balance | -153 | 1,450 | 1,208 | -80 | -117 | -114
Changes in credit liability reserve |  |  |  | 165 | 37 | -19
Unrealised revaluations | -2,901 | -1,603 | 242 |  |  |
Realised revaluations transferred to retained earnings |  |  |  | -15 |  | 16
Other changes |  |  |  |  |  |
Closing balance | -3,055 | -153 | 1,450 | 70 | -80 | -117

Changes in Property in own use reserve |  |
| Property in own use
In EUR million | 2022 | 2021 | 2020
Opening balance | 208 | 221 | 253
Impact IAS 29 on opening balance 1 | -20 |  |
Unrealised revaluations | 15 | -2 | -7
Realised revaluations transferred to retained earnings | -26 | -11 | -26
Other changes |  |  |
Closing balance | 176 | 208 | 221

1 Impact of application of hyperinflation accounting under IAS 29 from 1 January 2022.
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 | 2022 | 2021 | 2020
Opening balance | -3,483 | -3,636 | -2,079
Impact IAS 29 on opening balance 1 | 647 |  |
Unrealised revaluations | -7 | -61 | 106
Realised gains/losses transferred to the statement of profit or loss | 4 |  | -1
Exchange rate differences | 444 | 214 | -1,662
Closing balance | -2,395 | -3,483 | -3,636

1 Impact of application of hyperinflation accounting under IAS 29 from 1 January 2022.
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 increase of unrealize d revaluations and Exchange rate differences of EUR 437
million is related to several currencies including USD (EUR 380 million), TRY (EUR 192 million including EUR
364 million IAS 29 indexation effect), GBP (EUR -73 million), PLN (EUR -49 million), CHF (EUR 41 million), AUD
(EUR -20 million), UAH (EUR -27 million) and other currencies (EUR -7 million).

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> 19 Equity
ING Bank Annual Report 2022 175
Share of associates and joint ventures and other reserves

Changes in share of associates, joint ventures and other reserves
In EUR million | 2022 | 2021 | 2020
Opening balance | 3,416 | 3,246 | 3,189
Result for the year | 161 | 191 | 94
Transfer to/from retained earnings | 26 | -21 | -37
Closing balance | 3,604 | 3,416 | 3,246

The Share of associates, joint ventures and other reserves includes non-distributable profits from associates
and joint ventures of EUR 797 m illion (2021: EUR 738 million). Other reserves includes a statutory reserve of
EUR 2,264 million (2021: EUR 2,103 million) related to the former Stichting Regio Bank and the former
Stichting Vakbondsspaarbank SPN and a legal reserve of EUR 540 million (2021: EUR 573 million) related to
own developed software.
Retained earnings

Changes in retained earnings
In EUR million | 2022 | 2021 | 2020
Opening balance | 29,778 | 28,273 | 25,857
Impact IAS 29 on opening balance 1 | -563 |  |
Transfer to/from other reserves | -8 | 26 | 108
Result for the year | 3,506 | 4,579 | 2,321
Dividend and other distributions | -6,277 | -3,125 | -43
Employee stock options and share plans | 27 | 28 | 23
Changes in composition of the group and other changes | -1 | -3 | 7
Closing balance | 26,462 | 29,778 | 28,273

1 Impact of application of hyperinflation accounting under IAS 29 from 1 January 2022.
Dividend
In 2022, a cash dividend and other cash distribution of EUR 6,277 million in total (2021: EUR 3,125 million
and 2020: EUR 43 million) was paid to the shareholder of ING Bank.
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 part related to the former Stichting Regio Bank and the former
Stichting Vakbondsspaarbank SPN.
As at 31 December 2022, an amount of EUR 2,264 million (2021: EUR 2,103 million) related to the former
Stichting Regio Bank and the former Stichting Vakbondsspaarbank SPN is included.
ING Bank N.V. is subject to legal restrictions regarding the amount of dividends it can pay to its shareholder.
Pursuant to the Dutch Civil Code, dividends can only be paid up to an
amount equal to the excess of the company’s own funds over the sum of the paid-up capital and reserves
required by law.
Moreover, ING Bank N.V.’s ability to pay dividends is dependent on the dividend payment ability of its
subsidiaries, associates and joint ventures. ING Bank N.V. is legally required to create a non-distributable
reserve insofar as profits of its subsidiaries, associates and joint ventures are subject to dividend payment
restrictions which apply to those subsidiaries, associates and joint ventures themselves.
Non distributable reserves, determined in accordance with the financial reporting requirements
included in Part 9 of Book 2 of the Dutch Civil Code, from ING Bank’s subsidiaries, associates and joint
amounts to EUR 8,408 million (2021: 8,205 million).
Furthermore there are restrictions to the ability of subsidiaries, associates and joint ventures to distribute
reserves to ING Bank N.V. as a result of minimum capital requirements that are imposed by industry
regulators in the countries in which the subsidiaries operate.
In addition to the legal and regulatory restrictions on distributing dividends from subsidiaries, associates and
joint ventures to ING Bank N.V. there are various other considerations and limitations that are taken into
account in determining the appropriate levels of equity in the Bank’s subsidiaries, associates and joint
ventures. These considerations and limitations include, but are not restricted to, minimum capital
requirements that are imposed by industry regulators in the countries in which the subsidiaries, associates
and joint ventures operate, or other limitations which may exist in certain countries and may or may not be
temporary in nature. It is not possible to disclose a reliable quantification of these limitations. For an
overview of the minimal capital requirements of ING Bank refer to the ‘Capital Management’ section.
Without prejudice to the authority of the Executive Board to allocate profits to reserves and to the fact that
the shares are the most junior securities issued by ING Bank N.V., no specific dividend payment restrictions
with respect to the shares exist.
Furthermore, ING Bank N.V. is subject to legal restrictions with respect to repayment of capital to Its
shareholder. Pursuant to the Dutch Civil Code, capital may only be repaid if none of ING Bank N.V.’s creditors
opposes such a repayment within two months following the announcement of a resolution to that effect.

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> 19 Equity
ING Bank Annual Report 2022 176
Notes to the Consolidated statement of profit or loss
20 Net interest income

Net interest income
in EUR million | 2022 | 2021 | 2020 |  |  | 2022 | 2021 | 2020
Interest income on loans | 18,537 | 13,979 | 15,766 |  | Interest expense on deposits from banks | 903 | 109 | 177
Interest income on financial assets at fair value through OCI | 510 | 346 | 512 |  | Interest expense on customer deposits | 4,133 | 1,999 | 2,022
Interest income on debt securities at amortised cost | 591 | 468 | 508 |  | Interest expense on debt securities in issue | 859 | 597 | 1,145
Interest income on non-trading derivatives (hedge accounting) | 4,011 | 2,361 | 3,392 |  | Interest expense on subordinated loans | 646 | 573 | 613
Negative interest on liabilities | 892 | 1,502 | 686 |  | Negative interest on assets | 285 | 572 | 353
Total interest income using effective interest rate method | 24,541 | 18,657 | 20,865 |  | Interest expense on non-trading derivatives (hedge accounting) | 4,144 | 1,700 | 3,198
|  |  |  |  | Total interest expense using effective interest rate method | 10,969 | 5,550 | 7,507
Interest income on financial assets at fair value through profit or loss | 1,444 | 435 | 658 |  |  |  |  |
Interest income on non-trading derivatives (no hedge accounting) | 2,390 | 2,025 | 1,156 |  | Interest expense on financial liabilities at fair value through profit or loss | 1,237 | 304 | 514
Interest income other | 101 | 14 | 31 |  | Interest expense on non-trading derivatives (no hedge accounting) | 2,411 | 1,605 | 1,029
Total other interest income | 3,935 | 2,474 | 1,846 |  | Interest expense on lease liabilities | 15 | 14 | 18
Total interest income | 28,476 | 21,131 | 22,711 |  | Interest expense other | 98 | 43 | 42
|  |  |  |  | Total other interest expense | 3,761 | 1,966 | 1,603
|  |  |  |  | Total interest expense | 14,730 | 7,516 | 9,110
|  |  |  |  | Net interest income | 13,745 | 13,615 | 13,600

Total net interest income amounts to EUR 13,745 million (2021: EUR 13,615 million). Despite a one-off
impact related to credit moratoria in Poland (EUR -343 million), net interest income is increasing: a reflection
of the changing interest rate environment which reprices faster on the asset side than the liability side of
the balance sheet.
Negative interest on liabilities in 2022, amounting to EUR 892 million (2021: EUR 1,502 million) includes ECB
funding rate benefit from the TLTRO III programme of EUR 314 million (2021: EUR 808 million).
As ING met the 2020-2021 TLTRO III lending growth targets, the funding rate for TLTRO III amounted -100
bps during the special interest periods between 24 June 2020 and 23 June 2022 (of which -50 bps was
unconditional and -50 bps was conditional). As a result, -100 bps was the applicable TLTRO III rate
throughout the entire 2021 and the first half of 2022 until 23 June 2022.
In October 2022, the ECB changed the terms of the unconditional interest related to the periods before and
after the special interest periods. Interest rate before 24 June 2020 and from 23 June 2022 until 22
November 2022 is now based on the average Deposit Facility (DF) rate during the period between the draw
down date until 22 November 2022. As ING participated in series 3, 4 and 7 of TLTRO III, 3 different average
DF rates apply to those and comprised -37 bps, -36 bps and -29 bps, respectively.
Under the revised terms of TLTRO III, interest rate after 22 November 2022 until maturity is now based on
the average DF rate during that period instead of the average DF rate for the whole life of TLTRO III, as it was

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> 20 Net interest income
ING Bank Annual Report 2022 177
contemplated previously. The DF rate was at 150 bps between 22 November 2022 and 21 December 2022
and at 200 bps thereafter until the end of 2022.
Interest income recognised in 2022 within ‘Negative interest on liabilities’ is based on the above updated
terms of TLTRO.
Furthermore, the above change in terms caused the discontinuation of the fair value hedge accounting
relationship on TLTRO III, impacting net interest income for an amount of EUR -483 million (refer to Note 39
'Derivatives and hedge accounting' for more details).
21 Net fee and commission income

Net fee and commission income
in EUR million | 2022 | 2021 | 2020
Fee and commission income |  |  |
Payment Services | 1,888 | 1,661 | 1,566
Securities business | 632 | 853 | 700
Insurance and other broking | 682 | 734 | 705
Portfolio management | 600 | 617 | 525
Lending business | 556 | 477 | 368
Financial guarantees and other commitments | 496 | 458 | 364
Other | 232 | 204 | 286
Total fee and commission income | 5,085 | 5,004 | 4,514
Fee and commission expenses |  |  |
Payment Services | 600 | 563 | 611
Securities business | 160 | 164 | 133
Distribution of products (Externally) | 555 | 591 | 548
Other | 184 | 169 | 211
Total fee and commission expenses | 1,499 | 1,487 | 1,503
Net fee and commission income | 3,586 | 3,517 | 3,011

1 ING changed the presentation of net fee and commission income as of 2021. The comparative figure for 2020 has been updated
accordingly. The reclassification does not affect the total amount of Net Fee and Commission Income.
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 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.
All of ING’s net fee and commission income are in scope of IFRS 15 ‘Revenue from Contracts with
Customers’. Reference is made to Note 31 'Segments' which includes net fee and commission income, as
reported to the Management Board Banking, disaggregated by line of business and by geographical
segment.
22 Valuation results and net trading income

Valuation results and net trading income
in EUR million | 2022 | 2021 | 2020
Securities trading results | -356 | 787 | -500
Derivatives trading results | 11 | -554 | 701
Other trading results | 71 | 84 | 72
Change in fair value of derivatives relating to |  |  |
– fair value hedges | 5,265 | -85 | 246
– cash flow hedges (ineffective portion) | 20 | 1 | -5
– other non-trading derivatives | 1,164 | -53 | 222
Change in fair value of assets and liabilities (hedged items) | -5,150 | 113 | -183
Valuation results on assets and liabilities designated at FVPL (excluding trading) | 444 | -12 | -121
Foreign exchange transactions results | 33 | 566 | 422
| 1,503 | 847 | 852

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 2022 the market has been affected by
a significant increase in interest rates volatility, interest rate hikes across EU, and US and a steady fall of the
EUR value and appreciation of USD.
Securities trading results includes the results of market making in instruments such as government
securities, equity securities, corporate debt securities, money-market instruments. Derivatives trading

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> 20 Net interest income
ING Bank Annual Report 2022 178
results includes the results of derivatives such as interest rate swaps, options, futures, and forward
contracts.
Trading gains and losses relating to trading securities still held as at 31 December 2022 amount to EUR -157
million (2021: EUR -268 million; 2020: EUR -690 million).
The majority of the risks involved in security and currency trading is economically hedged with derivatives.
The securities trading results are partly offset by results on these derivatives. The result of these derivatives
is included in Derivatives trading results.
Other trading results include the results of trading loans and funds entrusted.
Foreign exchange transactions results include gains and losses from spot and forward contracts, options,
futures, and translated foreign currency assets and liabilities. The result on currency trading is included in
foreign exchange transactions results.
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 Bank’s trading books are managed based on internal limits and comprise a mix of
products with results which could be offset. 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 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.
‘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. During 2022, the interest rate movements
significantly affected the fair value changes of other non-trading derivatives as well as 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 is 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 CollV A). Spreads widened in 2022 compared to 2021 and the fair value changes increased.
In 2022, Derivatives trading results include EUR 43 million CVA/DVA adjustments on trading derivatives
(2021: EUR 98 million; 2020: EUR 17 million).
Valuation results on assets and liabilities designated at fair value through profit or loss (excluding trading)’
include fair value changes on financial assets and financial liabilities driven by changed market conditions.
Refer to Note 4 'Financial assets at fair value through profit or loss' and to Note 14 'Financial liabilities at fair
value through profit or loss'.
In addition, ‘Valuation results on assets and liabilities designated at fair value through profit or loss
(excluding trading)’ include fair value adjustments on own issued notes amounting to EUR 709 million (2021:
EUR 56 million; 2020: EUR 8 million).
Interest income from trading assets in 2022 amounted to EUR 18,593 million (2021: EUR 13,737 million;
2020: EUR 13,412 million). Interest expense from trading liabilities in 2022 amounted to EUR 18,765 million
(2021: EUR 14,079 million; 2020: EUR 13,052 million).
23 Investment income

Investment income
in EUR million | 2022 | 2021 | 2020
Dividend income | 149 | 122 | 107
Realised gains/losses on disposal of debt instruments measured at FVOCI | 32 | 45 | 44
Income from and fair value gains/losses on investment properties | -1 |  | 1
| 181 | 167 | 152

In 2022, 2021 and 2020 dividend income mainly consists of dividend received from ING’s equity stake in
Bank of Beijing.

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> 22 Valuation results and net trading income
ING Bank Annual Report 2022 179
24 Net result on derecognition of financial assets measured at amortised
cost

Net result on derecognition of financial assets measured at amortised cost
in EUR million | 2022 | 2021 | 2020
Loans at amortised cost |  | 1 | 4
Securities at amortised cost | -5 | -1 | 185
| -5 | 0 | 189

In 2020, driven by exceptional market circumstances in the first quarter, ING realised a profit on the sale of
debt securities at amortised cost of EUR 186 million.
25 Other net income
In 2022, Other net income of EUR -369 million (2021: EUR 230 million; 2020: EUR 12 million) includes EUR
-333 million net monetary loss reflecting the IAS 29 hyperinflation impact in Turkey related to the
indexation of Turkey’s statement of financial position and statement of profit or loss and is directly
recognized in equity (retained earnings). Other net income as per 31 December 2022 also includes an
amount of EUR -307 million loss recognised to unwind a macro fair value hedge of deposits, which led to a
timing difference with expected fair value.
Furthermore, it includes the proceeds of the agreement with Boursorama after our exit from the retail
banking market in France of EUR 125 million and a gain of EUR 67 million from a legacy entity in Retail
Belgium.
In 2021, other net income included the recognition of EUR 72 million relating to a better than expected
recovery of the insolvency of a financial institution in the Netherlands and EUR 34 million proceeds of the
agreement with Raiffeisenbank due to the withdrawal from the retail banking market in the Czech Republic.
Furthermore, it includes the positive recovery of defaulted receivables of EUR 25 million (2020: EUR 27
million).
In 2020, Other net income is impacted by positive and negative non-recurring results, including a loss of EUR
-58 million following a settlement with the Australian Tax Authorities related to former insurance activities,
that were fully indemnified by NN Group. This was offset by a tax profit for the same amount resulting from
the release of the provision for uncertain tax positions in current tax liabilities.
26 Staff Expenses

Staff expenses
in EUR million | 2022 | 2021 | 2020
Salaries | 4,145 | 4,011 | 3,751
Pension costs and other staff-related benefit costs | 390 | 408 | 395
Social security costs | 584 | 563 | 538
Share-based compensation arrangements | 27 | 28 | 23
External employees | 738 | 699 | 881
Education | 47 | 47 | 43
Other staff costs | 222 | 182 | 186
| 6,152 | 5,938 | 5,817

Share-based compensation arrangements include EUR 25 million (2021: EUR 29 million; 2020: EUR 17
million) relating to equity-settled share-based payment arrangements and EUR 1 million (2021: EUR 2
million; 2020: EUR 2 million) relating to cash-settled share-based payment arrangements.

Number of employees
| Netherlands | Rest of the world | Total
| 2022 | 2021 | 2020 | 2022 | 2021 | 2020 | 2022 | 2021 | 2020
Total average number of internal employees at full time equivalent basis | 14,488 | 15,138 | 15,201 | 43,081 | 42,523 | 40,701 | 57,569 | 57,660 | 55,901

Remuneration of senior management, Management Board Banking and Supervisory
Board
Reference is made to Note 46 'Related parties'.
Share plans and Stock Options
ING grants various types of share awards, namely deferred shares, performance shares and upfront shares,
which form part of the variable remuneration offering via the Long-term Sustainable Performance Plan
(LSPP). The entitlement to the LSPP share awards is granted conditionally. If the participant remains in
employment for an uninterrupted period between the grant date and the vesting date, the entitlement
becomes unconditional, with the exception of the upfront shares which are immediately vested upon grant.
Upfront and deferred shares awarded to the Management Board members of ING Bank as well as identified
staff, have a retention obligation that must be adhered to upon vesting, typically a minimum retention of 12

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> 22 Valuation results and net trading income
ING Bank Annual Report 2022 180
months applies. ING has the authority to apply a holdback to awarded but unvested shares and a clawback
to vested shares
The share awards granted in 2022 relate to the performance year 2021. In 2022, 55,651 share awards
(2021: 0; 2020: 63,837) were granted to the members of the Executive Board, and 137,506 share awards
(2021: 123,750; 2020: 186,176) were granted to the Management Board Banking. To senior management
and other employees 2,913,926 share awards (2021: 3,267,372; 2020: 3,678,775) were granted.

Changes in share awards
| Share awards (in numbers) | Weighted average grant date fair values (in euros)
| 2022 | 2021 | 2020 | 2022 | 2021 | 2020
Opening balance | 3,672,659 | 3,876,206 | 3,855,035 | 7.60 | 7.25 | 11.14
Granted | 3,107,083 | 3,391,122 | 3,864,951 | 8.99 | 9.69 | 5.12
Vested | -2,962,698 | -3,459,163 | -3,690,340 | 8.60 | 9.25 | 9.01
Forfeited | -119,502 | -135,506 | -153,440 | 7.63 | 7.61 | 8.55
Closing balance | 3,697,542 | 3,672,659 | 3,876,206 | 7.97 | 7.60 | 7.25

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 2022, total unrecognised compensation costs related to share awards amount to EUR 13
million (2021: EUR 13 million; 2020: EUR 10 million). These costs are expected to be recognised over a
weighted average period of 1.9 years (2021: 1.7 years; 2020: 1.6 years).
27 Other operating expenses

Other operating expenses
in EUR million | 2022 | 2021 | 2020
Regulatory costs | 1,250 | 1,265 | 1,105
Audit and non-audit services | 31 | 34 | 29
IT related expenses | 818 | 781 | 812
Advertising and public relations | 331 | 305 | 335
External advisory fees | 306 | 297 | 413
Office expenses | 273 | 280 | 320
Travel and accommodation expenses | 91 | 52 | 68
Contributions and subscriptions | 109 | 112 | 109
Postal charges | 31 | 38 | 38
Depreciation of property and equipment | 485 | 573 | 578
Amortisation of intangible assets | 226 | 261 | 251
(Reversals of) impairments of property and equipment | 19 | 26 | 43
(Reversals of) impairments of intangible assets | 60 | 95 | 515
Addition to / (unused amounts reversed of) provision for reorganisations | 170 | 214 | 149
Addition to / (unused amounts reversed of) other provisions | 117 | 254 | 39
Other | 723 | 669 | 541
| 5,040 | 5,257 | 5,344

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 further information on addition to (unused amounts reversed of) provision for reorganisations refer to
Note 15 'Provisions' and for further 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 2022, are
contributions to DGS of EUR 425 million (2021: EUR 435 million; 2020: EUR 413 million) mainly related to the
Netherlands, Germany, Belgium, and Poland and contributions to the SRF and local resolution funds of EUR
354 million (2021: EUR 308 million; 2020: EUR 277 million). In 2022 local bank taxes decreased by EUR 51
million from EUR 522 million in 2021 to EUR 470 million (2020: EUR 414 million).
In 2022, ING Bank Slaski, together with seven other Polish banks, has established an Institutional Protection
Scheme (IPS). The fund can be used to ensure the liquidity and solvency of each of its participants, and to

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> 26 Staff Expenses
ING Bank Annual Report 2022 181
assist in the resolution of participating and non-participating banks. The contribution by ING amounts to EUR
99 million and is recognized as regulatory costs (DGS).
Audit and non-audit services
Audit and non-audit services include fees for services provided by the Bank’s auditors and remained stable
for 2022. The increase of audit fees in 2021 follow from the re-appointment of the current auditor that also
triggered a revision of the audit fees.
Notes to the consolidated statement of cash flows
28 Net cash flow from operating activities
The table below shows a detailed overview of the net cash flow from operating activities.

Cash flows from operating activities
in EUR million | 2022 | 2021 | 2020
Cash flows from operating activities |  |  |
Result before tax | 5,493 | 6,774 | 3,810
Adjusted for: | - Depreciation and amortisation | 711 | 834 | 829
| - Addition to loan loss provisions | 1,861 | 516 | 2,675
| - Other non-cash items included in result before tax | 5,519 | 413 | 1,259
Taxation paid |  | -1,489 | -1,871 | -1,735
Changes in: | – Loans and advances to banks, not available on demand | -5,836 | 262 | 10,031
| – Deposits from banks, not payable on demand | -26,976 | 8,438 | 43,044
| Net change in loans and advances to/ from banks, not available/ payable on demand | -32,813 | 8,700 | 53,076
| – Trading assets | -5,485 | -29 | -2,095
| – Trading liabilities | 11,975 | -5,596 | 4,667
| Net change in Trading assets and Trading liabilities | 6,490 | -5,624 | 2,571
| Loans and advances to customers | -19,306 | -27,772 | 2,888
| Customer deposits | 34,005 | 18,339 | 40,576
| – Non–trading derivatives | -5,469 | 290 | -1,420
| – Assets designated at fair value through profit or loss | 56 | -1,905 | -1,371
| – Assets mandatorily at fair value through profit or loss | -4,143 | 1,650 | -1,963
| – Other assets | -2,861 | -121 | 1,092
| – Other financial liabilities at fair value through profit or loss | 9,843 | -6,795 | 1,190
| – Provisions and other liabilities | -667 | -1,298 | -298
| Other | -3,241 | -8,179 | -2,770
Net cash flow from/(used in) operating activities | -2,769 | -7,869 | 103,179

29 Changes in liabilities arising from financing activities

Changes in liabilities arising from financing activities
| Debt securities in issue | Subordinated Loans | Lease liabilities | Total Liabilities from financing activities
in EUR million | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Opening balance | 57,443 | 55,573 | 16,719 | 15,897 | 1,220 | 1,339 | 75,382 | 72,809
Cashflows: |  |  |  |  |  |  |  |
Additions | 81,636 | 77,298 | 983 | 3,169 |  |  | 82,620 | 80,467
Redemptions / Disposals | -78,609 | -76,150 | -1,090 | -2,538 | -296 | -301 | -79,995 | -78,989
Non cash changes: |  |  |  |  |  |  |  |
Amortisation | 281 | -22 | 31 | 8 | 15 | 14 | 328 |
Other | -66 | -120 | 8 | -27 | 239 | 161 | 180 | 14
Changes in unrealised revaluations | -3,746 | -962 | -1,470 | -414 |  |  | -5,216 | -1,376
Foreign exchange movement | 1,135 | 1,827 | 608 | 624 | -4 | 6 | 1,739 | 2,456
Closing balance | 58,075 | 57,443 | 15,789 | 16,719 | 1,174 | 1,220 | 75,038 | 75,382

Part of Debt securities in issue and subordinated loans are in 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 paragraph 'fair value hedge accounting' in Note 36 'Derivatives and
hedge accounting'.
30 Cash and cash equivalents

Cash and cash equivalents
in EUR million | 2022 | 2021 | 2020
Treasury bills and other eligible bills | 1 | 23 |
Deposits from banks/Loans and advances to banks | 7,775 | 1,121 | 477
Cash and balances with central banks | 87,614 | 106,520 | 111,087
Cash and cash equivalents at end of year | 95,390 | 107,664 | 111,565

Treasury bills and other eligible bills included in cash and cash equivalents
in EUR million | 2022 | 2021 | 2020
Treasury bills and other eligible bills included in trading assets | 0 | 0 | 0
Treasury bills and other eligible bills included in FVOCI | 0 | 0 | 0
Treasury bills and other eligible bills included in securities at AC | 0 | 23 | 0
| 1 | 23 | 0

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> 27 Other operating expenses
ING Bank Annual Report 2022 182

Deposits from banks/Loans and advances to banks
in EUR million | 2022 | 2021 | 2020
Included in cash and cash equivalents: |  |  |
– Deposits from banks | -6,172 | -7,059 | -8,788
– Loans and advances to banks | 13,947 | 8,180 | 9,265
| 7,775 | 1,121 | 477
Not included in cash and cash equivalents: |  |  |
– Deposits from banks | -50,460 | -78,033 | -69,310
– Loans and advances to banks | 21,156 | 15,411 | 16,098
| -29,304 | -62,621 | -53,212
Total as included in the statement of financial position: |  |  |
– Deposits from banks | -56,632 | -85,092 | -78,098
– Loans and advances to banks | 35,103 | 23,591 | 25,363
| -21,529 | -61,501 | -52,734

Cash and cash equivalents includes deposits from banks and loans and advances to banks that are on
demand.
Included in Cash and cash equivalents, are minimum mandatory reserve deposits to be held with 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.
Segment reporting
31 Segments
ING Bank’s segments are based on the internal reporting structure by lines of business.
The Management Board Banking of ING Bank (Chief Operating Decision Maker (CODM)) set the performance
targets, approve and monitor the budgets prepared by the business lines. Business lines formulate strategic,
commercial, and financial plans in conformity with the strategy and performance targets set by the CODM.
Recognition and measurement of segment results are in line with the accounting policies as described in
Note 1 ‘Basis of preparation and significant accounting policies’. 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.
The following table specifies the segments by line of business and 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 (Market Leaders) | Income from retail and private banking activities in the Netherlands, including the SME and mid-corporate segments, and the Real Estate Finance portfolio related to Dutch domestic mid-corporates. The main products offered are current and savings accounts, business lending, mortgages and other consumer lending in the Netherlands.
Retail Belgium (Market Leaders) | Income from retail and private banking activities in Belgium (including Luxembourg), including the SME and mid-corporate segments. The main products offered are similar to those in the Netherlands.
Retail Germany (Challengers and Growth Markets) | Income from retail and private banking activities in Germany (including Austria up to and including 2021, after which ING left the retail market). The main products offered are current and savings accounts, mortgages and other customer lending.
Retail Other (Challengers and Growth Markets) | Income from retail banking activities in the rest of the world, including the SME and mid-corporate segments in specific countries. The main products offered are similar to those in the Netherlands.
Wholesale Banking | Income from wholesale banking activities. The main products are: lending, debt capital markets, working capital solutions, export finance, daily banking solutions, treasury and risk solutions, and corporate finance.

Specification of geographical split of the segments
Geographical split of the segments | Main countries
The Netherlands |
Belgium | Including Luxembourg
Germany | Including Retail Banking Austria 1
Other Challengers | Australia, Retail Banking Czech Republic 1, France 2, Italy, Spain, Portugal
Growth Markets | Poland, Romania, Turkey, Philippines 2 and Asian stakes
Wholesale Banking Rest of World | UK, Americas, Asia and other countries in Central and Eastern Europe 3
Other | Corporate Line

1 Retail Banking Austria and Retail Banking Czech Republic up to and including 2021, after which ING left the retail market
2 In 2022, ING discontinued its retail activities in France and the Philippines.
3 As from 2022, Wholesale Banking Austria as well as Wholesale Banking Czech Republic are recorded in Wholesale Banking Rest of
World. Previously these financials were reported in Germany and Other Challengers respectively.

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> 30 Cash and cash equivalents
ING Bank Annual Report 2022 183
ING Bank monitors and evaluates the performance of ING Bank at a consolidated level and by segment. The
Management Board Banking consider this to be relevant to an understanding of the Bank’s financial
performance, because it allows investors to understand the primary method used by management to
evaluate the Bank’s operating performance and make decisions about allocating resources.
ING Bank reconciles the total segment results to the total result using Corporate Line. The Corporate Line is a
reflection of capital management activities and certain income and expenses that are not allocated to the
banking businesses. Furthermore, the Corporate Line includes the isolated legacy costs (mainly negative
interest results) caused by the replacement of short-term funding with long-term funding during 2013 and
2014. 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. In 2022, results in the Corporate Line were impacted by the application of
hyperinflation accounting in the consolidation of our subsidiary in Turkey.
Income in 2022 included a hyperinflation accounting impact of EUR -279 million and a net TLTRO impact of
EUR 16 million, while previous year was supported by a EUR 143 million net TLTRO impact and the
recognition of a EUR 72 million receivable related to the insolvency of a financial institution. The decline was
partly compensated by higher income from foreign currency ratio hedging, mainly on US dollar and the
Polish zloty. Expenses in 2022 included a hyperinflation impact of EUR 30 million and a EUR 32 million
impairment loss related to the goodwill allocated to Turkey, while previous year had included EUR 87 million
of regulatory costs due to an incidental 50% increase in the Dutch bank tax.
The information presented in this note is in line with the information presented to the Management Board
Banking of ING Bank.
This note does not provide information on the types of products and services from which each reportable
segment derives its revenues, as this is not reported internally and is therefore not readily available.

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> 31 Segments
ING Bank Annual Report 2022 184

Segments by line of business
12 month period | 2022 |  |  |  |  |  |  | 2021 |  |  |  |  |  |  | 2020 |  |  |  |  |  |
in EUR million | Retail Nether- lands | Retail Belgium | Retail Germany | Retail Other 1 | Wholesale Banking | Corporate Line | Total | Retail Nether- lands | Retail Belgium | Retail Germany 2 | Retail Other 2 | Wholesale Banking | Corporate Line | Total | Retail Nether- lands | Retail Belgium | Retail Germany | Retail Other | Wholesale Banking | Corporate Line | Total
Income |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
– Net interest income | 2,888 | 1,668 | 1,666 | 2,726 | 4,260 | 539 | 13,745 | 3,290 | 1,747 | 1,447 | 2,712 | 4,151 | 268 | 13,615 | 3,511 | 1,816 | 1,587 | 2,760 | 3,718 | 208 | 13,600
– Net fee and commission income | 892 | 511 | 437 | 535 | 1,217 | -6 | 3,586 | 771 | 519 | 497 | 530 | 1,197 | 3 | 3,517 | 681 | 413 | 437 | 412 | 1,069 | -1 | 3,011
– Total investment and other income | 417 | -32 | 69 | 402 | 849 | -490 | 1,215 | 201 | 209 | 65 | 361 | 568 | -51 | 1,354 | 279 | 145 | 93 | 89 | 609 | -180 | 1,034
Total income | 4,196 | 2,147 | 2,172 | 3,663 | 6,325 | 43 | 18,546 | 4,262 | 2,475 | 2,009 | 3,602 | 5,916 | 221 | 18,485 | 4,471 | 2,373 | 2,117 | 3,261 | 5,396 | 27 | 17,645
Expenditure |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
– Operating expenses | 2,115 | 1,786 | 1,140 | 2,516 | 3,114 | 523 | 11,193 | 2,403 | 1,667 | 1,174 | 2,452 | 2,926 | 574 | 11,195 | 2,236 | 1,737 | 1,110 | 2,469 | 3,218 | 390 | 11,160
– Addition to loan loss provisions | 67 | 139 | 131 | 302 | 1,220 | 2 | 1,861 | -76 | 225 | 49 | 202 | 117 |  | 516 | 157 | 514 | 57 | 593 | 1,351 | 3 | 2,675
Total expenses | 2,182 | 1,924 | 1,271 | 2,818 | 4,334 | 525 | 13,053 | 2,326 | 1,892 | 1,223 | 2,654 | 3,042 | 574 | 11,711 | 2,393 | 2,251 | 1,167 | 3,063 | 4,568 | 393 | 13,835
Result before taxation | 2,014 | 223 | 901 | 845 | 1,991 | -482 | 5,493 | 1,936 | 583 | 786 | 949 | 2,874 | -353 | 6,774 | 2,078 | 122 | 950 | 199 | 827 | -366 | 3,810
Taxation | 540 | 72 | 202 | 257 | 581 | 71 | 1,723 | 499 | 146 | 252 | 212 | 703 | 64 | 1,876 | 523 | 51 | 331 | 105 | 295 | 13 | 1,317
Non-controlling interests |  |  | 3 | 47 | 52 | 1 | 102 |  |  | 4 | 98 | 26 |  | 128 | -1 |  | 4 | 55 | 20 |  | 78
Net result IFRS | 1,474 | 151 | 696 | 541 | 1,358 | -553 | 3,667 | 1,437 | 437 | 529 | 639 | 2,144 | -417 | 4,770 | 1,556 | 71 | 615 | 39 | 512 | -378 | 2,415

1 In 2022, ING discontinued its retail activities in France and the Philippines.
2 In the fourth quarter of 2021, ING exited from the retail banking markets in Austria and the Czech Republic.

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> 31 Segments
ING Bank Annual Report 2022 185

Geographical split of the segments
12 month period | 2022 |  |  |  |  |  |  |  | 2021 |  |  |  |  |  |  |  | 2020 |  |  |  |  |  |  |
in EUR million | Nether -lands | Belgium | Ger- many | Other Challen gers 1 | Growth markets 1 | Whole- sale Banking Rest of World | Other | Total | Nether -lands | Belgium | Ger- many 2,3 | Other Challen gers 2,3 | Growth markets | Whole- sale Banking Rest of World 3 | Other | Total | Nether- lands | Belgium | Ger- many 3 | Other Challen gers 3 | Growth markets | Whole- sale Banking Rest of World 3 | Other | Total
Income |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
– Net interest income | 3,782 | 2,065 | 2,126 | 1,988 | 1,464 | 1,786 | 534 | 13,745 | 4,068 | 2,109 | 1,938 | 1,833 | 1,532 | 1,866 | 269 | 13,615 | 4,178 | 2,116 | 2,083 | 1,744 | 1,578 | 1,697 | 204 | 13,600
– Net fee and commission income | 1,171 | 714 | 494 | 312 | 376 | 526 | -6 | 3,586 | 1,070 | 717 | 523 | 327 | 351 | 525 | 3 | 3,517 | 981 | 583 | 466 | 271 | 286 | 425 | -1 | 3,011
– Total investment and other income | 577 | -14 | 94 | 192 | 416 | 435 | -485 | 1,215 | 314 | 265 | 118 | 80 | 446 | 182 | -51 | 1,354 | 398 | 196 | 125 | 28 | 215 | 244 | -172 | 1,034
Total income | 5,531 | 2,765 | 2,714 | 2,491 | 2,256 | 2,746 | 43 | 18,546 | 5,452 | 3,092 | 2,578 | 2,240 | 2,330 | 2,574 | 221 | 18,485 | 5,557 | 2,896 | 2,674 | 2,043 | 2,078 | 2,366 | 31 | 17,645
Expenditure |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
– Operating expenses | 3,001 | 2,120 | 1,318 | 1,456 | 1,444 | 1,331 | 523 | 11,193 | 3,279 | 1,960 | 1,339 | 1,516 | 1,276 | 1,251 | 574 | 11,195 | 3,347 | 2,037 | 1,263 | 1,536 | 1,272 | 1,310 | 395 | 11,160
– Addition to loan loss provisions | 181 | 230 | 460 | 241 | 230 | 517 | 2 | 1,861 | 28 | 184 | 118 | 100 | 110 | -23 |  | 516 | 421 | 589 | 267 | 297 | 412 | 685 | 3 | 2,675
Total expenses | 3,182 | 2,350 | 1,778 | 1,696 | 1,674 | 1,847 | 525 | 13,053 | 3,307 | 2,143 | 1,457 | 1,616 | 1,386 | 1,228 | 574 | 11,711 | 3,769 | 2,627 | 1,530 | 1,833 | 1,684 | 1,995 | 397 | 13,835
Result before taxation | 2,349 | 415 | 936 | 795 | 581 | 899 | -482 | 5,493 | 2,145 | 948 | 1,121 | 623 | 944 | 1,346 | -353 | 6,774 | 1,788 | 269 | 1,144 | 209 | 395 | 371 | -366 | 3,810
Retail Banking | 2,014 | 223 | 901 | 547 | 298 |  |  | 3,983 | 1,936 | 583 | 786 | 206 | 742 |  |  | 4,253 | 2,078 | 122 | 950 | -27 | 225 |  |  | 3,348
Wholesale Banking | 335 | 192 | 34 | 248 | 284 | 899 |  | 1,991 | 209 | 365 | 336 | 417 | 202 | 1,346 |  | 2,874 | -290 | 147 | 194 | 236 | 169 | 371 |  | 827
Corporate Line |  |  |  |  |  |  | -482 | -482 |  |  |  |  |  |  | -353 | -353 |  |  |  |  |  |  | -366 | -366
Result before taxation | 2,349 | 415 | 936 | 795 | 581 | 899 | -482 | 5,493 | 2,145 | 948 | 1,121 | 623 | 944 | 1,346 | -353 | 6,774 | 1,788 | 269 | 1,144 | 209 | 395 | 371 | -366 | 3,810
Taxation | 658 | 114 | 297 | 255 | 156 | 189 | 55 | 1,723 | 556 | 240 | 358 | 185 | 178 | 296 | 63 | 1,876 | 518 | 89 | 380 | 90 | 141 | 87 | 12 | 1,317
Non-controlling interests |  |  | 3 |  | 98 |  | 1 | 102 |  |  | 4 |  | 124 |  |  | 128 | -1 |  | 4 |  | 75 |  |  | 78
Net result IFRS | 1,691 | 301 | 636 | 540 | 327 | 710 | -538 | 3,667 | 1,589 | 708 | 759 | 438 | 641 | 1,050 | -415 | 4,770 | 1,271 | 180 | 760 | 119 | 178 | 284 | -378 | 2,415

1 In 2022, ING discontinued its retail activities France and the Philippines.
2 In the fourth quarter of 2021, ING exited from the retail banking markets in Austria and the Czech Republic.
3 As from 2022, Wholesale Banking Austria as well as Wholesale Banking Czech Republic are recorded in Wholesale Banking Rest of World. Previously these financials were reported in Germany and Other Challengers respectively. Historical figures have been adjusted.

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> 31 Segments
ING Bank Annual Report 2022 186
32 Information on geographical areas
ING Bank’s business lines operate in Seven main geographical areas: the Netherlands, Belgium, Rest of
Europe, North America, Latin America, Asia and Australia. A geographical area is a distinguishable
component of the Group engaged in providing products or services within a particular economic
environment that is subject to risks and returns that are different from those of geographical areas
operating in other economic environments. The geographical analyses are based on the location of the
office from which the transactions are originated and do not include countries where ING only has
representation offices. The Netherlands is ING Bank’s country of domicile.
In order to increase ING Bank’s tax transparency, additional financial information on a per country basis has
been included in this disclosure: Tax paid represents all income tax paid to and/or received from tax
authorities in the current year, irrespective of the fiscal year to which these payments or refunds relate.
Total assets by country does not include intercompany balances and reconciles to the total assets in the
consolidated statement of financial position of ING Bank. In December 2021 the OECD released a draft
legislative framework that is designed to ensure, from 2024 onwards, that large multinational groups pay
income tax at a minimum rate of 15% in all the countries they are present in. At the date when these
financial statements were authorized for issue, of all the countries ING is present in, only South Korea has
enacted legislation to this effect. At 31 December 2022 ING Bank does not have sufficient information to
determine the future potential quantitative impact.
The table below provide additional information, for the years 2022, 2021 and 2020 respectively, on names
of principal subsidiaries and branches, nature of main activities and 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
|  |  |  | 2022 | 2021 | 2020 | 2022 | 2021 | 2020 | 2022 | 2021 | 2020 | 2022 | 2021 | 2020 | 2022 | 2021 | 2020 | 2022 | 2021 | 2020
Netherlands | Netherlands | ING Bank N.V. | Wholesale / Retail | 14,488 | 15,138 | 15,201 | 5,017 | 5,671 | 5,422 | 308,931 | 301,446 | 286,119 | 1,069 | 1,442 | 934 | 418 | 506 | 493 | 392 | 428 | 591
Belgium | Belgium | ING België N.V. | Wholesale / Retail | 6,582 | 6,965 | 7,397 | 2,353 | 2,719 | 2,581 | 127,085 | 130,687 | 133,843 | 286 | 808 | 156 | 81 | 204 | 61 | 152 | 174 | 66
| Luxembourg | ING Luxembourg S.A. | Wholesale / Retail | 927 | 856 | 855 | 422 | 338 | 300 | 18,351 | 20,452 | 15,335 | 180 | 161 | 120 | 45 | 41 | 30 | 37 | 20 | 24
Rest of Europe | Poland 1 | ING Bank Slaski S.A | Wholesale / Retail | 11,130 | 10,674 | 9,425 | 1,652 | 1,509 | 1,399 | 45,598 | 43,888 | 40,928 | 544 | 660 | 438 | 143 | 154 | 131 | -23 | 235 | 232
| Germany | ING DiBa A.G. | Wholesale / Retail | 5,573 | 5,521 | 5,059 | 2,815 | 2,387 | 2,545 | 161,997 | 159,805 | 162,935 | 1,039 | 1,012 | 1,065 | 328 | 338 | 364 | 189 | 493 | 409
| Romania 1 | Branch of ING Bank N.V. | Wholesale / Retail | 3,580 | 3,319 | 3,049 | 584 | 495 | 456 | 10,555 | 9,635 | 8,526 | 324 | 273 | 141 | 51 | 41 | 20 | 67 | 21 | 24
| Turkey | ING Bank A.S. | Wholesale / Retail | 3,076 | 3,338 | 3,724 | 64 | 335 | 420 | 5,400 | 5,818 | 7,316 | -143 | 144 | 125 | 65 | 35 | 27 | 79 | 33 | 25
| Spain | Branch of ING Bank N.V. | Wholesale / Retail | 1,439 | 1,380 | 1,228 | 877 | 743 | 679 | 32,262 | 32,559 | 29,899 | 299 | 212 | 104 | 98 | 57 | 37 | 101 | 59 | 52
| Italy | Branch of ING Bank N.V. | Wholesale / Retail | 1,118 | 1,099 | 1,025 | 345 | 335 | 337 | 14,152 | 13,983 | 13,747 | 63 | 73 | 44 | 22 | 25 | 24 | 2 | 2 | 2
| UK | Branch of ING Bank N.V. | Wholesale | 692 | 698 | 709 | 693 | 636 | 546 | 46,066 | 50,734 | 64,676 | 286 | 277 | 97 | 81 | 73 | 15 | 58 | 50 | 32
| France 2,3 | Branch of ING Bank N.V. | Wholesale | 600 | 764 | 737 | 372 | 271 | 266 | 8,934 | 12,381 | 11,570 | 44 | -107 | -43 | 12 | -27 | -10 | 22 | -7 | 9
| Russia | ING Bank (Eurasia) Z.A.O. | Wholesale | 272 | 281 | 297 | 246 | 38 | 51 | 2,783 | 898 | 1,035 | 128 | 3 | 3 | 9 | 0 | 0 | 21 | -7 | -3
| Czech Republic 4 | Branch of ING Bank N.V. | Wholesale | 137 | 285 | 355 | 78 | 121 | 83 | 3,192 | 2,894 | 3,851 | 38 | 54 | -3 | 6 | 12 | 0 | 13 | -2 | 4
| Hungary | Branch of ING Bank N.V. | Wholesale | 120 | 119 | 131 | 82 | 44 | 43 | 1,993 | 1,148 | 1,092 | 38 | 12 | 6 | 5 | 3 | 2 | 2 | 2 | 1
| Slovakia 1 | Branch of ING Bank N.V. | Wholesale | 1,129 | 983 | 878 | 15 | 15 | 18 | 391 | 352 | 385 | -1 | 3 | 7 | 1 | 0 | 3 | 0 | 2 | 1
| Ukraine | PJSC ING Bank Ukraine | Wholesale | 91 | 96 | 108 | 45 | 22 | 26 | 385 | 409 | 335 | 9 | 11 | 16 | 2 | 2 | 3 | 2 | 2 | 3
| Austria 4 | Branch of ING Bank N.V. | Wholesale | 17 | 292 | 332 | 19 | 175 | 75 | 261 | 419 | 1,840 | 9 | 101 | 0 | 2 | 16 | -5 | 3 | 6 | -14
| Bulgaria | Branch of ING Bank N.V. | Wholesale | 60 | 61 | 65 | 15 | 14 | 13 | 436 | 420 | 406 | 1 | 2 | 2 | 0 | 0 | 0 | 0 | 0 | 0
| Ireland | Branch of ING Bank N.V. | Wholesale | 72 | 64 | 50 | 66 | 70 | 72 | 2,771 | 1,831 | 2,050 | 26 | 65 | 58 | 3 | 8 | 7 | 6 | 8 | 7
| Portugal | Branch of ING Bank N.V. | Wholesale | 11 | 11 | 13 | 15 | 15 | 16 | 689 | 675 | 790 | 9 | 9 | 11 | 3 | 3 | 7 | 2 | 3 | 4
| Switzerland | Branch of ING Bank N.V. | Wholesale | 277 | 259 | 256 | 290 | 241 | 187 | 9,513 | 11,081 | 7,939 | 182 | 148 | 88 | 25 | 21 | 13 | 45 | 67 | 14

1 Includes significant number of FTEs in relation to global services provided.
2 Public subsidies received, as defined in article 89 of the CRD IV, amounts to EUR 0.1 million (2021: EUR 0.0 million; 2020: EUR 0.3 million).
3 In 2022, ING discontinued its retail activities in France and the Philippines.
4 In the fourth quarter of 2021, ING exited from the retail banking markets in Austria and the Czech Republic.

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> 32 Information on geographical areas
ING Bank Annual Report 2022 187

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
|  |  |  | 2022 | 2021 | 2020 | 2022 | 2021 | 2020 | 2022 | 2021 | 2020 | 2022 | 2021 | 2020 | 2022 | 2021 | 2020 | 2022 | 2021 | 2020
North America | Canada | Payvision Canada Services Ltd. | In liquidation | 0 | 0 | 1 | 0 | 0 | 3 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0
| USA | ING Financial Holdings Corp. | Wholesale | 586 | 563 | 600 | 892 | 936 | 720 | 65,024 | 55,582 | 48,205 | 413 | 779 | 39 | 115 | 182 | 16 | 135 | 148 | 38
Latin America | Brazil | Branch of ING Bank N.V. | Closed in 2022 | 30 | 63 | 89 | 17 | 13 | 30 | 57 | 288 | 1,813 | 9 | 1 | 3 | 1 | 5 | 19 | 5 | 8 | 4
| Colombia | ING Capital Colombia S.A.S. | Dissolved in 2021 |  | 0 | 3 |  | 0 | 1 |  | 0 | 2 |  | 0 | 0 |  | 0 | 0 |  | 0 | 0
| Mexico | ING Consulting, S.A. de C.V. | Wholesale | 6 | 6 | 7 | 0 | 1 | 1 | 1 | 3 | 2 | -2 | -1 | -1 | 0 | 0 | 0 | 0 | 0 | 0
Asia | China | Branch of ING Bank N.V. | Wholesale | 76 | 79 | 90 | 30 | 26 | 26 | 1,181 | 1,654 | 1,598 | 4 | 0 | -2 | 5 | 6 | 1 | 13 | -1 | -5
| Japan | Branch of ING Bank N.V. | Wholesale | 31 | 30 | 32 | 30 | 25 | 29 | 5,128 | 2,256 | 3,104 | 20 | 4 | -1 | 7 | 2 | -1 | -1 | 3 | 2
| Singapore | Branch of ING Bank N.V. | Wholesale | 565 | 573 | 608 | 354 | 331 | 353 | 25,701 | 24,163 | 24,498 | 105 | 133 | 42 | 14 | 19 | 8 | 21 | 9 | 7
| Macau | Payvision Macau Ltd. | Liquidated in 2022 |  | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0
| Hong Kong | Branch of ING Bank N.V. | Wholesale | 103 | 105 | 122 | 82 | 79 | 92 | 4,343 | 6,691 | 7,030 | -33 | 5 | -9 | -5 | 1 | -1 | 0 | -7 | 15
| Philippines 1,3 | Branch of ING Bank N.V. | Wholesale | 3,098 | 2,414 | 1,857 | 10 | 6 | 13 | 381 | 567 | 497 | -39 | -33 | -26 | 8 | -5 | 6 | 2 | 1 | 2
| South Korea | Branch of ING Bank N.V. | Wholesale | 78 | 75 | 77 | 86 | 65 | 66 | 7,989 | 5,800 | 6,692 | 47 | 26 | 18 | 12 | 6 | 4 | 7 | -2 | 10
| Taiwan | Branch of ING Bank N.V. | Wholesale | 35 | 33 | 34 | 33 | 26 | 36 | 3,578 | 2,963 | 3,160 | -16 | -3 | 19 | -5 | -1 | 4 | 4 | 0 | 1
| Indonesia | PT ING Securities Indonesia | Liquidated in 2022 |  | 0 | 0 | 0 | 0 | 0 | 0 | 5 | 5 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0
| Malaysia | Branch of ING Bank N.V. | Closed in 2022 |  | 4 | 6 | 0 | 0 | 1 | 1 | 1 | 141 | 0 | -1 | -1 | 0 | 0 | 0 | 0 | 0 | 0
| Sri Lanka | Branch of ING Hubs B.V. | Global services | 4 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0
| United Arab Emirates | Branch of ING Bank N.V. | Wholesale | 10 | 10 | 10 | -1 | 0 | 0 | 1 | 1 | 1 | -1 | -1 | -2 | 0 | 0 | 0 | 0 | 0 | 0
Australia | Australia | ING Bank (Australia) Ltd. | Wholesale / Retail | 1,556 | 1,503 | 1,472 | 948 | 782 | 740 | 52,728 | 49,826 | 46,014 | 557 | 500 | 362 | 172 | 149 | 40 | 135 | 121 | 181
Other | Mauritius | ING Mauritius Investment I | Liquidated in 2022 |  | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0
Total |  |  |  | 57,569 | 57,660 | 55,901 | 18,546 | 18,485 | 17,645 | 967,861 | 967,861 | 937,379 | 5,493 | 6,774 | 3,810 | 1,723 | 1,876 | 1,317 | 1,489 | 1,871 | 1,735

1 Includes significant number of FTEs in relation to global services provided.
3 In 2022 ING discontinued its retail activities in France and the Philippines.
2022
The higher tax charge of 39% in the Netherlands (compared to the statutory rate of 25.8%) is mainly caused
by the non-deductible Dutch bank tax (EUR 179 million) and the non-deductible impairments regarding
goodwill ING Turkey (EUR 32 million) and TTB (EUR 165 million).
The higher positive tax charge of Turkey combined with its accounting loss based on hyperinflation
accounting is mainly caused by the non deductibility of this loss for tax purposes.
Since the Russian invasion of the Ukraine our strategy is no new business with Russian clients, including
Russian owned entities outside of Russia and to get existing Russia-related credit exposures repaid as
quickly as possible. These exposures are booked in various countries and totalled EUR 6.7 billion, published
on 4 March 2022. Remaining at risk for ING Group at year-end 2022 is EUR 0.3 billion local equity and EUR
2.5 billion credit exposures booked outside of Russia. In 2022, ING's results in connection with Russia-related
credit exposures declined significantly, as we have recognized EUR 0.5 billion risk costs related to these
exposures. The local results on a stand-alone basis were higher compared to 2021.

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> 32 Information on geographical areas
ING Bank Annual Report 2022 188
This was driven by the high local interest rate environment and increased rouble inflow from existing,
predominantly non-Russian, clients. Under local law and banking regulations, ING Russia must accept these
rouble inflows. Furthermore, the local result before tax expressed in euro (EUR 128 million) was positively
impacted by the appreciation of the rouble against the euro for an amount of EUR 80 million throughout
2022. Going forward, we will continue to actively reduce our Russia-related credit exposure.
The higher tax charge in Poland is mainly caused by non-deductible regulatory and other costs.
2021
The higher tax charge of 35% in the Netherlands (compared to the statutory rate of 25%) is mainly caused
by the non-deductible Dutch bank tax (EUR 260 million) and the impairments on deferred tax assets
regarding Payvision and Yolt (EUR 26 million tax).
The lower tax charge in Austria is caused by previously not recognised tax losses (EUR -10 million tax).
The higher tax charge in Poland is mainly caused by non-deductible regulatory- and other costs.
2020
The higher tax charge of 53% in the Netherlands (compared to the statutory rate of 25%) is mainly caused
by the non-deductible Dutch bank tax (EUR 169 million) and the non-deductible impairments regarding
goodwill (EUR 266 million) and TMB (EUR 230 million).
The lower tax charge in Australia is caused by a release of a tax provision after concluding a settlement with
the Australian Tax Authorities on an issue related to former Insurance activities, which issue was fully
indemnified by NN Group.
The higher tax charges in Brazil and the Philippines are mainly caused by the de-recognition of tax benefits
for incurred tax losses due to expected insufficient future taxable profits.
The higher tax charges in Poland and Belgium are mainly caused by non-deductible regulatory- and other
costs.
Additional notes to the Consolidated financial statements
33 Pensions and other post-employment benefits
Most group companies sponsor defined contribution pension plans. The assets of all ING Bank’s defined
contribution plans are held in independently administered funds. Contributions, including the defined
contribution plan in the Netherlands, are principally determined as a percentage of remuneration. These
plans do not give rise to provisions in the statement of financial position, other than relating to short-term
timing differences included in other assets and in other liabilities.
ING Bank maintains defined benefit retirement plans in some countries. These plans provide benefits that
are related to the remuneration and service of employees upon retirement. The benefits in some of these
plans are subject to various forms of indexation. The indexation is, in some cases, at the discretion of
management; in other cases it is dependent upon the sufficiency of plan assets.
Annual contributions are paid to the funds at a rate necessary to adequately finance the accrued liabilities
of the plans calculated in accordance with local legal requirements. Plans in all countries are designed to
comply with applicable local regulations governing investments and funding levels.
ING Bank provides other post-employment benefits to certain former employees. These are primarily
discounts on ING products.
Defined contribution plans
ING, as part of the labour agreements with its employee’s , 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 contribution are
recognized as an expense which amounted for 2022 EUR 364 million (2021: EUR 369 million).

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> 32 Information on geographical areas
ING Bank Annual Report 2022 189

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 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
The Netherlands | 310 | 427 | 400 | 578 | -90 | -151
United States | 248 | 332 | 230 | 312 | 18 | 20
United Kingdom | 1,277 | 1,968 | 750 | 1,236 | 527 | 732
Belgium | 507 | 606 | 475 | 617 | 32 | -11
Other countries | 295 | 338 | 305 | 372 | -10 | -34
Funded status (Net defined benefit asset/liability) | 2,637 | 3,671 | 2,159 | 3,115 | 478 | 556
Presented as: |  |  |  |  |  |
- Other assets |  |  |  |  | 617 | 783
- Other liabilities |  |  |  |  | -139 | -227
|  |  |  |  | 478 | 556

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 2022. 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.
The current worldwide uncertainty due to the Russian invasion in the Ukraine and the resulting increasing
interest rates and inflation has a strong negative impact on most investment markets in 2022, the effect on
the fair value of ING Bank’s plan assets and defined benefit obligation is significant however the funding
status declined only by EUR -78 million mainly following the Liability Driven Investment (LDI) strategy in the
United Kingdom.
Changes in the fair value of plan assets for the period were as follows:

Changes in fair value of plan assets
in EUR million | 2022 | 2021
Opening balance | 3,671 | 3,583
Interest income | 54 | 37
Remeasurements: Return on plan assets excluding amounts included in interest income | -947 | 2
Employer's contribution | 34 | 26
Participants contributions | 3 | 2
Benefits paid | -126 | -136
Exchange rate differences | -53 | 158
Closing balance | 2,637 | 3,671
Actual return on the plan assets | -894 | 39

As at 31 December 2022 the defined benefit plans did not hold any direct investments in ING Groep N.V.
(2021: nil). During 2022 and 2021 there were no purchases or sales of assets between ING and the pension
funds.
ING does not manage the pension funds and thus receives no compensation for fund management. The
pension funds have not engaged ING in any swap or derivative transactions to manage the risk of the
pension funds.
No plan assets are expected to be returned to ING Bank during 2023.
Changes in the present value of the defined benefit obligation and other post-employment benefits for the
period were as follows:

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> 33 Pensions and other post-employment benefits
ING Bank Annual Report 2022 190

Changes in defined benefit obligation and other post-employment benefits
| Defined benefit obligation | Other post- employment benefits
in EUR million | 2022 | 2021 | 2022 | 2021
Opening balance | 3,115 | 3,208 | 72 | 83
Current service cost | 33 | 33 | 1 | 1
Interest cost | 46 | 31 | 1 | 2
Remeasurements: Actuarial gains and losses arising from changes in demographic assumptions |  | -5 |  |
Remeasurements: Actuarial gains and losses arising from changes in financial assumptions | -882 | -122 | -45 | -16
Participants’ contributions | 3 | 1 |  | 1
Benefits paid | -129 | -141 | -1 | -1
Past service cost |  |  | -1 |
Effect of curtailment or settlement |  |  |  | -2
Exchange rate differences | -26 | 109 | 5 | 4
Closing balance | 2,159 | 3,115 | 29 | 72

Amounts recognised directly in Other comprehensive income were as follows:

Changes in the net defined benefit assets/liability remeasurement reserve
in EUR million | 2022 | 2021
Opening balance | -212 | -307
Remeasurement of plan assets | -947 | 2
Actuarial gains and losses arising from changes in demographic assumptions |  | 5
Actuarial gains and losses arising from changes in financial assumptions | 882 | 122
Taxation and Exchange rate differences | 46 | -34
Total Other comprehensive income movement for the year | -19 | 95
Closing balance | -232 | -212

In 2022 EUR -947 million (2021: EUR 2 million) remeasurement of plan assets, that is recognised as a loss in
other comprehensive income, is driven by higher yields on investments. Also the war in Ukraine and high
inflation had impact on the investment return. Material changes in interest rates and equity returns
impacted plan assets negatively during 2022 substantially.
The EUR 882 million (2021: EUR 122 million) actuarial gains arising from changes in financial assumptions in
the calculation of the defined benefit obligation are mainly due to an increase in discount rates.
The accumulated amount of remeasurements recognised directly in Other comprehensive income is EUR
-289 million(EUR -232 million after tax) as at 31 December 2022 (2021: EUR -296 million; EUR -212 million
after tax).
Amounts recognised in the statement of profit or loss related to pension and other staff related benefits are
as follows:

Pension and other staff-related benefit costs
| Net defined benefit asset/liability | Other post-employment benefits | Total
in EUR million | 2022 | 2021 | 2020 | 2022 | 2021 | 2020 | 2022 | 2021 | 2020
Current service cost | 33 | 33 | 31 | 1 | 1 | -2 | 34 | 34 | 29
Past service cost |  |  | 2 | -1 |  |  |  |  | 2
Net Interest cost | -8 | -6 | -6 | 1 | 2 | 2 | -6 | -4 | -4
Effect of curtailment or settlement |  |  |  |  | -2 |  |  | -2 |
Defined benefit plans | 26 | 27 | 27 | 2 | 1 | 0 | 27 | 28 | 28
Defined contribution plans |  |  |  |  |  |  | 364 | 369 | 356
Pension and other post employment benefits |  |  |  |  |  |  | 392 | 397 | 383
Other staff related benefits |  |  |  |  |  |  | -2 | 11 | 12
Pension and other staff-related benefits |  |  |  |  |  |  | 390 | 408 | 395

Determination of the net defined benefit asset/liability
The net defined benefit asset/liability is reviewed and adjusted annually. The assumptions used in the
determination of the net defined benefit asset/liability and the Other post-employment benefits include
discount rates, mortality rates, expected rates of salary increases (excluding promotion increases), and
indexation. The rates used for salary developments, interest discount factors, and other adjustments reflect
country-specific conditions.
The key assumption in the determination of the net defined benefit asset/liability is the discount rate. The
discount rate is the weighted average of the discount rates that are applied in different regions where ING
Bank has defined benefit pension plans (weighted by the defined benefit obligation). The discount rate is
based on a methodology that uses market yields on high quality corporate bonds of the specific regions

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> 33 Pensions and other post-employment benefits
ING Bank Annual Report 2022 191
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 2022 was 4.3% (2021: 1.5%) 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 2022 was 5.5% (2021:
2.9%)
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, 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
247 million (decrease) and EUR 287 million (increase), respectively.
Expected cash flows
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 supervisory requirements. Plans in all countries are designed
to comply with applicable local regulations governing investments and funding levels. ING Bank’s
subsidiaries should fund the cost of the entitlements expected to be earned on a yearly basis.
For 2023 the expected contributions to defined benefit pension plans are EUR 33 million.
The benefit payments for defined benefit and other post-employment benefits expected to be made by the
plan between 2023-2027 are estimated to be between EUR 128 million and EUR 150 million per year. From
2028 to 2032 the total payments made by the plan are expected to be EUR 739 million.
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 Bank is subject to taxation.

Changes in deferred tax
in EUR million 2022 | 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 | -70 | 148 | 5 | -3 |  | 80
Financial assets and liabilities at FVPL | 107 |  | -88 | 9 |  | 28
Depreciation | -7 |  | -5 | -2 |  | -13
Cash flow hedges | -126 | 875 |  | 2 |  | 752
Pension and post-employment benefits | -49 | 6 | -13 | 8 | -7 | -54
Other provisions | 19 |  | 44 | -4 |  | 59
Loans and advances | 430 |  | 177 | -3 | 7 | 612
Unused tax losses carried forward | 199 |  | 137 | -8 |  | 327
Other | -148 | -123 | 26 | -6 |  | -251
| 354 | 907 | 283 | -5 | 0 | 1,539
Presented in the statement of financial position as: |  |  |  |  |  |
– Deferred tax liabilities | -603 |  |  |  |  | -257
– Deferred tax assets | 957 |  |  |  |  | 1,796
| 354 |  |  |  |  | 1,539

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 205 million
(2021: EUR 220 million and 2020: EUR 306 million) and a deferred tax amount for lease liabilities of EUR 231
million (2021: EUR 252 million and 2020: EUR 326 million)
Financial assets at FVOCI changes through equity in 2022 (EUR 148 million) relates to the decline in fair
value of the debt securities FVOCI due to increased interest yield curves.

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> 33 Pensions and other post-employment benefits
ING Bank Annual Report 2022 192
Financial assets and liabilities FVPL changes through net result in 2022 (EUR -88 million) and 2021 (EUR -39
million) relates to the decrease in fair value of derivatives due to increased interest yield curves.
The deferred tax on cash flow hedges relate to floating rate lending with interest rate swaps. Due to an
increase in the interest rate yield curve in 2022 there was a negative revaluation through other
comprehensive income of EUR 875 million (2021 EUR 233 million) and an increase of the deferred tax asset
from EUR -126 million in 2021 to EUR 752 million in 2022.
The deferred tax on Loans and advances changes through net result in 2022 EUR 177 million (2021: EUR -83
million relates mainly to valuation changes of collectively assessed expected credit losses. The deferred tax
changes through equity - Other in 2022 is EUR -123 million (2021: EUR -83 million) is due to FX
developments following the USD depreciation and the application of IAS 29 Hyperinflation in Turkey and also
due to the increase in the Liability Credit Reserve due to spread widening.

Changes in deferred tax
in EUR million 2021 | 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 | -103 | 26 | -1 | 1 | 7 | -70
Financial assets and liabilities at FVPL | 134 |  | -39 | 20 | -7 | 107
Depreciation | -10 |  | 5 | -2 |  | -7
Cash flow hedges | -360 | 233 |  | 1 |  | -126
Pension and post-employment benefits | 36 | -54 | -23 | -8 |  | -49
Other provisions | -5 |  | 28 | -4 |  | 19
Loans and advances | 517 | -2 | -83 | -1 |  | 430
Unused tax losses carried forward | 63 |  | 129 | 7 |  | 199
Other | -82 | -83 | 15 | 1 |  | -148
Total | 190 | 120 | 30 | 15 | -1 | 354
Presented in the statement of financial position as: |  |  |  |  |  |
– deferred tax liabilities | -584 |  |  |  |  | -603
– deferred tax assets | 773 |  |  |  |  | 957
| 190 |  |  |  |  | 354

Deferred tax in connection with unused tax losses carried forward
in EUR million | 2022 | 2021
Total unused tax losses carried forward | 2,668 | 2,165
Unused tax losses carried forward not recognised as a deferred tax asset | 937 | 819
Unused tax losses carried forward recognised as a deferred tax asset | 1,731 | 1,345
Average tax rate | 21.1% | 22.3%
Deferred tax asset | 365 | 300

Total unused tax losses carried forward analysed by expiry terms
| No deferred tax asset recognised | Deferred tax asset recognised
in EUR million | 2022 | 2021 | 2022 | 2021
Within 1 year |  |  | 591 |
More than 1 year but less than 5 years | 120 | 3 | 587 | 642
More than 5 years but less than 10 years | 9 | 9 | 2 |
More than 10 years but less than 20 years |  |  |  |
Unlimited | 808 | 808 | 550 | 704
| 937 | 819 | 1,731 | 1,345

The above mentioned deferred tax asset of EUR 365 million (2021: EUR 300 million) and the related unused
tax losses carried forward exclude the deferred tax liability recognised in the Netherlands with respect to the
recapture of tax losses originated in the United Kingdom but previously deducted in the Netherlands for the
amount of EUR 37 million (2021: EUR 102 million).
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.

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> 34 Taxation
ING Bank Annual Report 2022 193

Breakdown of certain net deferred tax asset positions by jurisdiction
in EUR million | 2022 | 2021
Poland | 391 | 265
France | 70 | 66
Philippines | 0 | 7
China | 0 | 12
Czech | 0 | 2
Hong Kong | 6 | 1
United States of America | 1 | 1
Turkey | 7 |
Taiwan | 8 |
| 483 | 354

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.
In 2022 and 2021 ING Bank Slaski (Poland) incurred a tax loss following the large value changes of the cash
flow hedge derivatives which are settled net via a central clearing party. This tax loss can be carried forward
for 5 years. Based on a taxable profit forecast, ING considers it probable that the future taxable profits will
compensate for this tax loss carry forward position within 2 years. Based on this a deferred tax asset on
unused tax losses carried forward (EUR 224 million) is fully recognised. The remaining deferred tax asset in
Poland of EUR 167 million relates to temporary tax differences on loans and advances and financial assets
at fair value through profit and loss.
Recognition is based on the fact that it is probable that the entity will have taxable profits and/or can utilise
tax planning opportunities before expiration of the deferred tax assets. Changes in circumstances in future
periods may adversely impact the assessment of the recoverability. The uncertainty of the recoverability is
taken into account in establishing the deferred tax assets.
At 31 December 2021 and 2022, ING Bank had no significant temporary differences associated with the
parent company’s investments in subsidiaries as any economic benefit from those investments will not be
taxable at parent company level.
Statement of profit or loss – Taxation

Taxation by type
| Netherlands | Rest of the world | Total
in EUR million | 2022 | 2021 | 2020 | 2022 | 2021 | 2020 | 2022 | 2021 | 2020
Current taxation | 496 | 459 | 428 | 1,510 | 1,447 | 1,015 | 2,006 | 1,906 | 1,442
Deferred taxation | -79 | 47 | 64 | -204 | -78 | -189 | -283 | -30 | -125
| 417 | 507 | 492 | 1,306 | 1,369 | 826 | 1,723 | 1,876 | 1,317

Reconciliation of the weighted average statutory income tax rate to ING Bank’s effective income tax rate
in EUR million | 2022 | 2021 | 2020
Result before tax from continuing operations | 5,493 | 6,774 | 3,810
Weighted average statutory tax rate | 24.8% | 24.3% | 25.6%
Weighted average statutory tax amount | 1,363 | 1,645 | 975
Permanent differences affecting current tax |  |  |
Participation exemption | -64 | -68 | -46
Other income not subject to tax | -40 | -32 | -5
Expenses not deductible for tax purposes | 403 | 201 | 320
Current tax from previously unrecognised amounts | 10 | 51 | 17
State and local taxes | 68 | 64 | 44
Adjustments to prior periods | -29 | -12 | -16
Differences affecting deferred tax |  |  |
Impact on deferred tax from change in tax rates | 5 | 9 | 10
Deferred tax benefit from previously unrecognised amounts | -3 | -18 | -6
Write-off/reversal of deferred tax assets | 10 | 37 | 24
Effective tax amount | 1,723 | 1,876 | 1,317
Effective tax rate | 31.4% | 27.7% | 34.6%

The weighted average statutory tax rate in 2022 ( 24.8%) increased compared to that of 2021 (24.3%).
The effective tax rate of 31.4% in 2022 is higher than the weighted average statutory tax rate. This is mainly
caused by the impact in 2022 of the following non-deductible items for income tax purposes: hyperinflation
accounting loss in Turkey, impairments on TTB and interest expenses in various countries.

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> 34 Taxation
ING Bank Annual Report 2022 194
The weighted average statutory tax rate in 2021 (24.3%) was lower than the rate of 25.6% in 2020.
The effective tax rate of 27.7% in 2021 was significantly higher than the weighted average statutory tax
rate. This is mainly caused by a high amount of expenses non-deductible for tax purposes like the non-
deductible bank tax and a tax charge caused by the recapture of tax losses originated in the United
Kingdom but previously deducted in the Netherlands.
The effective tax rate of 34.6% in 2020 was higher than the weighted average statutory tax rate. This is
mainly caused by a high amount of expenses non-deductible for tax purposes like the non-deductible bank
tax and non-deductible losses with respect to goodwill impairments and impairments on associates in the
Netherlands and in some other European countries.
Adjustments to prior periods in 2020 relates to a release of a tax provision of EUR 68 million after concluding
on a settlement with the Australian tax authorities with respect to an issue related to former insurance
activities, which issue was fully indemnified by NN Group.
Equity – Other comprehensive income

Income tax related to components of other comprehensive income
in EUR million | 2022 | 2021 | 2020
Unrealised revaluations financial assets at fair value through other comprehensive income and other revaluations | 140 | 14 | -3
Realised gains/losses transferred to the statement of profit or loss (reclassifications from equity to profit or loss) | 8 | 12 | 10
Changes in cash flow hedge reserve | 875 | 233 | -23
Remeasurement of the net defined benefit asset/liability | 6 | -54 | -8
Changes in fair value of own credit risk of financial liabilities at fair value through profit or loss | 19 | -8 | -1
Exchange rate differences and other | -141 | -77 | 63
Total income tax related to components of other comprehensive income | 907 | 120 | 38

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.
In 2022 the financial market witnessed globally a higher-volatility due to a confluence of factors, such as
changing expectations about the paths of future interest rates in major advanced economies, energy crisis
and geopolitical tensions after Russia's invasion of Ukraine. Globally, interest rates hike across EU and US.
The USD appreciates against EURO and various currencies during the year. These main factors drive the
market-to-market movements across different asset classes and spread movement through the year.
Overall in 2022, financial assets and liabilities, including Level 3, continued to be valued using agreed
methodologies and ING continued to limit the unobservable input to arrive at the most appropriate Fair
Market value.
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 various governance bodies, including Local
Parameter Committees, Global Valuation and Impairment Committee, Market Data Committee and
Valuation Model Committee. All relevant committees meet on a regular basis (monthly/quarterly), where
agenda covers the aforementioned valuation controls.
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 Valuation Model Committee 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 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).

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> 34 Taxation
ING Bank Annual Report 2022 195
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 (DOP).
ING defers material Day One Profit or Loss 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 Day One Profit or Loss 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. Both the impact on the profit and loss in
2022 and the Day One Profit or Loss reserve is disclosed in the below table.
The following table presents the models reserves for financial assets and liabilities.

Valuation adjustment reserves on financial assets and liabilities
in EUR million | 2022 | 2021
Deferred Day One Profit or Loss 1 | -108 | -7
Own credit adjustments 2 | 75 | -95
Bid/Offer | -216 | -143
Model Risk | -13 | -11
CVA | -192 | -159
DVA 2 | 99 | 30
CollVA | -8 | -8
FVA | -78 | -95
Total Valuation Adjustments | -441 | -489

1.In 2022, the presentation of Day One Profit or Loss reserve has been included in the table above
2. The change in the DVA as of 2022 entails the split into DVA on derivatives and Own credit adjustments on own issued liabilities.
Comparatives figures for 2021 have been updated accordingly.
Overall, the fair value adjustments balance move down compared to last year end explained by own credit
adjustments on own issued liabilities, mainly driven by the widening of ING CDS curve spread across all
tenors, and for DVA on derivatives.
Deferred Day One Profit or Loss Reserve
The table below summarizes the movement in the aggregate profit not recognised when financial
instruments were initially recognised (Day One Profit or Loss), because of the use of valuation techniques for
which not all the inputs were market observable data.
As at 31 December 2022 ING further refined the thresholds to identify trades with significant unobservable
CVA which triggered more Day One Profit or Loss deferral. Reference is made to the table below.

Deferred day one profit or loss reserve
in EUR million | 2022 | 2021
Opening balance at 1 January | -7 | -5
DOP deferred on new transactions during the period | -107 | -8
DOP recognised in the statement of profit or loss during the period | 6 | 6
Closing balance at 31 December | -108 | -7

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 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).

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> 35 Fair value of assets and liabilities
ING Bank Annual Report 2022 196
•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, 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 (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 remuneration rate on collateral which may
pay lower or higher rate than overnight rate or even no interest at all; other deviations can be posting
securities rather than cash as collateral, etc.
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 collateralized and uncollateralized
derivatives portfolios. This adjustment is based on the expected exposure profiles of the uncollateralized or
partially collateralized OTC derivatives and market-based funding spreads.
d) Fair value hierarchy
ING Bank has categorised its financial instruments that are either measured in the statement of financial
position at fair value or of which the fair value is disclosed, into a three level hierarchy based on the
observability of the valuation inputs. Highest priority is retained to unadjusted quoted prices in active
markets for identical assets or liabilities and the lowest priority to valuation techniques supported by
unobservable inputs.
Transfers into and transfers out of fair value hierarchy levels are made on a quarterly basis at the end of the
reporting period.
Level 1 – (Unadjusted) quoted prices in active markets
This category includes financial instruments whose fair value is determined directly by reference to
(unadjusted) quoted prices in an active market. A financial instrument is regarded as quoted in an active
market if quoted prices are readily and regularly available from an exchange, dealer markets, brokered
markets, or principal to principal markets. Those prices represent actual and regularly occurring market
transactions with sufficient frequency and volume to provide pricing information on an ongoing basis.
Transfers out of Level 1 into Level 2 or Level 3 occur when ING Bank establishes that markets are no longer
active and therefore (unadjusted) quoted prices no longer provide reliable pricing information.
Level 2 – Valuation technique supported by observable inputs
This category includes financial instruments whose fair value is based on market observable inputs, either
directly or indirectly, other than quoted prices included within Level 1. The fair value for financial
instruments in this category can be determined by reference to quoted prices for similar instruments in
active markets, quoted prices for identical or similar instruments in markets that are not active, inputs other
than quoted prices that are observable or market-corroborated inputs. ING analyses how the prices are
derived and determines whether the prices are liquid tradable prices or model-based consensus prices
taking various data as inputs.
For financial instruments that do not have a reference price available, fair value is determined using a
valuation technique (e.g., a model), where inputs in the model are taken from an active market or are
observable, such as interest rates and yield curves observable at commonly quoted intervals, implied
volatilities, and credit spreads.
Instruments, where inputs are unobservable are classified in this category, provided that the impact of
those unobservable inputs on the overall valuation is insignificant. The notion of significant is particularly
relevant for the distinction between Level 2 and Level 3 assets and liabilities, as the significance assessment
of the valuation input on the entire fair value measurement will determine whether the instrument should
be classified as Level 2 or Level 3. Expert judgement is required on the significance assessment approach.
Level 3 – Valuation technique supported by unobservable inputs
This category includes financial instruments whose fair value is determined using a valuation technique for
which a significant part of the overall valuation is driven by unobservable valuation inputs. Where valuation
inputs are unobservable, the Group must use the best information available to value the instruments. This
may require internally derived inputs taking into account market participants assumptions that are
reasonably available, including assumptions on the risk inherent in a particular valuation technique used to
measure fair value and the risk inherent in the inputs to the valuation technique. Unobservable inputs may
include, among others, volatility, correlation, spreads to discount rates, default rates, recovery rates,
prepayment rates, and certain credit spreads.

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> 35 Fair value of assets and liabilities
ING Bank Annual Report 2022 197
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 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Financial Assets |  |  |  |  |  |  |  |
Financial assets at fair value through profit or loss |  |  |  |  |  |  |  |
- Equity securities | 11,787 | 17,599 | 2 | 2 | 156 | 134 | 11,945 | 17,735
- Debt securities | 1,636 | 2,317 | 5,361 | 7,016 | 3,450 | 2,643 | 10,447 | 11,976
- Derivatives | 22 | 6 | 34,229 | 21,154 | 483 | 140 | 34,734 | 21,299
- Loans and receivables |  |  | 54,097 | 48,706 | 2,547 | 2,248 | 56,644 | 50,954
| 13,445 | 19,922 | 93,690 | 76,877 | 6,635 | 5,165 | 113,770 | 101,964
Financial assets at fair value through other comprehensive income |  |  |  |  |  |  |  |
- Equity securities | 1,639 | 2,232 |  |  | 247 | 225 | 1,887 | 2,457
- Debt securities | 25,644 | 21,753 | 3,451 | 5,587 |  |  | 29,095 | 27,340
- Loans and receivables |  |  |  |  | 643 | 838 | 643 | 838
| 27,284 | 23,984 | 3,451 | 5,587 | 891 | 1,063 | 31,625 | 30,635
Financial liabilities |  |  |  |  |  |  |  |
Financial liabilities at fair value through profit or loss |  |  |  |  |  |  |  |
– Debt securities | 444 | 377 | 5,574 | 5,227 | 53 | 135 | 6,072 | 5,739
– Deposits |  |  | 50,803 | 43,582 |  |  | 50,803 | 43,582
– Trading securities | 1,952 | 955 | 273 | 120 | 1 |  | 2,226 | 1,075
– Derivatives | 40 | 63 | 33,200 | 20,388 | 678 | 195 | 33,917 | 20,646
| 2,436 | 1,395 | 89,851 | 69,317 | 732 | 330 | 93,019 | 71,041

The following methods and assumptions were used by ING Bank 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 absence of active markets, fair values are estimated by analysing the
investee’s financial position, result, risk profile, prospect, price, earnings comparisons and revenue multiples.
Additionally, reference is made to valuations of peer entities where quoted prices in active markets are
available. For equity securities best market practice will be applied using the most relevant valuation
method. All non-listed equity investments, including investments in private equity funds, are subject to a
standard review framework which ensures that valuations reflect the fair values.
Fair value hierarchy: The majority of equity securities are publicly traded and quoted prices are readily and
regularly available. Hence, these securities are classified as Level 1. Equity securities which are not traded in
active markets mainly include corporate investments, fund investments and other equity securities and are
classified as Level 3.
Debt securities
Instrument description: Debt securities include government bonds, financial institutions bonds and Asset-
backed securities (ABS).
Valuation: Where available, fair values for debt securities are generally based on quoted market prices.
Quoted market prices are obtained from an exchange market, dealer, broker, industry group, pricing service,
or regulatory service. The quoted prices from non-exchange sources are reviewed on their tradability of
market prices. If quoted prices in an active market are not available, fair value is based on an analysis of
available market inputs, which includes 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 institutions bonds are generally traded in active
markets, where quoted prices are readily and regularly available and are hence, classified as Level 1. The
remaining positions are classified as Level 2 or Level 3. 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: Derivatives 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

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> 35 Fair value of assets and liabilities
ING Bank Annual Report 2022 198
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 (amongst 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 includes
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, debt
instruments, primarily comprised of structured notes, which are held at fair value under the fair value
option. Besides that, it includes 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 an EUR 1.8 billion transfer from Level 2 to
Level 1 in debt securities measured at fair value through other comprehensive income. No significant
transfers from Level 1 to Level 2 were recorded in the reporting period 2022.
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 2022 of EUR 7.5 billion
(31 December 2021: EUR 6.2 billion), an amount of EUR 2.2 billion (29.2%) (31 December 2021: EUR 2.0
billion, being 32.5%) 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 includes approximately EUR 4.2 billion (31 December 2021: EUR 2.9
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 1.1 billion (31 December 2021: EUR 1.3 billion of the fair value classified in Level 3
financial assets is established using valuation techniques that incorporates certain inputs that are
unobservable.
Of the total amount of financial liabilities classified as Level 3 as at 31 December 2022 of EUR 0.7 billion
(31 December 2021: EUR 0.3 billion), an amount of EUR 0.02 billion (2.5%) (31 December 2021: EUR 0.1
billion, being 42.0%) 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.

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> 35 Fair value of assets and liabilities
ING Bank Annual Report 2022 199
Furthermore, Level 3 financial liabilities includes approximately EUR 0.6 billion (31 December 2021: 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 (31 December 2021: 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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> 35 Fair value of assets and liabilities
ING Bank Annual Report 2022 200

Valuation techniques and range of unobservable inputs (Level 3)
| Assets | Liabilities | Valuation techniques | Significant unobservable inputs | Lower range | Upper range
In EUR million | 2022 | 2021 | 2022 | 2021 |  |  | 2022 | 2021 | 2022 | 2021
At fair value through profit or loss |  |  |  |  |  |  |  |  |  |
Debt securities | 3,447 | 2,643 | 1 | 1 | Price based | Price (%) | 0% | 0% | 125% | 121%
|  |  |  |  |  | Price (price per share) | 208 |  | 208 |
|  |  |  |  | Present value techniques | Credit spread (bps) | 60 |  | 100 |
|  |  |  |  |  | Price (%) | 97% |  | 100% |
Equity securities | 156 | 134 |  |  | Price based | Price (price per share) | 0 | 0 | 5,457 | 5,475
Loans and advances | 1,485 | 1,598 |  |  | Price based | Price (%) | 0% | 0% | 100% | 100%
|  |  |  |  | Present value techniques | Credit spread (bps) | 2 | 0 | 12 | 250
(Reverse) repo's | 1,062 | 650 |  |  | Present value techniques | Interest rate (%) | 3% | 0% | 5% | 1%
Structured notes | 3 | 0 | 53 | 135 | Price based | Price (%) | 84% | 84% | 107% | 125%
|  |  |  |  | Option pricing model | Equity volatility (%) | 13% | 13% | 42% | 30%
|  |  |  |  |  | Equity/Equity correlation | 0.5 | n.a. | 1.0 | n.a.
|  |  |  |  |  | Equity/FX correlation | -0.4 | 0.0 | 0.6 | 0.0
|  |  |  |  |  | Dividend yield (%) | 0% | 3% | 8% | 4%
|  |  |  |  | Present value techniques | Credit spreads (bps) | 96 |  | 96 |
Derivatives |  |  |  |  |  |  |  |  |  |
– Rates | 431 | 5 | 476 | 35 | Option pricing model | Interest rate volatility (bps) | 49 | 43 | 148 | 82
|  |  |  |  | Present value techniques | Reset spread (%) | 0% | 2% | 1% | 2%
|  |  |  |  |  | Interest rate (%) | 2% |  | 2% |
|  |  |  |  |  | Prepayment rate (%) | 5% |  | 13% |
– FX | 5 | 27 | 4 | 30 | Present value techniques | FX volatility (%) |  | 1% |  | 16%
|  |  |  |  | Option pricing model | Implied volatility (%) | 6% | 1% | 20% | 22%
– Credit | 13 | 75 | 175 | 94 | Present value techniques | Credit spread (bps) | 5 | 1 | 623 | 359
|  |  |  |  | Price based | Price (%) | 0% | 0% | 100% | 100%
– Equity | 33 | 30 | 22 | 27 | Option pricing model | Equity volatility (%) | 0% | 11% | 77% | 119%
|  |  |  |  |  | Equity/Equity correlation | 0.5 | 0.5 | 0.9 | 0.8
|  |  |  |  |  | Equity/FX correlation | -0.5 | -0.7 | 0.1 | 0.1
|  |  |  |  |  | Dividend yield (%) | 1% | 0% | 14% | 18%
|  |  |  |  | Price based | Price (%) | n.a | 0% | n.a | 0%
– Other | 1 | 3 |  | 9 | Option pricing model | Commodity volatility (%) | 0% | 20% | 63% | 89%
At fair value through other comprehensive income |  |  |  |  |  |  |  |  |  |
– Loans and advances | 643 | 838 |  |  | Present value techniques | Prepayment rate (%) | 6% | 9% | 6% | 9%
|  |  |  |  | Price based | Price (%) | 67% | 99% | 99% | 100%
– Equity | 247 | 225 |  |  | Present value techniques | Credit spread (bps) | 6.7 | 1.9 | 6.7 | 1.9
|  |  |  |  |  | Interest rate (%) | 4% | 3% | 4% | 3%
|  |  |  |  | Price based | Price (%) | n.a | 1% | n.a | 1%
|  |  |  |  | Price based | Other (EUR) | 70 | 63 | 90 | 80
Total | 7,526 | 6,228 | 732 | 330 |  |  |  |  |  |

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> 35 Fair value of assets and liabilities
ING Bank Annual Report 2022 201
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 strong positive (statistical) relationship, where underliers move, everything else equal,
into the same direction. The same holds for a high negative correlation.
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.
Inflation rate Inflation rate is a key input to inflation linked instruments. Inflation linked instruments protect
against price inflation and are denominated and indexed to investment units. Interest payments would be
based on the inflation index and nominal rate in order to receive/pay the real rate of return. A rise in
nominal coupon payments is a result of an increase in inflation expectations, real rates, or both.
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.
Jump rate
Jump rates simulate abrupt changes in valuation models. The rate is an added component to the discount
rate in the model to include default risks.
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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> 35 Fair value of assets and liabilities
ING Bank Annual Report 2022 202
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
in EUR million | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Opening balance | 822 | 882 | 1 | 1 | 1,862 | 1,191 | 2,480 | 796 | 1,063 | 1,231 | 6,228 | 4,101
Realised gain/loss recognised in the statement of profit or loss during the period 1 | 53 | 22 | 52 |  | -57 | 32 | 122 | -80 | 8 | -12 | 178 | -37
Revaluation recognised in other comprehensive income during the period 2 |  | 0 |  |  |  |  |  |  | -84 | 22 | -84 | 22
Purchase of assets | 694 | 453 | 15 | 3 | 1,586 | 1,496 | 772 | 1,919 | 221 | 165 | 3,288 | 4,036
Sale of assets | -49 | -48 | -4 | -3 | -669 | -612 | -191 | -141 | -275 | -234 | -1,187 | -1,037
Maturity/settlement | -511 | -14 | -2 |  | -617 | -163 |  | -13 | -59 | -109 | -1,188 | -299
Reclassifications |  | 0 |  |  | -18 | -5 |  |  | 10 | -6 | -8 | -11
Transfers into Level 3 | 288 | 43 | 474 |  | 605 | -1 | 322 |  | -43 | -1 | 1,646 | 42
Transfers out of Level 3 | -442 | -517 | -115 | -1 | -856 | -98 |  |  |  |  | -1,414 | -615
Exchange rate differences | 18 | 0 |  |  | 14 | 20 | -12 |  | 49 | 9 | 68 | 29
Changes in the composition of the group and other changes |  | 0 |  |  |  |  |  |  |  | -2 |  | -2
Closing balance | 873 | 822 | 421 | 1 | 1,849 | 1,862 | 3,492 | 2,480 | 891 | 1,063 | 7,526 | 6,228

1 Net gains/losses were recorded as ‘Valuation results and net trading income’ in the statement of profit or loss. The total amounts includes EUR -171 million (2021: EUR 50 million) of unrealised gains and losses recognised in the statement of profit or loss.
2 Revaluation recognised in other comprehensive income is included on the line ‘Net change in fair value of debt instruments at fair value through other comprehensive income’.
In 2022, the transfers into Level 3 mainly consisted of (non) trading derivatives that were transferred to
Level 3 as a result of the valuation being significantly impacted by unobservable inputs. Furthermore, it
relates to debt obligations of which the valuation is being significantly impacted by unobservable inputs.
In 2022, following the enhancement of the significance assessment, transfers into and out of Level 3 of
financial assets mandatorily at fair value mainly relate to a portfolio of securitization loans. Furthermore,
transfers out of Level 3 relate to two syndicated deals due to the unobservable parameters were
insignificant.
In 2022, transfers into level 3 financial assets designated at fair value relate to government bonds of which
the valuation being significantly impacted by unobservable inputs
In 2021, transfers out of Level 3 of financial assets designated at fair value mainly relate to (long term)
reverse repurchase transactions that were transferred out of Level 3 due to the valuation not being
significantly impacted by unobservable inputs.

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> 35 Fair value of assets and liabilities
ING Bank Annual Report 2022 203

Changes in Level 3 Financial liabilities
| Trading liabilities | Non-trading derivatives | Financial liabilities designated as at fair value through profit or loss | Total
in EUR million | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Opening balance | 160 | 180 | 35 | 39 | 135 | 180 | 330 | 398
Realised gain/loss recognised in the statement of profit or loss during the period 1 | 131 | 101 | 59 |  | -10 | 13 | 179 | 113
Additions | 124 | 58 | 16 | 3 | 13 | 52 | 153 | 113
Redemptions | -38 | -10 |  | -3 | -13 | -140 | -51 | -153
Maturity/settlement | -282 | -44 | -7 |  | -71 | -1 | -360 | -45
Transfers into Level 3 | 254 | 48 | 368 |  | 88 | 233 | 710 | 282
Transfers out of Level 3 | -117 | -173 | -21 | -3 | -88 | -203 | -226 | -378
Exchange rate differences | -3 |  |  |  |  |  | -3 |
Closing balance | 229 | 160 | 449 | 35 | 54 | 135 | 732 | 330

1 Net gains/losses were recorded as ‘Valuation results and net trading income’ in the statement of profit or loss. The total amount
includes EUR 179 million (2021: EUR 113 million) of unrealised gains and losses recognised in the statement of profit or loss.
In 2022, the transfers into Level 3 mainly consisted of non-trading derivatives that were transferred to Level
3 as a result of the valuation being significantly impacted by unobservable inputs.
In 2021, financial liabilities transfers into and out of Level 3 mainly consisted of structured notes, measured
as designated at fair value through profit or loss. The structured notes were transferred out of Level 3 as the
valuation was no longer impacted 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 relates 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 | 2022 | 2021 | 2022 | 2021
Equity (equity derivatives, structured notes) | 12 | 3 | -6 | -27
Interest rates (Rates derivatives, FX derivatives) | 22 | 15 | -14 | -1
Credit (Debt securities, Loans, structured notes, credit derivatives) | 32 | 27 | -28 | -2
Loans and advances |  |  | -32 |
| 65 | 45 | -80 | -30

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. The aggregation of the fair values presented below does not
represent, and should not be construed as representing, the underlying value of ING Bank.

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> 35 Fair value of assets and liabilities
ING Bank Annual Report 2022 204

Methods applied in determining fair values of financial assets and liabilities (carried at amortised cost)
| Carrying Amount | Carrying amount approximates fair value | Level 1 | Level 2 | Level 3 | Total fair value
in EUR million | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Financial Assets |  |  |  |  |  |  |  |  |  |  |  |
Loans and advances to banks 1 | 35,103 | 23,591 | 2,858 | 1,674 |  | 1 | 29,459 | 17,033 | 2,786 | 4,926 | 35,103 | 23,634
Loans and advances to customers | 635,557 | 627,550 | 19,101 | 16,943 |  |  | 15,264 | 18,465 | 575,805 | 600,253 | 610,170 | 635,661
Securities at amortised cost | 48,160 | 48,319 |  |  | 39,787 | 40,314 | 3,160 | 7,327 | 1,406 | 681 | 44,353 | 48,323
| 718,820 | 699,459 | 21,959 | 18,617 | 39,788 | 40,316 | 47,883 | 42,825 | 579,996 | 605,860 | 689,626 | 707,618
Financial liabilities |  |  |  |  |  |  |  |  |  |  |  |
Deposits from banks | 56,632 | 85,092 | 3,696 | 4,298 |  |  | 48,524 | 75,847 | 3,954 | 5,890 | 56,174 | 86,035
Customer deposits | 686,341 | 657,831 | 590,321 | 586,151 |  |  | 80,305 | 61,158 | 15,511 | 11,861 | 686,136 | 659,171
Debt securities in issue | 58,075 | 57,443 |  |  | 20,308 | 15,320 | 20,501 | 27,718 | 17,577 | 14,756 | 58,385 | 57,794
Subordinated loans | 15,789 | 16,719 |  |  |  |  | 15,548 | 17,203 |  |  | 15,548 | 17,203
| 816,838 | 817,085 | 594,016 | 590,449 | 20,308 | 15,321 | 164,878 | 181,926 | 37,041 | 32,507 | 816,243 | 820,203

1 The prior period has been updated to improve consistency and comparability of level 3 and 2.
The following methods and assumptions were used by ING Bank to estimate the fair value of the financial
instruments which are nor recorded and measured at fair value. These fair values were calculated for
disclosure purposes only. The carrying amount of financial instruments presented in the above table
includes the fair value hedge adjustment, this explains why the carrying amount approximates fair value.
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.
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 reflects ING’s own
credit risk.
Customer deposits
The carrying values of customer deposits with an immediate on demand features approximate their fair
values. The fair values of deposits with fixed contractual terms have 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

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> 35 Fair value of assets and liabilities
ING Bank Annual Report 2022 205
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 arises
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 1.7 ‘Financial instruments’ of Note 1 ‘Basis of preparation
and significant accounting policies’.
IBOR transition
Reference is made to the note Risk management/ IBOR Transition for information on how ING is managing
the transition to alternative benchmark rates and INGs progress in completing the transition.
At the reporting date, ING assessed the extent to which hedge relationships are subject to uncertainties
driven by IBOR reform.
The IBOR's in scope of ING’s IBOR Transition program are a component of either the hedging instrument and/
or the hedged item where the interest rate and/or foreign currency risk are the designated hedged risk. The
hedged exposures are mainly loan portfolios, issued debt securities and purchased debt instruments.
ING early adopted the amendments to IAS 39 issued in September 2019 to these hedging relationships
directly affected by IBOR reform (Phase 1). This excludes EURIBOR hedges as EURIBOR is Benchmarks
Regulation compliant and continues to be available. Refer to section 1.7.4 of Note 1 ‘Basis of preparation
and significant accounting policies’ for more information on the Phase 1 amendments.
Phase 1 amendments to IFRS allow ING to apply a set of temporary exceptions to continue hedge
accounting even when there is uncertainty about contractual cash flows arising from IBOR reform. Phase 1
reliefs cease to apply when uncertainty arising from IBOR Reform is no longer present with respect to the
timing and amount of the IBOR-based cash flows of the relevant instruments.
In Poland the local working group (the 'National Working Group') for benchmark reform issued a roadmap to
replace the current Polish benchmark rate Warsaw Interbank Offered Rate (WIBOR) with a new rate named
Warsaw Interest Rate Overnight (WIRON). The National Working Group indicated that the plan is for the
market to be ready for a cessation of WIBOR by the start of 2025, consequently ING extended the
application of the phase 1 reliefs to those hedge accounting relationships that will be subject to WIBOR
reform.
Hedging relationships are being amended to incorporate the new benchmark rates. During 2022, ING
focussed on USD LIBOR contracts. In the coming year, ING will continue the focus on the remaining USD
LIBOR contracts as the used USD LIBOR tenors will cease to be published on 30 June 2023.
As of 31 December 2022, USD LIBOR and WIBOR indexed fair value and cash flow hedges are directly
affected by the uncertainties arising from the IBOR reform. In particular, uncertainties over the timing and
amount of the replacement rate may impact the effectiveness and highly probable assessment.
For these affected fair value and cash flow hedge relationships ING assumes that the USD LIBOR and WIBOR
based cash flows from the hedging instrument and hedged item will remain unaffected.
The same assumption is used to assess the likelihood of occurrence of the forecast transactions that are
subject to cash flow hedges. The hedged cash flows in cash flow hedges directly impacted by the IBOR

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> 35 Fair value of assets and liabilities
ING Bank Annual Report 2022 206
reform still meet the highly probable requirement, assuming the USD LIBOR and WIBOR benchmark on
which the hedged cash flows are based is not altered as a result of the reform.
The total gross notional amounts of hedging instruments as at 31 December that are used in the ING's
hedge accounting relationships for which the Phase 1 amendments to IAS39 were applied are:

Notional amounts of Hedging instruments in EUR mln as at 31 December
Benchmark | 2022 | 2021
USD LIBOR | 28,316 | 41,473
WIBOR 1 | 57,774 |

1 WIBOR transition plans became concrete in 2022 and therefore no comparatives for 2021 are included.
Approximately 89% (31 December 2021: 72%) of the notional amounts for USD LIBOR have a maturity date
beyond 30 June 2023. Approximately 71% of the notional amounts for WIBOR have a maturity date beyond
1 January 2025.
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.
TLTRO
ING hedged the interest rate risk of the TLTRO-III funding with derivatives and designated this in a fair value
hedge relationship. In Q4 2022 the ECB changed the terms of the TLTRO-III, resulting in the discontinuation
of the hedging relationship. The fair value hedge adjustment was amortized to profit or loss over the revised
interest period (i.e. until the date the change in TLTRO-III terms became effective). The impact of this is
recorded in net interest income. Refer to Note 20 'Net interest income' for more details.
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
manage market risk, including interest rate risk, is discussed in ‘Risk management –Market risk’. ING’s
exposure to interest rate risk is disclosed in paragraph ‘Interest rate risk in banking book’.
ING Bank designates specific non-contractual risk components of hedged items. This is usually determined
by designating benchmark interest rates such as EURIBOR, SOFR, SONIA or TONAR, between others.
By using derivative financial instruments to hedge exposures to changes in interest rates, ING also exposes
itself to credit risk of the derivative counterparty, which is not offset by the hedged item. ING minimises
counterparty credit risk in derivative instruments by clearing most of the derivatives through Central
Clearing Counterparties. In addition, ING only enters into transactions with high-quality counterparties and
requires posting collateral.
ING applies fair value hedge accounting on micro level in which one hedged item is hedged with one or
multiple hedging instruments as well as on macro level whereby a portfolio of items is hedged with multiple
hedging instruments. For these macro hedges of interest rate risk ING applies the EU carve-out. The EU
‘carve-out’ for macro hedging enables a group of derivatives (or proportions) to be viewed in combination
and jointly designated as the hedging instrument and removes some of the limitations in fair value hedge
accounting relating to hedging core deposits and under-hedging strategies. In retail operations, exposure on
retail funding (savings and current accounts) and retail lending (mortgages) is initially offset. The remaining
exposure is hedged in a portfolio hedge, using the EU carve-out, in which a portion of the retail lending
portfolio and core deposits are designated as a hedged item for hedge accounting purposes.
For portfolio hedges the fair value is projected based on contractual terms and other variables including
prepayment expectations. These projected fair value of the portfolios form the basis for identifying the
notional amount subject to interest rate risk that is designated under fair value hedge accounting.
Micro fair value hedge accounting is mainly applied on issued debt securities and purchased debt
instruments for hedging interest rate risk.
Before fair value hedge accounting is applied, ING determines whether an economic relationship between
the hedged item and the hedging instrument exists based on an evaluation of the quantitative
characteristics of these items and the hedged risk that is supported by quantitative analysis. ING considers
whether the critical terms of the hedged item and hedging instrument closely align when assessing the
presence of an economic relationship. ING evaluates whether the fair value of the hedged item and the
hedging instrument respond similarly to similar risks. In addition, ING is mainly using regression analysis to
assess whether the hedging instrument is expected to be and has been highly effective in offsetting
changes in the fair value of the hedged item.
For the macro hedge on the loan portfolio ING follows a dynamic hedging strategy. This means that on
monthly basis, based on the new portfolio projection, the hedging relationship is renewed. From an
operational point of view, the existing hedging relationship is adjusted based on the new portfolio projection
and additional hedging instruments are added to the hedging relationship.

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> 36 Derivatives and hedge accounting
ING Bank Annual Report 2022 207
ING uses the following derivative financial instruments in a fair value hedge accounting relationship:

Gross carrying value of derivatives designated under fair value hedge accounting
in EUR million | Assets 2022 | Liabilities 2022 | Assets 2021 | Liabilities 2021
As at 31 December |  |  |  |
Hedging instrument on interest rate risk |  |  |  |
– Interest rate swaps | 40,346 | 32,482 | 6,629 | 5,940
– Other interest derivatives | 395 | 39 | 87 | 83

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 836 million (2021:
EUR 365 million) respectively ‘Financial liabilities at fair value through profit or loss – Non-trading derivatives’
EUR 244 million (2021: EUR 270 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 0.54% (2021: 0.20%) for EUR and 3.86% (2021: 3.83%) 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 |  |  |  |  |  |  |  |  |
As at 31 December 2022 | Less than 1 month | 1 to 3 months | 3 to 12 months | 1 to 2 year | 2 to 3 years | 3 to 4 years | 4 to 5 years | >5 years | Total
Hedging instrument on interest rate risk |  |  |  |  |  |  |  |  |
– Interest rate swaps | -15 | -3,184 | -1,343 | -677 | 6,864 | 5,396 | 8,204 | -29,530 | -14,284
– Other interest derivatives | -10 | -55 | -190 | 180 | 61 | 349 | 147 | 933 | 1,416
As at 31 December 2021 |  |  |  |  |  |  |  |  |
Hedging instrument on interest rate risk |  |  |  |  |  |  |  |  |
- Interest rate swaps | -242 | 2,807 | -3,150 | -6,593 | -4,428 | -4,347 | 2,310 | 2,278 | -11,363
– Other interest derivatives |  | -102 | -237 | -286 | 153 | 119 | 243 | 1,026 | 917

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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> 36 Derivatives and hedge accounting
ING Bank Annual Report 2022 208

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 used for measuring ineffectiveness for the period | Change in fair value hedging instruments | Hedge ineffectiveness recognised in the statement of profit or loss gain (+) / loss (-)
in EUR million | Assets | Liabilities | Assets | Liabilities |  |  |
As at 31 December 2022 |  |  |  |  |  |  |
Interest rate risk |  |  |  |  |  |  |
– Debt securities at fair value through other comprehensive income | 19,816 |  | n/a |  | -2,798 |  |
– Loans at FVOCI | 35 |  | n/a |  | -4 |  |
– Loans and advances to customers | 58,673 |  | -12,112 |  | -11,466 |  |
– Debt instruments at amortised cost | 4,098 |  | -448 |  | -678 |  |
– Debt securities in issue |  | 26,040 |  | -2,815 | 3,746 |  |
– Subordinated loans |  | 15,767 |  | -1,344 | 1,470 |  |
– Amounts due to banks |  |  |  |  | 483 |  |
– Customer deposits and other funds on deposit |  | 36,843 |  | -3,373 | 4,099 |  |
– Discontinued hedges |  |  | 2,966 | 34 |  |  |
Total | 82,623 | 78,650 | -9,594 | -7,497 | -5,150 | 5,265 | 115
As at 31 December 2021 |  |  |  |  |  |  |
Interest rate risk |  |  |  |  |  |  |
– Debt securities at fair value through other comprehensive income | 17,307 |  | n/a |  | -798 |  |
– Loans at FVOCI | 105 |  | n/a |  | -2 |  |
– Loans and advances to customers | 68,704 |  | -923 |  | -1,451 |  |
– Debt instruments at amortised cost | 3,458 |  | 301 |  | -165 |  |
– Debt securities in issue |  | 22,553 |  | 945 | 962 |  |
– Subordinated loans |  | 16,559 |  | 115 | 414 |  |
– Amounts due to banks |  |  |  |  |  |  |
– Customer deposits and other funds on deposit |  | 40,924 |  | 385 | 1,152 |  |
– Discontinued hedges |  |  | 3,774 | 73 |  |  |
Total | 89,574 | 80,037 | 3,153 | 1,518 | 112 | -86 | 26

During 2022, the interest rate movements significantly affected the fair value changes of both the
derivatives and the hedged items designated in fair value hedges. Refer to note 22 ‘Valuation results and
net trading income'.
In addition, the decrease in customer deposits is due to the discontinuation of the customer deposits
portfolio fair value hedge in Belgium. This hedge was discontinued and the related fair value adjustment
released due to changes in expected repricing of client rates as a result of the steep increase in interest

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> 36 Derivatives and hedge accounting
ING Bank Annual Report 2022 209
rates occurred in 2022. Discontinued hedges further mainly relate to the transfer of derivatives from UK
based clearing houses to EU based clearing houses related to Brexit in 2020.
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).
Additionally, for portfolio (macro) fair value hedges of ING’s fixed rate mortgage portfolio, ineffectiveness
also arises from the disparity between expected and actual prepayments (prepayment risk).
There were no other sources of significant ineffectiveness in these hedging relationships.
Cash flow hedge accounting
ING applies cash flow hedge accounting on 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 – Credit risk and 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 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 | 2022 | 2022 | 2021 | 2021
As at 31 December |  |  |  |
Hedging instrument on interest rate risk |  |  |  |
– Interest rate swaps | 10,038 | 14,836 | -437 | 781
Hedging instrument on combined interest and FX rate risk |  |  |  |
– Cross currency interest rate derivatives | 428 | 168 | 73 | 285

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 814 million (2021:
EUR 300 million) respectively ‘Financial liabilities at fair value through profit or loss – Non-trading derivatives’
EUR 1,275 million (2021: EUR 485 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 0.51% (2021: -0.16%) for EUR, 3.27% (2021: 1.73%) for PLN, 1.96% (2021: 2.09%) for USD and 1.28%
(2021: 0.55%) for AUD. The average currency exchange rates for cross currency swaps used in cash flow
hedge accounting is for EUR/USD 0.99 (2021: 1.01) and for EUR/AUD 1.58 (2021: 1.61).
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.

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> 36 Derivatives and hedge accounting
ING Bank Annual Report 2022 210

Maturity derivatives designated in cash flow hedging
in EUR million |  |  |  |  |  |  |  |  |
As at 31 December 2022 | Less than 1 month | 1 to 3 months | 3 to 12 months | 1 to 2 year | 2 to 3 years | 3 to 4 years | 4 to 5 years | >5 years | Total
Hedging instrument on interest rate risk |  |  |  |  |  |  |  |  |
– Interest rate swaps | -562 | -935 | -6,730 | -12,464 | -8,926 | -8,115 | -3,620 | -8,947 | -50,300
Hedging instrument on combined interest and FX rate risk |  |  |  |  |  |  |  |  |
– Cross currency interest rate derivatives |  | -834 | -1,535 | -721 | -2,140 | -52 | 7 | -48 | -5,323
As at 31 December 2021 |  |  |  |  |  |  |  |  |
Hedging instrument on interest rate risk |  |  |  |  |  |  |  |  |
– Interest rate swaps | 418 | -1,075 | -6,939 | -5,470 | -6,711 | -5,825 | -5,272 | -18,107 | -48,982
Hedging instrument on combined interest and FX rate risk |  |  |  |  |  |  |  |  |
– Cross currency interest rate derivatives | -256 | -1,048 | -1,760 | -3,831 | -2,528 | -2,580 | 181 | -56 | -11,878

The following table shows the cash flow hedge accounting impact on profit or loss and comprehensive
income:

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> 36 Derivatives and hedge accounting
ING Bank Annual Report 2022 211

Cash flow hedging – impact of hedging instruments on the statement of profit or loss and other comprehensive income
in EUR million | Change in value of hedged item used for calculating hedge ineffectiveness for the period | Carrying amount cash flow hedge reserve at the end of the reporting period 1 | Amount reclassified from CFH reserve to profit or loss | Cash flow is no longer expected to occur | 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 2022 |  |  |  |  |  |
Interest rate risk on; |  |  |  |  |  |
– Floating rate lending | 4,817 | -5,460 | 395 |  |  |
– Floating rate borrowing | -775 | 923 | -181 |  |  |
– Other | -5 | -2 |  |  |  |
– Discontinued hedges |  | 330 | -263 |  |  |
Total interest rate risk | 4,037 | -4,210 | -50 |  | -4,279 | 21
Combined interest and FX rate risk on; |  |  |  |  |  |
– Floating rate lending | -47 | -16 | -269 |  |  |
– Floating rate borrowing | -7 | -4 | 14 |  |  |
– Other | 4 | -2 | -3 |  |  |
– Discontinued hedges |  | 4 | -5 |  |  |
Total combined interest and Fx | -51 | -18 | -263 |  | 296 | -1
Total cash flow hedge | 3,986 | -4,227 | -313 |  | -3,982 | 20
As at 31 December 2021 |  |  |  |  |  |
Interest rate risk on; |  |  |  |  |  |
– Floating rate lending | 2,937 | -1,132 | -454 |  |  |
– Floating rate borrowing | -915 | 366 | 143 |  |  |
– Other | 165 | -122 | 15 |  |  |
– Discontinued hedges |  | 674 | -306 |  |  |
Total interest rate risk | 2,188 | -214 | -603 |  | -1,825 | -2
Combined interest and FX rate risk on; |  |  |  |  |  |
– Floating rate lending | -90 | -19 | -153 |  |  |
– Floating rate borrowing | -2 | -16 | 9 |  |  |
– Other |  | -1 | -1 |  |  |
– Discontinued hedges |  | -13 | -90 |  |  |
Total combined interest and Fx | -92 | -49 | -235 |  | 250 | 3
Total cash flow hedge | 2,096 | -262 | -838 |  | -1,574 | 1

1 The carrying amount is the gross amount, excluding tax adjustments.
The decrease in the carrying amount of the cash flow hedge reserve is driven by increased interest rates.

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> 36 Derivatives and hedge accounting
ING Bank Annual Report 2022 212
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.
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 not
doing so it is 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. The gains and losses on ineffective portions are
recognised immediately in the statement of profit or loss in 'Valuation results and net trading income'.
ING has the following derivative financial instruments used for net investment hedging:

Gross carrying value of derivatives used for net investment hedging
| Assets | Liabilities | Assets | Liabilities
in EUR million | 2022 | 2022 | 2021 | 2021
As at 31 December |  |  |  |
– FX forwards and Cross currency swaps | 119 | 83 | 18 | 88

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 119 million
(2021: EUR 18 million) respectively ‘Financial liabilities at fair value through profit or loss – Non trading
derivatives’ EUR 83 million (2021: EUR 88 million).
For ING’s main currencies the average exchange rates used in net investment hedge accounting for 2022
are EUR/USD 1.06 (2021: 1.18), EUR/PLN 4.68 (2021: 4.58), EUR/AUD 1.52 (2021: 1.58) and EUR/THB 36.87
(2021: 37.84).
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 |  |  |  |  |  |  |  |  |
As at 31 December 2022 | Less than 1 month | 1 to 3 months | 3 to 12 months | 1 to 2 year | 2 to 3 years | 3 to 4 years | 4 to 5 years | >5 years | Total
– FX forwards and cross currency swaps | -6,164 | -2,638 | -97 |  |  |  |  |  | -8,899
As at 31 December 2021 |  |  |  |  |  |  |  |  |
– FX forwards and Cross currency swaps | -4,462 | -461 | -590 |  |  |  |  |  | -5,514

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 |  |  |  |  |
As at 31 December 2022 | Change in value used for calculating hedge ineffectiveness for the period | Carrying amount net investment hedge reserve at the end of the reporting period 1 | 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(-)
Investment in foreign operations | 0 | -33 |  | 0 | 0
Discontinued hedges |  | 304 | -1 |  |
As at 31 December 2021 |  |  |  |  |
Investment in foreign operations | 72 | 330 |  | -72 | -1
Discontinued hedges |  | -59 |  |  |

1 The carrying amount is the gross amount, excluding tax adjustments.

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> 36 Derivatives and hedge accounting
ING Bank Annual Report 2022 213
37 Assets by contractual maturity
Amounts presented in these tables 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’.

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> 37 Assets by contractual maturity
ING Bank Annual Report 2022 214

Assets by contractual maturity
2022 | 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 | 87,614 |  |  |  |  |  | 87,614
Loans and advances to banks | 28,733 | 1,633 | 2,331 | 2,190 | 216 |  | 35,103
Financial assets at fair value through profit or loss |  |  |  |  |  |  |
– Trading assets | 15,520 | 5,399 | 9,991 | 13,062 | 12,904 |  | 56,875
– Non-trading derivatives | 623 | 95 | 592 | 1,555 | 1,027 |  | 3,893
– Mandatorily at fair value through profit or loss | 29,153 | 10,504 | 3,753 | 2,329 | 901 | 203 | 46,844
– Designated as at fair value through profit or loss | 287 | 158 | 185 | 2,497 | 3,031 |  | 6,159
Financial assets at fair value through other comprehensive income |  |  |  |  |  |  |
– Equity securities |  |  |  |  |  | 1,887 | 1,887
– Debt securities | 167 | 420 | 2,458 | 12,587 | 13,463 |  | 29,095
– Loans and advances | 3 | 1 | 7 | 226 | 407 |  | 643
Securities at amortised cost | 1,810 | 1,719 | 4,566 | 24,689 | 15,376 |  | 48,160
Loans and advances to customers | 54,482 | 23,554 | 54,056 | 197,275 | 306,190 |  | 635,557
Other assets 2 | 7,151 | 272 | 1,154 | 1,436 | 1,418 | 4,600 | 16,031
Total assets | 225,545 | 43,754 | 79,093 | 257,846 | 354,933 | 6,690 | 967,861
2021 |  |  |  |  |  |  |
Cash and balances with central banks | 106,520 |  |  |  |  |  | 106,520
Loans and advances to banks | 15,162 | 2,204 | 3,921 | 1,937 | 367 |  | 23,591
Financial assets at fair value through profit or loss |  |  |  |  |  |  |
– Trading assets | 21,055 | 3,859 | 8,735 | 7,922 | 9,818 |  | 51,389
– Non-trading derivatives | 240 | 171 | 217 | 421 | 488 |  | 1,536
– Mandatorily at fair value through profit or loss | 20,462 | 12,063 | 7,487 | 1,741 | 770 | 161 | 42,684
– Designated as at fair value through profit or loss | 96 | 120 | 520 | 2,510 | 3,109 |  | 6,355
Financial assets at fair value through other comprehensive income |  |  |  |  |  |  |
– Equity securities |  |  |  |  |  | 2,457 | 2,457
– Debt securities | 593 | 518 | 1,926 | 11,182 | 13,121 |  | 27,340
– Loans and advances | 14 | 11 | 173 | 214 | 427 |  | 838
Securities at amortised cost | 1,108 | 1,217 | 4,509 | 24,413 | 17,072 |  | 48,319
Loans and advances to customers | 52,311 | 26,414 | 53,616 | 188,222 | 306,988 |  | 627,550
Other assets 2 | 3,823 | 362 | 1,505 | 841 | 1,482 | 4,725 | 12,738
Total assets | 221,382 | 46,940 | 82,608 | 239,401 | 353,642 | 7,343 | 951,317

1 Includes assets on demand.
2 Includes other financial assets such as current and deferred tax assets as presented in the consolidated statement of the financial position. Additionally, non-financial assets are included in that position where maturities are not applicable 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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> 37 Assets by contractual maturity
ING Bank Annual Report 2022 215
38 Liabilities and off-balance sheet commitments by maturity
The tables below include all liabilities and off-balance sheet commitments by maturity based on
contractual, undiscounted cash flows. These balances are included in the maturity analysis as follows:
•Perpetual liabilities are included in the column ‘Maturity not applicable’.
•Derivative liabilities are included on a net basis if cash flows are settled net. For other derivative liabilities
the contractual gross cash flow payable is included.
•Undiscounted future coupon interest on financial liabilities payable is included in a separate line and in
the relevant maturity bucket.
•Non-financial liabilities are included based on a breakdown of the amounts per statement of financial
position, per expected maturity.
•Loans and other credit-related commitments are classified on the basis of the earliest date they can be
drawn down.
ING Bank’s expected cash flows on some financial liabilities vary significantly from contractual cash flows.
Principal differences are in demand deposits from customers that are expected to remain stable or increase
and in unrecognised loan commitments that are not all expected to be drawn down immediately. Reference
is made to the liquidity risk paragraph in ‘Risk Management – Funding and liquidity risk’ for a description on
how liquidity risk is managed.

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> 38 Liabilities and off-balance sheet commitments by maturity
ING Bank Annual Report 2022 216

Liabilities and off-balance sheet commitments by maturity
in EUR million |  |  |  |  |  |  |  |
2022 | 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 | 10,053 | 2,238 | 33,268 | 9,878 | 1,794 |  | -598 | 56,632
Customer deposits | 605,706 | 16,294 | 22,637 | 24,641 | 20,304 |  | -3,240 | 686,341
Financial liabilities at fair value through profit or loss |  |  |  |  |  |  |  |
– Other trading liabilities | 5,778 | 875 | 304 | 771 | 575 |  | -83 | 8,219
– Trading derivatives | 2,100 | 2,319 | 4,942 | 9,330 | 3,609 |  | 8,570 | 30,869
– Non-trading derivatives | 345 | 288 | 216 | 1,204 | 470 |  | 525 | 3,048
– Designated at fair value through profit or loss | 31,505 | 11,472 | 1,626 | 3,177 | 3,699 | 21 | -618 | 50,883
Debt securities in issue | 2,049 | 11,227 | 18,626 | 12,857 | 15,905 |  | -2,587 | 58,075
Subordinated loans |  |  | 760 |  | 9,936 | 6,307 | -1,214 | 15,789
Lease liabilities | 19 | 43 | 170 | 593 | 377 |  | -28 | 1,174
Financial liabilities | 657,554 | 44,755 | 82,548 | 62,450 | 56,668 | 6,328 | 727 | 911,030
Other liabilities 3 | 9,659 | 683 | 2,395 | 638 | 406 |  |  | 13,781
Total liabilities | 667,213 | 45,438 | 84,943 | 63,089 | 57,074 | 6,328 | 727 | 924,811
Coupon interest due on financial liabilities | 426 | 719 | 3,171 | 6,408 | 3,166 | 348 |  | 14,237
Contingent liabilities in respect of |  |  |  |  |  |  |  |
– Discounted bills |  |  |  |  |  |  |  |
– Guarantees | 28,304 |  |  | 4 | 550 |  |  | 28,859
– Irrevocable letters of credit | 15,660 | 19 | 3 |  |  |  |  | 15,682
– other |  |  |  |  | 3 |  |  | 3
Irrevocable facilities | 161,147 |  | 194 | 434 | 166 |  |  | 161,940
| 205111.478 | 18.786 | 197.475 | 438.013 | 718.593 | 0 | 0 | 206,484

1 Includes liabilities on demand.
2 This 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).
3 Includes Other liabilities, Current and deferred tax liabilities, and Provisions as presented in the Consolidated statement of financial position.

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> 38 Liabilities and off-balance sheet commitments by maturity
ING Bank Annual Report 2022 217

Liabilities and off-balance sheet commitments by maturity
in EUR million |  |  |  |  |  |  |  |
2021 | 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 | 10,477 | 1,062 | 1,387 | 71,413 | 1,719 |  | -967 | 85,092
Customer deposits | 597,906 | 14,989 | 6,849 | 17,814 | 19,718 |  | 557 | 657,831
Financial liabilities at fair value through profit or loss |  |  |  |  |  |  |  |
– Other trading liabilities | 6,965 | 397 | 322 | 462 | 438 |  | 4 | 8,588
– Trading derivatives | 1,689 | 1,608 | 3,674 | 8,295 | 5,731 |  | -2,472 | 18,525
– Non-trading derivatives | 546 | 245 | 422 | 900 | 571 |  | -564 | 2,120
– Designated at fair value through profit or loss | 24,862 | 10,224 | 771 | 1,850 | 3,719 | 20 | 362 | 41,808
Debt securities in issue | 2,766 | 15,826 | 15,459 | 9,667 | 12,581 |  | 1,145 | 57,443
Subordinated loans |  |  |  | 716 | 8,948 | 6,822 | 233 | 16,719
Lease liabilities | 18 | 40 | 159 | 571 | 454 |  | -23 | 1,220
Financial liabilities | 645,229 | 44,391 | 29,042 | 111,688 | 53,880 | 6,843 | -1,725 | 889,346
Other liabilities 3 | 8,810 | 487 | 2,500 | 591 | 934 |  |  | 13,321
Total liabilities | 654,039 | 44,877 | 31,541 | 112,279 | 54,813 | 6,843 | -1,725 | 902,668
Coupon interest due on financial liabilities | 195 | 407 | 1,010 | 2,602 | 2,727 | 387 |  | 7,328
Contingent liabilities in respect of |  |  |  |  |  |  |  |
– Discounted bills |  |  |  |  |  |  |  |
– Guarantees | 25,911 |  |  |  | 550 |  |  | 26,461
– Irrevocable letters of credit | 16,851 |  |  |  |  |  |  | 16,851
– other | 1 |  | 2 | 5 |  |  |  | 8
Irrevocable facilities4 | 143,891 | 1 | 13 | 184 | 78 |  |  | 144,167
| 186,653 | 1 | 15 | 189 | 628 | 0 | 0 | 187,486

1 Includes liabilities on demand.
2 This 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).
3 Includes Other liabilities, Current and deferred tax liabilities, and Provisions as presented in the Consolidated statement of financial position.

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> 38 Liabilities and off-balance sheet commitments by maturity
ING Bank Annual Report 2022 218
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 Loans and advances to customers pledged to
secure Debt securities in issue, deposits from the Dutch Central Bank and other banks, as well as debt
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 | 2022 | 2021
Banks |  |
– Cash and balances with central banks | 364 | 465
– Loans and advances to banks | 4,007 | 3,310
Financial assets at fair value through profit or loss | 17,079 | 15,334
Financial assets at fair value through OCI | 2,142 | 2,320
Securities at amortised cost | 3,578 | 4,468
Loans and advances to customers | 98,917 | 118,868
Other assets | 596 | 796
| 126,682 | 145,560

In addition, in some jurisdictions ING Bank N.V. has an obligation to maintain a reserve with central banks.
As at 31 December 2022, the minimum mandatory reserve deposits with various central banks amount to
EUR 11,108 million (2021: EUR 10,625 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 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 | 2022 | 2021
Total received collateral available for sale or repledge at fair value |  |
– equity securities | 22,847 | 27,553
– debt securities | 103,723 | 67,696
of which sold or repledged at fair value |  |
– equity securities | 18,613 | 23,330
– debt securities | 66,636 | 50,366

Transfer of financial assets
The majority of ING's financial assets that have been transferred, but do not qualify for derecognition are
debt instruments used in securities lending or sale and repurchase transactions.

Transfer of financial assets not qualifying for derecognition
| Securities lending | Sale and repurchase
| Equity | Debt | Equity | Debt
in EUR million | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Transferred assets at carrying amount |  |  |  |  |  |  |  |
Financial assets at fair value through profit or loss | 2,087 | 3,109 |  |  | 6,357 | 4,384 | 7,178 | 5,863
Financial assets at fair value through other comprehensive income |  |  | 499 |  |  |  | 453 | 527
Loans and advances to customers |  |  |  |  |  |  | 4,637 | 4,386
Securities at amortised cost |  |  | 435 |  |  |  | 261 | 992
Associated liabilities at carrying amount1 |  |  |  |  |  |  |  |
Financial liabilities at fair value through profit or loss | n/a | n/a | n/a | n/a | 6,245 | 4,130 | 8,932 | 7,538

1 The table includes the associated liabilities which are reported after offsetting, compared to the gross positions of the encumbered
assets.
2 The prior period on Financial assets at fair value through other comprehensive income and Securities at amortised cost has been
updated to improve consistency and comparability
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 45 'Structured entities'.

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> 39 Transfer of financial assets, assets pledged and received as collateral
ING Bank Annual Report 2022 219
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 Bank amounts that are offset mainly relate to derivatives transactions, sale and repurchase
agreements, securities lending agreements and cash pooling arrangements. A significant portion of
offsetting is applied to OTC derivatives which are cleared through central clearing parties.
Related amounts not set off 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 set off 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-collateralisation is excluded.
The net amounts resulting after set off 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 in the Risk Management Credit risk’ section ‘Credit risk
mitigation'.

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> 40 Offsetting financial assets and liabilities
ING Bank Annual Report 2022 220

Financial assets subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million 2022 |  | 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
Financial instruments | Cash and financial instruments received as collateral
Statement of financial position line item | Financial instrument |  |  |  |  |  |  |  |
Loans and advances to banks 2 | Reverse repurchase, securities borrowing and similar agreements | 2,576 |  | 2,576 |  | 2,549 | 27 | 16,820 | 19,395
| Other | 1 |  | 1 | 1 |  |  | -1 |
|  | 2,576 |  | 2,576 | 1 | 2,549 | 27 | 16,819 | 19,395
Financial assets at fair value through profit or loss |  |  |  |  |  |  |  |  |
Trading and Non-trading | Reverse repurchase, securities borrowing and similar agreements | 51,870 | -21,245 | 30,625 | 102 | 29,813 | 710 | 22,260 | 52,886
| Derivatives | 134,253 | -106,523 | 27,730 | 18,190 | 4,525 | 5,015 | 7,004 | 34,734
|  | 186,123 | -127,768 | 58,355 | 18,292 | 34,337 | 5,726 | 29,264 | 87,619
Loans and advances to customers 3 | Reverse repurchase, securities borrowing and similar agreements | 155 |  | 155 |  | 155 |  | 1,151 | 1,306
| Cash pools | 224,261 | -222,857 | 1,404 | 74 | 889 | 441 |  | 1,404
|  | 224,416 | -222,857 | 1,559 | 74 | 1,044 | 441 | 1,151 | 2,710
Other items where offsetting is applied in the statement of financial position 4 |  | 6,750 | -5,899 | 851 | 74 |  | 777 |  | 851
Total financial assets |  | 419,865 | -356,524 | 63,341 | 18,440 | 37,930 | 6,971 | 47,234 | 110,576

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’.
2 At 31 December 2022, the total amount of ‘Loans and advances to banks’ excluding repurchase agreements is EUR 15,708 million which is not subject to offsetting.
3 At 31 December 2022, the total amount of ‘Loans and advances to customers’ excluding repurchase agreements is EUR 634,251 million of which the net cash pool position of EUR 1,404 million is subject to offsetting.
4 Other items mainly 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 5,190 million in the statement of financial position of which EUR 851 million
is subject to offsetting as at 31 December 2022.

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> 40 Offsetting financial assets and liabilities
ING Bank Annual Report 2022 221

Financial assets subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million 2021 |  | 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
Financial instruments | Cash and financial instruments received as collateral
Statement of financial position line item | Financial instrument |  |  |  |  |  |  |  |
Loans and advances to banks 2 | Reverse repurchase, securities borrowing and similar agreements | 1,930 |  | 1,930 |  | 1,923 | 7 | 1,473 | 3,403
| Other | 1 | -1 |  |  |  |  |  |
|  | 1,931 | -1 | 1,930 |  | 1,923 | 7 | 1,473 | 3,403
Financial assets at fair value through profit or loss |  |  |  |  |  |  |  |  |
Trading and Non-trading | Reverse repurchase, securities borrowing and similar agreements | 43,822 | -11,564 | 32,258 | 168 | 31,848 | 243 | 15,590 | 47,848
| Derivatives | 52,724 | -38,431 | 14,293 | 9,005 | 3,108 | 2,180 | 7,006 | 21,299
|  | 96,546 | -49,995 | 46,552 | 9,172 | 34,956 | 2,423 | 22,596 | 69,148
Loans and advances to customers 3 | Reverse repurchase, securities borrowing and similar agreements | 71 |  | 71 |  | 71 |  |  | 71
| Cash pools | 196,328 | -194,522 | 1,806 | 19 | 1,417 | 369 |  | 1,806
|  | 196,400 | -194,522 | 1,878 | 19 | 1,489 | 369 |  | 1,878
Other items where offsetting is applied in the statement of financial position 4 |  | 3,692 | -3,470 | 222 |  |  | 222 |  | 222
Total financial assets |  | 298,569 | -247,987 | 50,581 | 9,191 | 38,368 | 3,022 | 24,069 | 74,650

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’.
2 At 31 December 2021, the total amount of ‘Loans and advances to banks’ excluding repurchase agreements is EUR 20,188 million which is not subject to offsetting.
3 At 31 December 2021, the total amount of ‘Loans and advances to customers’ excluding repurchase agreements is EUR 627,063 million of which the net cash pool position of EUR 1,806 million is subject to offsetting.
4 Other items mainly 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 2,424 million in the statement of financial position of which EUR 222 million
is subject to offsetting as at 31 December 2021.

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> 40 Offsetting financial assets and liabilities
ING Bank Annual Report 2022 222

Financial liabilities subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million 2022 |  |  |  |  | Related amounts not offset in the statement of financial position |  | Amounts not subject to enforceable netting arrangements | Statement of financial position total ¹
| Gross amounts of recognised financial liabilities | Gross amounts of recognised financial assets offset in the statement of financial position | Net amounts of financial liabilities presented in the statement of financial position | Financial instruments | Cash and financial instruments pledged as collateral | Net amount
Statement of financial position line item | Financial instrument |  |  |  |  |  |  |  |
Deposits from banks 2 | Repurchase, securities lending and similar agreements |  |  |  |  |  |  | 3,809 | 3,809
| Other |  |  |  |  |  |  |  |
|  |  |  |  |  |  |  | 3,809 | 3,809
Customer deposits 3 | Repurchase, securities lending and similar agreements |  |  |  |  |  |  |  |
| Cash pools | 236,219 | -222,857 | 13,362 | 52 |  | 13,310 |  | 13,362
|  | 236,219 | -222,857 | 13,362 | 52 |  | 13,310 |  | 13,362
Financial liabilities at fair value through profit or loss |  |  |  |  |  |  |  |  |
Trading and Non-trading | Repurchase, securities lending and similar agreements | 57,871 | -21,245 | 36,626 | 102 | 31,868 | 4,655 | 12,220 | 48,846
| Derivatives | 127,937 | -103,988 | 23,949 | 18,215 | 4,964 | 770 | 9,967 | 33,917
|  | 185,808 | -125,233 | 60,575 | 18,317 | 36,833 | 5,425 | 22,187 | 82,762
Other items where offsetting is applied in the statement of financial position 4 |  | 8,535 | -8,435 | 100 | 70 |  | 30 |  | 100
Total financial liabilities |  | 430,561 | -356,524 | 74,037 | 18,440 | 36,833 | 18,765 | 25,996 | 100,033

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’.
2 At 31 December 2022, the total amount of ‘Deposits from banks’ excluding repurchase agreements is EUR 52,823 million of which EUR 0 million is subject to offsetting.
3 At 31 December 2022, the total amount of ‘Customers deposits’ excluding repurchase agreements is EUR 686,341 million of which the net cash pool position of EUR 13,362 million is subject to offsetting.
4 Other items mainly 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 6,714 million in the statement of financial position of which EUR 100
million is subject to offsetting as at 31 December 2022.

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> 40 Offsetting financial assets and liabilities
ING Bank Annual Report 2022 223

Financial liabilities subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million 2021 |  |  |  |  | Related amounts not offset in the statement of financial position |  | Amounts not subject to enforceable netting arrangements | Statement of financial position total ¹
| Gross amounts of recognised financial liabilities | Gross amounts of recognised financial assets offset in the statement of financial position | Net amounts of financial liabilities presented in the statement of financial position | Financial instruments | Cash and financial instruments pledged as collateral | Net amount
Statement of financial position line item | Financial instrument |  |  |  |  |  |  |  |
Deposits from banks 2 | Repurchase, securities lending and similar agreements | 433 |  | 433 |  | 426 | 7 | 3,705 | 4,138
| Other | 3 | -1 | 2 |  |  | 2 |  | 2
|  | 436 | -1 | 435 |  | 426 | 9 | 3,705 | 4,140
Customer deposits 3 | Repurchase, securities lending and similar agreements |  |  |  |  |  |  |  |
| Cash pools | 207,930 | -194,522 | 13,408 | 19 |  | 13,389 |  | 13,408
|  | 207,930 | -194,522 | 13,408 | 19 |  | 13,389 |  | 13,408
Financial liabilities at fair value through profit or loss |  |  |  |  |  |  |  |  |
Trading and Non-trading | Repurchase, securities lending and similar agreements | 43,883 | -11,564 | 32,319 | 168 | 32,056 | 96 | 9,416 | 41,735
| Derivatives | 53,778 | -39,053 | 14,725 | 9,006 | 4,326 | 1,393 | 5,920 | 20,646
|  | 97,661 | -50,617 | 47,044 | 9,173 | 36,382 | 1,489 | 15,337 | 62,381
Other items where offsetting is applied in the statement of financial position 4 |  | 3,098 | -2,848 | 250 | -1 |  | 252 |  | 250
Total financial liabilities |  | 309,125 | -247,987 | 61,138 | 9,191 | 36,808 | 15,139 | 19,041 | 80,179

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’.
2 At 31 December 2021, the total amount of ‘Deposits from banks’ excluding repurchase agreements is EUR 80,954 million of which EUR 2 million is subject to offsetting.
3 At 31 December 2021, the total amount of ‘Customers deposits’ excluding repurchase agreements is EUR 657,831 million of which the net cash pool position of EUR 13,408 million is subject to offsetting.
4 Other items mainly 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 5,082 million in the statement of financial position of which EUR 250
million is subject to offsetting as at 31 December 2021.

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> 40 Offsetting financial assets and liabilities
ING Bank Annual Report 2022 224
41 Contingent liabilities and commitments
In the normal course of business, ING Bank is party to activities where risks are not reflected in whole or in
part in the consolidated financial statements. In response to the needs of its customers, the Group offers
financial products related to loans. These products include traditional off-balance sheet credit-related
financial instruments.

Contingent liabilities and commitments
in EUR million | 2022 | 2021
Contingent liabilities in respect of |  |
– Guarantees | 28,859 | 26,461
– Irrevocable letters of credit | 15,682 | 16,851
– Other | 3 | 8
| 44,544 | 43,319
Irrevocable facilities | 161,940 | 144,167
| 206,484 | 187,486

Guarantees relate both to credit and non-credit substitute guarantees. Credit substitute guarantees are
guarantees given by ING Bank in respect of credit granted to customers by a third party. Many of them are
expected to expire without being drawn on and therefore do not necessarily represent future cash outflows.
Irrevocable letters of credit mainly secure payments to third parties for a customer’s foreign and domestic
trade transactions in order to finance a shipment of goods. ING Bank’s credit risk in these transactions is
limited since these transactions are collateralized by the commodity shipped and are of a short duration.
Other contingent liabilities include acceptances of bills and are of a short-term nature. Other contingent
liabilities also include contingent liabilities resulting from the operations of the Real Estate business including
obligations under development and construction contracts.
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 Bank’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 to the items included in contingent liabilities, ING Bank has issued certain guarantees as
participant in collective arrangements of national banking funds and as a participant in required collective
guarantee schemes which apply in different countries.
ING Bank N.V. provided a guarantee to the German Deposit Guarantee Fund (‘Einlagensicherungsfonds’ or
ESF) under section 5 (10) of the by-laws of this fund, where ING Bank N.V. indemnifies the Association of
German Banks Berlin against any losses it might incur as result of actions taken with respect to ING
Germany. The ESF is a voluntary collective guarantee scheme for retail savings and deposits in excess of EUR
100,000.
Furthermore we refer to Note 42 'Legal proceedings' for any contingent liabilities in respect of legal
proceedings.
42 Legal proceedings
ING Bank and its consolidated subsidiaries are involved in governmental, regulatory, arbitration and legal
proceedings and investigations in the Netherlands and in a number of foreign jurisdictions, including the
U.S., involving claims by and against them which arise in the ordinary course of their businesses, including in
connection with their activities as lenders, broker-dealers, underwriters, issuers of securities and investors
and their position as employers and taxpayers. In certain of such proceedings, very large or indeterminate
amounts are sought, including punitive and other damages. While it is not feasible to predict or determine
the ultimate outcome of all pending or threatened governmental, regulatory, arbitration and legal
proceedings and investigations, ING is of the opinion that some of 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 the ING and/or the 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.
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

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> 41 Contingent liabilities and commitments
ING Bank Annual Report 2022 225
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 AML process at
ING Luxembourg. Although this matter remains at an early procedural stage and it is currently not possible
to determine how this matter will be resolved or the timing of any such resolution, ING does not expect a
financial outcome of this matter to have a material effect.
Payvision is the subject of a criminal investigation by Dutch authorities regarding money laundering and
various requirements of the Dutch act on Anti-Money Laundering and Counter Terrorist Financing, focusing
on the period from 1 January 2015 up to and including April 2020. Payvision is cooperating with such
ongoing investigation. It is currently not feasible to determine how the ongoing investigation may be
resolved or the timing of any such resolution, nor to estimate reliably the possible timing, scope or amounts
of any resulting fines, penalties and/or other outcome.
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 the Issuer 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.
SIBOR – SOR litigation: In July 2016, investors in derivatives tied to the Singapore Interbank Offer Rate
(“SIBOR”) filed a U.S. class action complaint in the New York District Court alleging that several banks,
including ING, conspired to rig the prices of derivatives tied to SIBOR and the Singapore Swap Offer Rate
(“SOR”). The lawsuit refers to investigations by the Monetary Authority of Singapore (“MAS”) and other
regulators, including the U.S. Commodity Futures Trading Commission (“CFTC”), in relation to rigging prices
of SIBOR- and SOR based derivatives. In October 2018, the New York District Court issued a decision
dismissing all claims against ING Group and ING Capital Markets LLC, but leaving ING Bank, together with
several other banks, in the case, and directing plaintiffs to file an amended complaint consistent with the
Court's rulings. In October 2018, plaintiffs filed such amended complaint, which asserts claims against a
number of defendants but none against ING Bank (or any other ING entity), effectively dismissing ING Bank
from the case. In December 2018, plaintiffs sought permission from the Court to file a further amended
complaint that names ING Bank as a defendant. In July 2019, the New York District Court granted the
defendants’ motion to dismiss and denied leave to further amend the complaint, effectively dismissing all
remaining claims against ING Bank. In March 2021, the Second Circuit court vacated the District Court’s
ruling. The case was remanded to the District Court to reconsider the amended complaint that would add
ING Bank N.V. back to the case. In April 2021, the defendants filed a petition for rehearing with the Second
Circuit court. In May 2021, the Second Circuit court denied the defendants’ petition. In March 2022, plaintiffs
and ING executed a formal class settlement agreement. On 29 November 2022, the Court entered its final
judgement, approving ING’s settlement (and those of all other defendants) with plaintiffs. The case is now
closed.
Claims regarding accounts with predecessors of ING Bank Turkey: ING Bank Turkey has received numerous
claims from (former) customers of legal predecessors of ING Bank Turkey. 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 Turkey in 2007 from OYAK. Pursuant to the acquisition contract, ING can
claim compensation from SDIF if a court orders ING to pay amounts to the offshore account holders. SDIF
has made payments to ING pursuant to such compensation requests, but filed various lawsuits to receive
those amounts back. These lawsuits are ongoing. 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. The exact impact of this decision on the ongoing cases is not clear
yet. 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.
Interest rate derivatives claims: I NG is involved in several legal proceedings in the Netherlands with respect
to interest rate derivatives that were sold to clients in connection with floating interest rate loans in order to
hedge the interest rate risk of the loans. These proceedings are based on several legal grounds, depending
on the facts and circumstances of each specific case, inter alia alleged breach of duty of care, insufficient
information provided to the clients on the product and its risks and other elements related to the interest
rate derivatives that were sold to clients. In some cases, the court has ruled in favour of the claimants and
awarded damages, annulled the interest rate derivative or ordered repayment of certain amounts to the
claimants.
Interest surcharges claims: ING received complaints and was involved in litigation with certain individuals in
the Netherlands regarding increases in interest surcharges with respect to several credit products, including
but not limited to commercial property. ING has reviewed the relevant product portfolio. The provision
previously taken has been reversed for certain of these complaints. All claims are dealt with individually.
Thus far, the courts have ruled in favour of ING in each case, ruling that ING was allowed to increase the

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> 42 Legal proceedings
ING Bank Annual Report 2022 226
interest surcharge based upon the essential obligations in the contract. In a relevant case the Dutch
Supreme Court ruled in favor of another Dutch bank, addressing the question whether or not a bank is
allowed to increase interest surcharges unilaterally. The Supreme Court ruled affirmative and referred the
case to the Court of Appeal in The Hague. The Court of Appeal also ruled in favour of the Dutch bank in
October 2022. ING will continue to deal with all claims individually.
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 court
proceedings in first instance 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 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 Supreme Court published a press release informing of its decision to ask the European Court of
Justice 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. ING
Spain has also been 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 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 could be
appealed in the Supreme Court. A provision has been established in the past and has been adjusted where
appropriate.
Imtech claim: In January 2018, ING Bank received a claim from Stichting ImtechClaim.nl and Imtech
Shareholders Action Group B.V. on behalf of certain (former) shareholders of Imtech N.V. (“Imtech”).
Furthermore, in March 2018, ING Bank received another claim on the same subject matter from the Dutch
Association of Stockholders (Vereniging van Effectenbezitters, “VEB”). In June 2022, VEB reiterated and
further substantiated its claim in a letter to ING. Each of the claimants allege inter alia that shareholders
were misled by the prospectus of the rights issues of Imtech in July 2013 and October 2014. ING Bank, being
one of the underwriters of the rights issues, is held liable by the claimants for the damages that investors in
Imtech would have suffered. ING Bank responded to the claimants denying any and all responsibility in
relation to the allegations made in the relevant letters. In September 2018, the trustees in the bankruptcy of
Imtech claimed from various financing parties, including ING, payment of what the security agent has
collected following bankruptcy or intends to collect, repayment of all that was repaid to the financing
parties, as well as compensation for the repayment of the bridge financing. At this moment it is not possible
to assess the outcome of these claims nor to provide an estimate of the (potential) effect of these claims.
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. ING has recorded a portfolio provision with respect to the claims and the PFSA proposal. The Polish
Supreme Court was expected to provide further clarity on this topic in a ruling scheduled for November
2021, however the court’s session on this matter was postponed and the date of the next session has not
yet been announced. In October 2022, a hearing of the European Court of Justice (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 interests for the amount borrowed under such loan prior to cancellation.
On 16 February 2023, the Advocate General (AG) of the CJEU provided his opinion on the matter. The AG
opined that 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 instalments previously paid to the bank. The AG’s opinion is not binding on
the CJEU. His role is to propose to the CJEU a legal solution to this case. Should the CJEU follow the opinion
of the AG, this will have negative effect for banks in Poland. The CJEU’s ruling is expected within a few
months.
Certain Consumer Credit Products: In October 2021, ING announced that it would offer compensation to
certain of 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 a number of rulings by the Dutch Institute for Financial Disputes (Kifid) regarding similar
products at other banks. ING currently expects that any such compensation will be paid before the end of
2022. 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 has reached an agreement with the Dutch
Consumers’ Association (Consumentenbond) on the compensation methodology for revolving credits. Based
on a recent Kifid ruling regarding similar products, ING will amend 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 or a revolving credit
card with a variable interest rate. ING will compensate such customers according to Kifid jurisprudence
about revolving credits including ‘interest-on-interest’-effect. Compensation will start in the first half of
2023.

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ING Bank Annual Report 2022 227
43 Consolidated companies and businesses acquired and divested
Acquisitions
There were no significant acquisitions in 2022, 2021 or 2020.
Divestments 2022
ING announced at 13 December 2022 that it has sold their interest (80%) in Intersoftware Holding BV to the
Sky Group/ DIAS and realised a transaction result of EUR 11.0 million which consists of a profit of EUR 7.0 on
sale of InterSoftware Holding BV and the release of the redemption liability of EUR 3.0 million.
Divestments 2021
On 18 February 2021 ING announced the intention to withdraw from the retail banking market in the Czech
Republic. The decision to discontinue Czech Retail Banking entails the closure of retail customer accounts /
mutual funds and the sale of assets comprising the related government bond portfolio. ING’s retail
customers in the Czech Republic have received a welcome offer from Raiffeisenbank Czech Republic. ING’s
departure from the Czech Retail banking market resulted in EUR 2.5 billion saving accounts being transferred
to Raiffeisenbank and the government bond portfolio with a carrying amount of EUR 0.5 billion being sold in
the second quarter of 2021.
At 12 July 2021, ING announced that it has reached an agreement to transfer ING’s Retail Banking
operations in Austria to Bank99. Under the terms of the agreement, approximately EUR 1.7 billion of savings
deposits and approximately EUR 1.0 billion of mortgages, approximately EUR 0.4 billion other personal
lending and approximately EUR 0.4 billion loans to banks of ING Austria have been transferred to Bank99. In
December 2021 the transaction was completed and a loss on disposal of EUR 26 million was realised. In
2022 some final closing activities resulted in an additional loss of EUR 1 million. ING Austria was included in
the segment Retail Challengers & Growth Markets.
In 2021, ING and the board of Makelaarsland agreed to continue Makelaarsland independently. The new
board will take over all clients and employees, and services to clients will continue unchanged. The negative
result on disposal of group companies from this management buyout amounted to approximately EUR 3
million.
On 28 October 2021 ING announced that its subsidiary Payvision will start phasing out its services as a
payment service provider and acquirer. In 2021, Payvision recognised an impairment loss of intangible
assets of EUR 44 million, mainly with respect to Brand, IT and Customer relationships and an impairment
loss of the deferred tax asset of EUR 14 million.
ING has been active in the French retail banking market since 2000 as an online bank. In December 2021 ING
announced that it will leave the retail banking market in France in order to sharpen the focus of its business
portfolio. ING and Boursorama (a subsidiary of Société Générale) have signed an agreement to offer the
attractive services to retail customers of ING in France.
The contract allows ING customers to join Boursorama and benefit from a simplified account opening
process and exclusive offers. The agreement also includes the transfer to Boursorama of
‘assurance'vie’ (investment products) contracts, for which ING acts as a broker with Generali Vie. Home loans
and consumer loans are not included in the agreement and the portfolio will continue to be managed by
ING.
The agreement follows ING’s announcement in December 2021 to exit the French retail banking market. The
exit is finalised end of 2022. ING’s departure from the France retail banking market is proceeding well with
EUR 9.7 billion saving accounts already transferred to Boursorama. ING will continue its Wholesale Banking
activities in France, with a focus on strengthening its position and the ambition to be the go-to bank for
sustainable finance.

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> 42 Legal proceedings
ING Bank Annual Report 2022 228

Most significant companies disposed in 2021
in EUR million | Makelaarsland BV & Above BV | ING Austria Retail Banking | Total divested
Sales Proceeds |  |  |
Sales proceeds |  | 29 | 29
Non-cash proceeds |  |  |
Cash proceeds |  | 29 | 29
Cash outflow / inflow on disposal |  | 29 | 29
Assets |  |  |
Cash assets | 3 |  | 3
Loans and advances to customers |  | 1,404 | 1,404
Amounts due from banks |  | 378 | 378
Miscalleneous other assets |  | 8 | 8
Liabilities |  |  |
Customer deposits and other funds on deposit |  | 1,725 | 1,725
Miscallaneous other liabilities | 1 | 8 | 9
Net assets | 3 | 56 | 58
% disposed | 100% | 100% |
Net assets disposed | 3 | 56 | 58
Result on disposal | -3 | -26 | -29

In 2020 there were no significant divestments.
44 Principal subsidiaries, investments in associates and joint ventures
For the majority of ING’s principal subsidiaries, ING Bank N.V. has control because it either directly or
indirectly owns more than half of the voting power. For subsidiaries in which the interest held is below 50%,
control exists based on the combination of ING’s financial interest and its rights from other contractual
arrangements which result in control over the operating and financial policies of the entity.
For each of the subsidiaries listed, the voting rights held equal the proportion of ownership interest and
consolidation by ING is based on the majority of ownership.
For the principal investments in associates and joint ventures ING Bank has significant influence but not
control. Significant influence generally results from a shareholding of between 20% and 50% of the voting
rights, but also the ability to participate in the financial and operating policies through situations including,
but not limited to one or more of the following:
•Representation on the board of directors;
•Participation in the policymaking process; and
•Interchange of managerial personnel.
The principal subsidiaries, investments in associates and joint ventures of ING Bank N.V. and their statutory
place of incorporation or primary place of business are as follows:

Principal subsidiaries, investments in associates and joint ventures
|  |  | Proportion of ownership and interest held
by the group
|  |  | 2022 | 2021
Subsidiary | Statutory place of Incorporation | Country of operation |  |
Bank Mendes Gans 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 | Turkey | 100% | 100%
ING Bank (Australia) Ltd | Sydney | Australia | 100% | 100%
ING Commercial Finance B.V. | Amsterdam | the Netherlands | 100% | 100%
ING Groenbank N.V. | Amsterdam | the Netherlands | 100% | 100%
Investments in associates and joint ventures |  |  |  |
TMBThanachart Bank Public Company Ltd 2 | Bangkok | Thailand | 23% | 23%

1 The shares of the non-controlling interest stake of 25% are listed on the Warsaw Stock Exchange, for summarised financial
information we refer to ‘Note 33 ‘Information on geographical areas.
2 Reference is made to Note 8 Investments in Associates and Joint Ventures.

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ING Bank Annual Report 2022 229
45 Structured entities
ING Bank’s activities involve transactions with various structured entities (SE) in the normal course of its
business. A structured entity is an entity that has been designed so that voting or similar rights are not the
dominant factor in deciding who controls the entity, such as when any voting rights relate to administrative
tasks only and the relevant activities are directed by means of contractual arrangements. ING Bank’s
involvement in these entities varies and includes both debt financing and equity financing of these entities
as well as other relationships. Based on its accounting policies, as disclosed in the section Principles of
valuation and determination of results of these financial statements, ING establishes whether these
involvements result in no significant influence, significant influence, joint control or control over the
structured entity.
The structured entities over which ING can exercise control are consolidated. ING may provide support to
these consolidated structured entities as and when appropriate. However, this is fully reflected in the
consolidated financial statements of ING Bank as all assets and liabilities of these entities are included and
off-balance sheet commitments are disclosed.
ING’s activities involving structured entities are explained below in the following categories:
1.Consolidated ING originated securitisation programmes;
2.Consolidated ING originated Covered bond programme (CBC);
3.Consolidated ING sponsored Securitisation programme (Mont Blanc);
4.Unconsolidated Securitisation programme; and
5.Other structured entities.
1. Consolidated ING originated securitisation programmes
ING Bank enters into liquidity management securitisation programmes in order to obtain funding and
improve liquidity. Within the programme ING Bank sells ING originated assets to a structured entity. The
underlying exposures include residential mortgages and SME loans in the Netherlands, Belgium, Spain, Italy,
Australia and Germany.
The structured entity issues securitised notes (traditional securitisations) which are eligible collateral for
central bank liquidity purposes. In most programmes ING Bank acts as investor of the securitised notes. ING
Bank continues to consolidate these structured entities if it is deemed to control the entities.
The structured entity issues securitisation notes in two or more tranches, of which the senior tranche
obtains a high rating (AAA or AA) by a rating agency. The tranche can subsequently be used by ING Bank as
collateral in the money market for secured borrowings.
ING Bank originated various securitisations, as at 31 December 2022, these consisted of approximately EUR
65 billion (2021: EUR 74 billion) of senior and subordinated notes, of which approximately EUR 1 billion
(2021: EUR 1 billion) were issued externally. The underlying exposures are residential mortgages and SME
loans. Apart from the third party funding, these securitisations did not impact ING Bank’s Consolidated
statement of financial position and profit or loss.
In 2022, there are no non-controlling interests as part of the securitisation structured entities that are
significant to ING Bank. ING Bank for the majority of the securitisation vehicles provides the funding for the
entity except for EUR 1 billion (2021: EUR 1 billion).
In addition ING Bank originated various securitisations for liquidity management optimisation purposes. As
at 31 December 2022, these consisted of EUR 444 million (2021: EUR 662 million) of senior secured portfolio
loans, which have been issued to ING subsidiaries in Germany. The underlying exposures are senior loans to
large corporations and financial institutions, and real estate finance loans, mainly in the Netherlands. These
securitisations did not impact ING Bank’s consolidated statement of financial position and profit or loss.
2. Consolidated ING originated Covered bond programme (CBC)
ING Bank has entered into a covered bond programme. Under the covered bond programme ING issues
bonds. The payment of interest and principal is guaranteed by the ING administered structured entities, ING
Covered Bond Company B.V., and ING SB Covered Bond Company B.V. In order for these entities to fulfil their
guarantee, ING legally transfers mainly Dutch mortgage loans originated by ING. Furthermore ING offers
protection against deterioration of the mortgage loans. The entities are consolidated by ING Bank.

Covered bond programme
| Fair value pledged mortgage loans
in EUR million | 2022 | 2021
Dutch Covered Bond Companies | 21,379 | 16,586
| 21,379 | 16,586

In addition, subsidiaries of ING in Germany, Belgium and Australia also issued covered bonds with pledged
mortgages loans of approximately EUR 24,880 million (2021: EUR 22,597 million) in total.
For the covered bond programme, third-party investors in securities issued by the structured entity have
recourse to the assets of the entity and to the assets of ING Bank.
3. Consolidated ING sponsored Securitisation programme (Mont Blanc)
In the normal course of business, ING Bank structures financing transactions for its clients by assisting them

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> 45 Structured entities
ING Bank Annual Report 2022 230
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.
In its role as administrative agent, ING Bank facilitates these transactions by acting as administrative agent,
swap counterparty and liquidity provider to Mont Blanc Capital Corp. ING Bank also provides support facilities
(i.e. liquidity) backing the transactions funded by the conduit. The types of asset currently in the Mont Blanc
conduit include trade receivables, consumer finance receivables, car leases and residential mortgages.
ING Bank supports the commercial paper 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 2,446 million (2021: EUR 2,581 million). The drawn
liquidity amount is nil as at 31 December 2022 (2021: nil).
The standby liquidity facilities are reported under irrevocable facilities. All facilities, which vary in risk profile,
are granted to the Mont Blanc Capital Corp. subject to normal ING Bank credit and liquidity risk analysis
procedures. The fees received for services provided and for facilities are charged subject to market
conditions.
4. Unconsolidated Securitisation programme
In 2013 ING transferred financial assets (mortgage loans) for an amount of approximately 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 on-going
involvement in the transferred assets: as counterparty to the SPE of a non-standard interest rate swap and
as servicer of the transferred assets. ING has an option to unwind the transaction by redeeming all notes at
their principal outstanding amount, in the unlikely event of changes in accounting and/or regulatory
requirements that significantly impact the transaction. The fair value of the swap held by ING at
31 December 2022 amounted to EUR -40 million (2021: EUR -34 million); fair value changes on this swap
recognised in the statement of profit or loss in 2022 were EUR -6 million (2021: EUR 0 million). Service fee
income recognised, for the role as administrative agent, in the statement of profit or loss in 2022 amounted
to EUR 1 million (2021: EUR 1 million). The cumulative income recognised in profit or loss since derecognition
amounts to EUR 18 million (2021: EUR 17 million).
5. Other structured entities
In the normal course of business, ING Bank enters into transactions with structured entities as counterparty.
Predominantly in its structured finance operations, ING can be instrumental in facilitating the creation of
these structured entity counterparties. These entities are generally not included in the consolidated
financial statements of ING Bank, as ING facilitates these transactions as administrative agent by providing
structuring, accounting, funding, lending, and operation services.
ING Bank offers various investment fund products to its clients. ING Bank does not invest in these investment
funds for its own account nor acts as the fund manager.
46 Related parties
In the normal course of business, ING Bank enters into various transactions with related parties. Parties are
considered to be related if one party has the ability to control or exercise significant influence over the other
party in making financial or operating decisions. Related parties of ING Bank include, among others, its
subsidiaries, associates, joint ventures, key management personnel, and various defined benefit and
contribution plans. For post-employment benefit plans, reference is made to Note 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.
ING Bank forms part of ING Group and also enters into transactions with ING Group. These transactions vary
from financing activities to regular purchase and sales transactions. Disclosed in the table below, are the
transactions with ING Groep N.V.
Parent Company

Transactions with ING Groep N.V. |  |
in EUR million | 2022 | 2021
Assets | 56 | 55
Liabilities | 65,704 | 56,349
Income received | 4 | 15
Expenses paid | 1,426 | 1,158

Liabilities to ING Groep N.V. mainly comprise long-term funding.

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> 45 Structured entities
ING Bank Annual Report 2022 231
Associates and joint ventures

Transactions with ING Bank’s main associates and joint ventures
| Associates | Joint ventures
in EUR million | 2022 | 2021 | 2022 | 2021
Assets | 121 | 115 |  |
Liabilities | 309 | 417 | 1 | 3
Off-balance sheet commitments | 28 | 24 |  |
Income received | 12 | 42 |  |
Expenses paid |  |  |  |

Assets, liabilities, commitments, and income related to Associates and joint ventures result from
transactions which are executed as part of the normal Banking business.
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 Group. In 2022 and 2021, 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)
2022 in EUR thousands | Executive Board of ING Groep N.V. | Management Board Banking 1 | Total
Fixed Compensation |  |  |
– Base salary | 4,220 | 4,969 | 9,189
– Collective fixed allowances 2 | 1,011 | 1,073 | 2,084
– Pension costs | 70 | 116 | 186
– Severance benefits |  | 932 | 932
Variable compensation |  |  |
– Upfront cash |  | 803 | 803
– Upfront shares | 268 | 803 | 1,071
– Deferred cash |  | 1,204 | 1,204
– Deferred shares | 401 | 1,204 | 1,605
– Other emoluments 3 | 296 | 638 | 934
Total compensation | 6,266 | 11,742 | 18,008

1 Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2 The 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 114,866.
3 This includes amongst others: housing, school/tuition fees, international health insurance, relocation costs and tax and financial
planning.

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> 46 Related parties
ING Bank Annual Report 2022 232

Key management personnel compensation (Executive Board and Management Board Banking)
| Executive Board of ING Groep N.V. 3 | Managemen t Board Banking 1,4 | Total
2021 in EUR thousands
Fixed Compensation |  |  |
– Base salary | 3,836 | 5,024 | 8,860
– Collective fixed allowances 2 | 954 | 1,214 | 2,168
– Pension costs | 64 | 116 | 180
– Severance benefits |  | 1,075 | 1,075
Variable compensation |  |  |
– Upfront cash |  | 664 | 664
– Upfront shares | 265 | 691 | 956
– Deferred cash |  | 997 | 997
– Deferred shares | 398 | 1,036 | 1,434
– Other emoluments 5 | 274 | 959 | 1,233
Total compensation | 5,791 | 11,776 | 17,567

1 Excluding members of the Management Board Banking that are also members of the Executive Board of ING Groep N.V.
2 The 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 112,189.
3 In 2021 one member of the Executive Board joined ING during the year. The table includes compensation earned in the capacity as
Executive Board member as of the appointment at the AGM on 26 April 2021.
4 One member of the Management Board Banking left ING during the reporting year 2021. In line with applicable regulation a
severance payment was granted.
5 This includes amongst others: housing, school/tuition fees, international health insurance, relocation costs and tax and financial
planning.
ING indemnifies the members of the EB against direct financial losses in connection with claims from third
parties filed, or threatened to be filed, against them by virtue of their service as a member of the EB, as far
as permitted by law, on the conditions laid down in the Articles of Association and their commission
contract. ING has taken out liability insurance for the members of the EB.
In accordance with the Articles of Association ING indemnifies the members of the Supervisory Board as far
as legally permitted against direct financial losses in connection with claims from third parties filed or
threatened to be filed against them by virtue of their service as a member of the Supervisory Board.
Key management personnel compensation is generally included in Staff expenses in the statement of profit
or loss. The total remuneration of the Executive Board and Management Board Banking is disclosed in the
table above. Under IFRS, certain components of variable remuneration are not recognised in the statement
of profit or loss directly, but are allocated over the vesting period of the award. The comparable amount
recognised in Staff expenses in 2022 relating to the fixed expenses of 2022 and the vesting of variable
remuneration of earlier performance years, i s EUR 14 million in 20 22 (2021: EUR 13 million).
The table below shows the total of fixed remuneration, expense allowances and attendance fees for the
Supervisory Board in 2022 and 2021

Key management personnel compensation (Supervisory Board)
in EUR thousands | 2022 | 2021
Total compensation | 1,048 | 994

Loans and advance to key management personnel
As at 31 December 2022 Loans and advances outstanding to key management personnel amounted to EUR
2.7 million (2021: EUR 2.4 million) and loan commitments to key management personnel amounted to EUR
203 thousand (2021: EUR 197 thousand). Total interest received in 2022 on these loans and advances
amounted to EUR 62 thousand (EUR 37 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.
Loans and advances to members of the Executive Board and Management Board Banking are compliant
with the standards set out in the DNB guidelines for loans to officers and directors of a regulated entity,
such as ING.
Deposits outstanding to key management personnel
As at 31 December 2022 Deposits outstanding from key management personnel amounted to EUR 11.5
million (2021: EUR 6.1 million). Total interest paid in 2022 on these deposits amounted to EUR 36 thousand
(2021: EUR 14 thousand).

Number of ING Groep N.V. shares and stock options to key management personnel
| ING Groep N.V. shares
in numbers | 2022 | 2021
Executive Board members | 108,217 | 91,853
Management Board Banking | 294,574 | 237,525
Supervisory Board members | 5,295 | 5,295
Total number of shares and stock options | 408,086 | 334,673

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> 46 Related parties
ING Bank Annual Report 2022 233
47 Capital management
Objectives
Group Treasury (“GT”) Balance Sheet & Capital Management, is responsible for maintaining the adequate
capitalisation of ING Group and ING Bank entities, to manage the risk associated with ING’s business
activities. This involves not only managing, planning and allocating capital within ING Group, ING Bank and
its various entities, but also helping to execute necessary capital market transactions, term (capital) funding
and risk management transactions. ING takes an integrated approach to assess the adequacy of its capital
position in relation to its risk profile and operating environment. This means GT Balance Sheet & Capital
Management takes into account both regulatory and internal, economic based metrics and requirements as
well as the interests of key stakeholders such as shareholders and rating agencies.
ING Bank applies the following main capital definitions:
•Common Equity Tier 1 capital (CET1) - is defined as shareholders’ equity less regulatory adjustments.
CET1 capital divided by risk-weighted assets equals the CET1 ratio.
•Tier 1 capital – is defined as CET1 capital plus Additional Tier 1 (hybrid) securities and other regulatory
adjustments. Tier 1 capital divided by risk-weighted assets equals the Tier 1 capital ratio.
•Total capital – is Tier 1 capital plus subordinated Tier 2 liabilities and regulatory adjustments. Total capital
divided by risk-weighted assets equals the Total capital ratio.
•Leverage ratio – is defined as Tier 1 capital divided by the leverage exposure.
Capital developments
ING Bank’s capital ratios at the end of the year decreased compared to 2021 primarily due to higher risk-
weighted assets and as most of the net profit of the year with EUR 2.75 billion additional distributions were
up streamed to ING Group. Risk-weighted assets were mainly impacted by rating downgrades on Russia-
related exposure, currency movements, the implementation of EBA guidelines on the treatment of
structural FX positions, and model impacts. Model impacts reflect the introduction of a risk-weight floor on
Dutch residential mortgages by the Dutch Central Bank as well as ongoing redevelopment of internal
models and EBA guidelines.
ING Bank paid EUR 3.5 billion of dividend to ING Group in relation to the 2022 profit and an additional EUR
2.75 billion for distribution to shareholders by the Group.
ING Bank N.V. has a CET1 ratio of 12.6% versus an overall CET1 requirement (including buffer requirements)
of 7.10%. The Bank’s Tier 1 ratio decreased from 16.5% to 14.5% compared to last year. The Banks’s Total
capital ratio decreased to 17.5%.

ING Bank capital position according to CRR II / CRD V
in EUR million | 2022 | 2021
Shareholders’ equity 1 | 42,546 | 47,914
-Interim profits not included in CET 1 capital | -913 | -934
- Other adjustments | 332 | -2,130
Regulatory adjustments | -580 | -3,064
Available common equity Tier 1 capital | 41,966 | 44,850
Additional Tier 1 securities | 6,280 | 6,792
Regulatory adjustments additional Tier 1 | 78 | 78
Available Tier 1 capital | 48,324 | 51,720
Supplementary capital Tier 2 bonds 2 | 10,046 | 9,341
Regulatory adjustments Tier 2 | 41 | 21
Available Total capital | 58,411 | 61,081
Risk weighted assets | 332,853 | 312,616
Common equity Tier 1 ratio | 12.61% | 14.35%
Tier 1 ratio | 14.52% | 16.54%
Total capital ratio | 17.55% | 19.54%

1 Shareholders' equity is determined in accordance with IFRS-EU.
2 All T2 securities are CRR/CRD V-compliant for 2022 (2021: EUR 153 million was subject to CRR/CRD IV grandfathering rules).
In accordance with the applicable regulation, credit and operational risk models used in the capital ratios
calculations are not audited.
Processes for managing capital
GT Balance Sheet & Capital Management ensures adherence to ING’s solvency risk appetite statements by
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 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 assesses continuously 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

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> 47 Capital management
ING Bank Annual Report 2022 234
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 to (i) identify and assess potential
vulnerabilities in ING’s businesses, business model, 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.
Regulatory requirements
Capital adequacy and the use of required regulatory capital are based on the guidelines developed by the
Basel Committee on Banking Supervision (The Basel Committee) and the European Union Directives, as
implemented by the Dutch Central Bank and the ECB for supervisory purposes. In 2010, the Basel Committee
issued new solvency and liquidity requirements that superseded Basel II, implemented in the EU via CRR /
CRD. In accordance with the CRR the minimum Pillar 1 capital requirements applicable to ING Bank are: a
CET1 ratio of 4.5%, a Tier 1 ratio of 6.0% and a Total capital ratio of 8.0% of risk-weighted assets.
The overall CET1 requirement (including buffer requirements) for ING Bank N.V. at a consolidated level was
7.10% in 2022. This requirement is the sum of a 4.5% Pillar I requirement, a 2.5% Capital Conservation Buffer
(CCB) and a 0.10% Countercyclical Buffer (CCyB) (based on December 2022 positions).
Ratings
ING’s credit ratings and outlook are shown in the table below. Each of these ratings reflects only the view of
the applicable rating agency at the time the rating was issued, and any explanation of the significance of a
rating may be obtained only from the rating agency.

Main credit ratings of ING Bank N.V. at 31 December 2022
| S&P | Moody’s | Fitch | GBB-Rating
ING Bank N.V. |  |  |  |
Issuer rating |  |  |  |
Long-term | A+ | A1 | AA- | A+
Short-term | A-1 | P-1 | F1+ | n/a
Outlook | Stable | Stable | Stable | Indeterminate
Senior unsecured rating | A+ | A1 | AA- |

A security rating is not a recommendation to buy, sell or hold securities and 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 a rating will not be lowered, suspended or withdrawn entirely by the
rating agency if, in the rating agency’s judgment, circumstances so warrant. ING accepts no responsibility
for the accuracy or reliability of the ratings.
48 Subsequent events
On 6 February 2023, a devastating earthquake with multiple aftershocks struck southern and central Turkey
and northern and western Syria causing a significant tragedy for the people and is causing disruption to
business and economic activity in the region. This qualifies as a non-adjusting subsequent event.

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> 47 Capital management
ING Bank Annual Report 2022 235
Authorisation of Consolidated Financial Statements
Amsterdam, 6 March 2023
The Supervisory Board
G.J. (Hans) Wijers, chairman
A.M.G. (Mike) Rees, vice-chairman
J. (Juan) Colombás
M. (Mariana) Gheorghe
M. (Margarete) Haase
L.J. (Lodewijk) Hijmans van den Bergh
H.A.H. (Herman) Hulst
H.H.J.G. (Harold) Naus
H.W.P.M.A. (Herna) Verhagen
The Management Board Banking
S.J.A. (Steven) van Rijswijk, CEO and chairman
T. (Tanate) Phutrakul, CFO
L. (Ljiljana) Čortan, CRO
P. (Pinar) Abay, head of Market Leaders
A.J.M. (Andrew) Bester, head of Wholesale Banking
A. (Aris) Bogdaneris, head of Challengers & Growth Markets and head of Retail Banking
R.H.E. (Ron) van Kemenade, chief technology officer
M.A. (Marnix) van Stiphout, chief operations officer and chief transformation officer

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> Authorisation of Consolidated Financial Statements
ING Bank Annual Report 2022 236
Parent company statement of financial position
as at 31 December before appropriation of result

in EUR million | 2022 | 2021 |  | in EUR million | 2022 | 2021
Assets |  |  |  | Liabilities |  |
Cash and balances with central banks 2 | 42,013 | 57,958 |  | Deposits from banks 13 | 70,515 | 91,247
Short-dated government paper 3 | 49 | 205 |  | Customer deposits 14 | 375,858 | 363,162
Loans and advances to banks 4 | 83,985 | 74,040 |  | Debt securities in issue | 39,526 | 49,117
Loans and advances to customers 5 | 346,012 | 350,202 |  | Other liabilities 15 | 88,197 | 39,161
Debt securities 6 | 43,784 | 43,315 |  | General provisions 16 | 883 | 1,246
Equity securities 7 | 4,263 | 10,079 |  | Subordinated loans 17 | 15,871 | 16,949
Investments in group companies 8 | 30,257 | 31,342 |  | Total liabilities | 590,851 | 560,882
Investments in associates and joint ventures 9 | 1,240 | 1,354 |  |  |  |
Intangible assets 10 | 565 | 632 |  | Equity 18 |  |
Equipment 11 | 828 | 901 |  | Share capital | 525 | 525
Other assets 12 | 80,400 | 38,769 |  | Share premium | 16,542 | 16,542
|  |  |  | Revaluation reserves | -862 | 1,617
|  |  |  | Legal and statutory reserves | 361 | -548
|  |  |  | Other reserves | 25,067 | 27,117
|  |  |  | Unappropriated result | 913 | 2,661
|  |  |  | Total equity | 42,546 | 47,914
Total assets | 633,396 | 608,796 |  | Total liabilities and equity | 633,396 | 608,796

References relate to the accompanying notes. These form an integral part of the Parent company financial statements.

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

ING Bank Annual Report 2022 237
Parent company statement of profit or loss
for the years ended 31 December

in EUR million | 2022 | 2021
Interest income | 14,182 | 11,930
Interest expense | -8,260 | -5,585
Net interest income 19 | 5,922 | 6,345
Investment income and results from participating interests 20 | 2,215 | 3,239
Fee and commission income | 2,402 | 2,248
Fee and commission expense | -584 | -502
Net fee and commission income 21 | 1,818 | 1,746
Results from financial transactions 22 | 721 | 472
Other income | 153 | 85
Total income | 10,829 | 11,887
Staff expenses 23 | 3,249 | 3,224
Depreciation, amortisation and impairments 24 | 405 | 408
Other expenses 25 | 2,150 | 2,523
Addition to loan loss provisions | 705 | 261
Total expenses | 6,510 | 6,416
Result before tax | 4,319 | 5,471
Taxation 26 | 652 | 701
Result after tax | 3,667 | 4,770

References relate to the accompanying notes. These form an integral part of the Parent company
financial statements.

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

ING Bank Annual Report 2022 238
Parent company statement of changes in equity

in EUR million | Share capital | Share premium | Revaluation reserves | Legal and statutory reserves | Other reserves | Unappropriated results | Total
Balance as at 31 December 2021 | 525 | 16,542 | 1,617 | -548 | 27,117 | 2,661 | 47,914
Realised and unrealised revaluations equity and debt instruments and other revaluations |  |  | -290 | -212 | -23 |  | -525
Realised gains/losses transferred to the statement of profit or loss |  |  | -9 | -15 |  |  | -24
Changes in cash flow hedge reserve |  |  | -2,200 | -701 |  |  | -2,901
Unrealised revaluations property in own use |  |  | 1 | -33 | 26 |  | -5
Remeasurement of the net defined benefit asset/liability |  |  | -131 | 112 |  |  | -19
Exchange rate differences and other |  |  | 149 | 1,089 | 15 |  | 1,253
Total amount recognised directly in equity |  |  | -2,479 | 239 | 19 |  | -2,221
Net result |  |  |  | 161 |  | 3,506 | 3,667
|  |  | -2,479 | 400 | 19 | 3,506 | 1,446
Transfer from unappropriated results |  |  |  |  | 2,661 | -2,661 |
Dividends |  |  |  |  | -3,684 | -2,594 | -6,277
Employee stock options and share plans |  |  |  |  | 27 |  | 27
Changes in the composition of the group and other changes |  |  |  | 509 | -1,073 |  | -564
Balance as at 31 December 2022 | 525 | 16,542 | -862 | 361 | 25,067 | 913 | 42,546

Changes in individual components are presented in Note 18 ‘Equity’.

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

ING Bank Annual Report 2022 239

Parent company statement of changes in equity - continued

in EUR million | Share capital | Share premium | Revaluation reserves | Legal and statutory reserves | Other reserves | Unappropriated results | Total
Balance as at 31 December 2020 | 525 | 16,542 | 2,150 | 185 | 25,953 | 2,321 | 47,675
Realised and unrealised revaluations equity and debt instruments and other revaluations |  |  | -7 | -61 | -6 |  | -74
Realised gains/losses transferred to the statement of profit or loss |  |  | -22 | -14 |  |  | -36
Changes in cash flow hedge reserve |  |  | -538 | -1,065 |  |  | -1,603
Unrealised revaluations property in own use |  |  | 1 | -14 | 11 |  | -2
Remeasurement of the net defined benefit asset/liability |  |  | -4 | 99 |  |  | 95
Exchange rate differences and other |  |  | 37 | 153 |  |  | 190
Total amount recognised directly in equity |  |  | -532 | -903 | 5 |  | -1,430
Net result |  |  |  | 191 |  | 4,579 | 4,770
|  |  | -532 | -712 | 5 | 4,579 | 3,339
Transfer from unappropriated results |  |  |  |  | 2,321 | -2,321 | 0
Dividends |  |  |  |  | -1,207 | -1,918 | -3,125
Employee stock options and share plans |  |  |  |  | 28 |  | 28
Changes in the composition of the group and other changes |  |  |  | -21 | 18 |  | -3
Balance as at 31 December 2021 | 525 | 16,542 | 1,617 | -548 | 27,117 | 2,661 | 47,914

Changes in individual components are presented in Note 18 ‘Equity’.

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

ING Bank Annual Report 2022 240
Notes to the parent company financial statements
1 Basis of presentation
ING Bank N.V. is registered at Bijlmerdreef 106, 1102 CT Amsterdam, the Netherlands (Commercial
Register of Amsterdam under number 33031431).
The Parent company financial statements of ING Bank N.V. are prepared in accordance with the financial
reporting requirements included in Part 9 of Book 2, of the Dutch Civil Code. In accordance with subsection
8 of section 362, Book 2 of the Dutch Civil Code, the recognition and measurement principles applied in
these Parent company financial statements are the same as those applied in the ING Bank Consolidated
financial statements, reference is made to Note 1 ‘Accounting policies’ of the Consolidated financial
statements. Investments in group companies are accounted in the Parent company accounts according
to the equity method. In addition to the notes to these financial statements, further information is
included in the notes to the consolidated financial statements.
A list containing the information referred to in Section 379 (1), Book 2, of the Dutch Civil Code has been
filed with the office of the Commercial Register of Amsterdam, in accordance with Section 379 (5), Book 2
of the Dutch Civil Code.
The parent company financial statements are presented in euros, rounded to the nearest million, unless
stated otherwise. Amounts may not add up due to rounding.
Parent company equity and related reserves
The total amount of equity in the Parent company financial statements equals Shareholders’ equity
(parent) in the Consolidated financial statements. Certain components within equity are different, as a
result of the following presentation differences between the parent company accounts and consolidated
accounts:
•Unrealised revaluations including those related to cash flow hedges within consolidated group
companies, presented in Other reserves - Revaluation reserve in the consolidated accounts, are
presented in the Share of associates and joint ventures reserve in the parent company accounts;
•Foreign currency translation on consolidated group companies, presented in Other reserves - Currency
translation reserve in the consolidated accounts, is presented in the Share of associates and joint
ventures reserve in the parent company accounts;
•Revaluations on investment property and certain participations recognised in income and
consequently presented in Retained earnings in the consolidated accounts, is presented in the Share of
associates and joint ventures reserve in the parent company accounts.
A legal reserve is carried at an amount equal to the share in the results of associates and joint ventures
since their first inclusion at net asset value less the amount of profit distributions to which rights have
accrued in the interim. Profit distributions which can be repatriated to the Netherlands without restriction
are likewise deducted from the Share of associates and joint ventures reserve.
Presentation parent company assets and liabilities
The presentation of assets and liabilities in the parent company financial statements differs from the
presentation in the consolidated financial statements. In below tables a reconciliation is included between
the presentation in the parent company versus consolidated financial statements.

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> 1 Basis of presentation
ING Bank Annual Report 2022 241

Presentation Parent company financial statements versus Consolidated financial statements, Assets
in EUR million | Parent company financial statements
Assets as at 31 December 2022 | Cash and balances with central banks | Short-dated government paper | Loans and advances to banks | Loans and advances to customers | Debt securities | Equity securities | Investments in associates and joint ventures | Intangible assets | Equipment | Other assets | Total
Included in Consolidated statement of financial position: |  |  |  |  |  |  |  |  |  |  |
Cash and balances with central banks | 42,013 |  |  |  |  |  |  |  |  |  | 42,013
Loans and advances to banks |  |  | 67,769 |  |  |  |  |  |  |  | 67,769
Financial assets at fair value through profit or loss |  |  |  |  |  |  |  |  |  |  |
– Trading assets |  | 6 | 1,105 | 8,906 | 3,941 | 2,395 |  |  |  | 52,769 | 69,121
– Non-trading derivatives |  |  |  |  |  |  |  |  |  | 19,958 | 19,958
– Designated as at fair value through profit or loss |  |  | 425 | 249 | 3,096 |  |  |  |  |  | 3,770
– Mandatorily at fair value through profit or loss |  |  | 14,685 | 12,368 | 814 | 61 |  |  |  |  | 27,928
Financial assets at fair value through other comprehensive income |  |  |  |  | 13,217 | 1,808 |  |  |  |  | 15,025
Securities at amortised cost |  | 43 |  |  | 22,717 |  |  |  |  |  | 22,760
Loans and advances to customers |  |  |  | 324,489 |  |  |  |  |  |  | 324,489
Investments in associates and joint ventures |  |  |  |  |  |  | 1,240 |  |  |  | 1,240
Property and equipment |  |  |  |  |  |  |  |  | 817 |  | 817
Intangible assets |  |  |  |  |  |  |  | 565 |  |  | 565
Current tax assets |  |  |  |  |  |  |  |  |  | 203 | 203
Deferred tax assets |  |  |  |  |  |  |  |  |  | 993 | 993
Other assets |  |  |  |  |  |  |  |  | 11 | 6,477 | 6,489
Total assets | 42,013 | 49 | 83,985 | 346,012 | 43,784 | 4,263 | 1,240 | 565 | 828 | 80,400 | 603,139

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> 1 Basis of presentation
ING Bank Annual Report 2022 242

Presentation Parent company financial statements versus Consolidated financial statements, Liabilities
in EUR million | Parent company financial statements
Liabilities as at 31 December 2022 | Deposits from banks | Customer deposits | Debt securities in issue | Other liabilities | General provisions | Subordinated loans | Total
Included in Consolidated statement of financial position: |  |  |  |  |  |  |
Deposits from banks | 61,215 |  |  |  |  |  | 61,215
Customer deposits |  | 357,078 |  |  |  |  | 357,078
Financial liabilities at fair value through profit or loss |  |  |  |  |  |  |
– Trading liabilities | 1,724 | 4,238 |  | 56,389 |  |  | 62,350
– Non-trading derivatives |  |  |  | 24,606 |  |  | 24,606
– Designated as at fair value through profit or loss | 7,576 | 14,543 | 5,854 |  |  | 82 | 28,055
Current tax liabilities |  |  |  | 99 |  |  | 99
Deferred tax liabilities |  |  |  |  | 183 |  | 183
Provisions |  |  |  |  | 693 |  | 693
Other liabilities |  |  |  | 7,103 | 7 |  | 7,111
Debt securities in issue |  |  | 33,672 |  |  |  | 33,672
Subordinated loans |  |  |  |  |  | 15,789 | 15,789
Total liabilities | 70,515 | 375,858 | 39,526 | 88,197 | 883 | 15,871 | 590,851

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> 1 Basis of presentation
ING Bank Annual Report 2022 243
Notes to the Parent company statement of financial position
2 Cash and balances with central banks
Amounts held at central banks amount to EUR 41,206 million (2021: EUR 57,143 million). In 2022, the
movement in Cash and balances with central banks reflects ING’s active liquidity management.
3 Short-dated government paper
Short-dated government paper includes Dutch and international government paper amounting to EUR 49
million (2021: EUR 205 million) for the company.
4 Loans and advances to banks

in EUR million | 2022 | 2021
Non-subordinated receivables from: |  |
Group companies | 34,181 | 33,583
Third parties | 46,810 | 38,280
| 80,991 | 71,864
Subordinated receivables from: |  |
Group companies | 2,994 | 2,176
| 83,985 | 74,040

As at 31 December 2022, Loans and advances to banks includes receivables with regard to securities, which
have been acquired in reverse repurchase transactions amounting to EUR 39,304 million (2021: EUR 33,057
million).
5 Loans and advances to customers

Loans and advances to customers |  |
in EUR million | 2022 | 2021
Non-subordinated receivables from: |  |
ING Groep N.V. | 51 | 42
Group companies | 36,191 | 43,904
Third parties | 308,367 | 304,856
| 344,610 | 348,802
Subordinated receivables from: |  |
Group companies | 1,403 | 1,400
| 346,012 | 350,202

As at 31 December 2022, receivables included in Loans and advances to customers that are part of the
trading portfolio amount to EUR 8,906 million (2021: EUR 8,009 million).
Loans and advances to customers includes receivables with regard to securities which have been acquired
in reverse repurchase transactions amounting to EUR 20,638 million (2021: EUR 19,645 million) for the
company.
6 Debt securities

Debt securities by issuer |  |
in EUR million | 2022 | 2021
Public sector | 31,088 | 31,395
Other | 12,696 | 11,920
| 43,784 | 43,315

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> 2 Cash and balances with central banks
ING Bank Annual Report 2022 244

Debt securities analysed by listing |  |
in EUR million | 2022 | 2021
Listed | 32,555 | 30,593
Unlisted | 11,229 | 12,721
| 43,784 | 43,315

The above table includes the following non subordinated debt securities: |  |
in EUR million | 2022 | 2021
Non-subordinated debt securities issued by: |  |
Third parties | 42,949 | 42,594
| 42,949 | 42,594

Changes in debt securities 1 |  |
in EUR million | 2022 | 2021
Opening balance | 34,693 | 34,672
Additions | 19,105 | 14,907
Amortisation | -130 | -142
Changes in unrealised revaluations | -2,135 | -497
Disposals and redemptions | -16,118 | -15,046
Exchange rate differences | 490 | 781
Other changes | 29 | 18
Closing balance | 35,934 | 34,693

1 Excluding fair value through profit or loss portfolio.
7 Equity securities

Equity securities analysed by listing |  |
in EUR million | 2022 | 2021
Listed | 4,042 | 9,910
Unlisted | 221 | 169
| 4,263 | 10,079

Changes in equity securities at fair value through OCI. |  |
in EUR million | 2022 | 2021
Opening balance | 2,369 | 1,782
Additions | 12 | 513
Changes in unrealised revaluations | -55 | -98
Disposals | -491 | -12
Exchange rate differences | -38 | 192
Other changes | 10 | -8
Closing balance | 1,808 | 2,369

The cost or purchase price of the shares in the trading portfolio approximates their fair value. As at
31 December 2022 the cost or purchase price of shares e xcluding trading portfolio is EUR 1,171 million lower
(2021: EUR 1,260 million lower) than the carrying amount.

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> 6 Debt securities
ING Bank Annual Report 2022 245
8 Investments in group companies

Investments in group companies |  |  |  |
in EUR million |  | 2022 |  | 2021
| Interest held (%) | Statement of financial position value | Interest held (%) | Statement of financial position value
ING België N.V. | 100 | 9,566 | 100 | 10,001
ING Holding Deutschland GMBH | 100 | 9,174 | 100 | 9,274
ING Bank (Australia) Limited | 100 | 3,894 | 100 | 3,730
ING Financial Holdings Corporation | 100 | 2,804 | 100 | 2,634
ING Bank Slaski S.A. | 75 | 1,496 | 75 | 2,188
ING Bank A.S. | 100 | 758 | 100 | 726
Bank Mendes Gans N.V. | 100 | 789 | 100 | 737
ING Real Estate B.V. | 100 | 71 | 100 | 227
ING Australia Holdings Limited | 100 | 10 | 100 | 10
ING Corporate Investments B.V. | 100 | 157 | 100 | 252
Other (including financing companies) |  | 1,539 |  | 1,562
|  | 30,257 |  | 31,342

As at 31 December 2022, Investments in group companies includes credit institutions of EUR 17,016 million
(2021: EUR 17,829 million).
As at 31 December 2022 listed investments in group companies amount to EUR 1,496 million (2021: EUR
2,188 million).

Changes in investments in group companies |  |
in EUR million | 2022 | 2021
Opening balance | 31,342 | 32,056
Repayment of capital injection | -226 | -155
Revaluations | -788 | -1,038
Results from group companies | 2,193 | 3,029
Dividends received | -2,502 | -2,232
Capital contribution | 14 | -137
Mergers and liquidations | -14 | -7
Exchange rate differences | 237 | -191
Other changes |  | 15
Closing balance | 30,257 | 31,342

9 Investments in associates and joint ventures

Investments in associates and joint ventures |  |
in EUR million |  | 2022 |  | 2021
| Interest held (%) | Statement of financial position value | Interest held (%) | Statement of financial position value
TMBThanachart Bank Public Company | 23 | 1,109 | 23 | 1,208
Other |  | 131 |  | 147
|  | 1,240 |  | 1,354

Changes in investments in associates and joint ventures |  |
in EUR million | 2022 | 2021
Opening balance | 1,354 | 1,332
Additions | 24 | 30
Share of results | 66 | 70
Dividends received | -38 | -28
Disposals | 1 | -10
Impairments | -192 | -3
Revaluations | -7 | 1
Exchange rate differences | 27 | -31
Other changes | 5 | -7
Closing balance | 1,240 | 1,354

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> 8 Investments in group companies
ING Bank Annual Report 2022 246
10 Intangible assets

Changes in intangible assets
|  | Goodwill |  | Software |  | Other |  | Total
in EUR million | 2022 | 2021 | 2022 | 2021 | 2022 | 2021 | 2022 | 2021
Opening balance | 122 | 184 | 508 | 569 | 2 | 2 | 632 | 755
Additions |  |  | 115 | 122 |  |  | 115 | 122
Disposals |  |  | 1 |  |  |  | 1 |
Amortisation |  |  | -155 | -166 |  |  | -155 | -166
Impairments | -32 |  | -17 | -16 |  |  | -49 | -16
Exchange rate differences | -1 | -61 |  |  |  |  | -1 | -62
Other changes | 25 |  | -3 | -2 |  |  | 23 | -2
Closing balance | 114 | 122 | 449 | 508 | 2 | 2 | 565 | 632

Goodwill is tested for impairment annually.
11 Equipment

Changes in equipment |  |
in EUR million | 2022 | 2021
Opening balance | 901 | 1,062
Additions | 139 | 89
Depreciation | -183 | -213
Disposals | -15 | -4
Impairments | -19 | -15
Reversal of impairments | 1 | 2
Exchange rate differences | -2 | 9
Other changes | 7 | -28
Closing balance | 828 | 901
Gross carrying amount as at 31 December | 2,240 | 2,220
Accumulated depreciation as at 31 December | -1,412 | -1,319
Net carrying value | 828 | 901

12 Other assets

Other assets |  |
in EUR million | 2022 | 2021
Derivatives | 72,726 | 34,038
Deferred tax assets | 993 | 364
Income tax receivables | 203 | 234
Accrued interests and rents | 47 | 41
Other accrued assets | 484 | 420
Pension asset | 515 | 717
Other receivables | 5,431 | 2,957
| 80,400 | 38,769

Derivatives includes transactions with group companies of EUR 44,988 million (2021: EUR 16,954 million).
Other receivables includes EUR 3,784 million (2021: EUR 1,479 million) related to transactions still to be
settled at balance sheet date. As at 31 December 2022, an amount of EUR 655 million (2021: EUR 844
million) is expected to be settled after more than one year from the balance sheet date.
13 Deposits from banks

Deposits from banks |  |
in EUR million | 2022 | 2021
Group companies | 24,369 | 26,227
Third parties | 46,147 | 65,021
| 70,515 | 91,247

14 Customer deposits

Customer deposits by group companies and third parties |  |
in EUR million | 2022 | 2021
ING Groep N.V. | 49,338 | 40,467
Group companies | 12,526 | 18,666
Third parties | 313,994 | 304,029
| 375,858 | 363,162

Customer deposits from ING Groep N.V. includes EUR 37,806 million (2021: EUR 34,303 million) Senior non-
preferred deb t.

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> 10 Intangible assets
ING Bank Annual Report 2022 247

Customer deposits by type |  |
in EUR million | 2022 | 2021
Savings accounts | 126,597 | 124,901
Credit balances on customer accounts | 149,042 | 144,018
Corporate deposits | 47,576 | 45,379
Other | 52,642 | 48,864
| 375,858 | 363,162

15 Other liabilities

Other liabilities |  |
in EUR million | 2022 | 2021
Derivatives | 79,360 | 31,948
Trading liabilities | 1,634 | 845
Accrued interest | 18 | 7
Costs payable | 984 | 1,274
Income tax payable | 99 | 112
Other taxation and social security contribution | 81 | 64
Other amounts payable | 6,021 | 4,910
| 88,197 | 39,161

Derivatives includes transactions with group companies of EUR 51,849 million (2021: EUR 14,499 million).
Other amounts payable includes EUR 4,001 million (2021: EUR 2,940 million) related to transactions still to
be settled at balance sheet date. As at 31 December 2022, an amount of EUR 249 million (2021: EUR 530
million) is expected to be settled after more than one year from the balance sheet date.
16 General provisions

General provisions |  |
in EUR million | 2022 | 2021
Deferred tax liabilities | 183 | 553
Pension liabilities and other staff-related liabilities | 7 | 8
Reorganisations and relocations | 237 | 308
Other | 456 | 377
| 883 | 1,246

As at 31 December 2022, an amount of EUR 232 million (2021: EUR 616 million) is expected to be settled
after more than one year from the balance sheet date.
17 Subordinated loans

Subordinated loans by group companies and third parties |  |
in EUR million | 2022 | 2021
Group companies | 16,441 | 15,955
Third parties | (570) | 993
| 15,871 | 16,949

Subordinated loans by type |  |
in EUR million | 2022 | 2021
Capital debentures | 1,761 | 1,935
Private loans | 14,111 | 15,014
| 15,871 | 16,949

The subordinated loans rank subordinated to the other liabilities in a winding-up of ING Bank.
18 Equity

Equity |  |
in EUR million | 2022 | 2021
Share capital | 525 | 525
Share premium | 16,542 | 16,542
Revaluation reserves | -862 | 1,617
Legal and statutory reserves | 361 | -548
Other reserves | 25,067 | 27,117
Unappropriated result | 913 | 2,661
Total equity | 42,546 | 47,914

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> 14 Customer deposits
ING Bank Annual Report 2022 248

Share capital |  |  |  |
| Ordinary shares (par value EUR 1.13)
| Number x 1,000 | Amount in EUR million
| 2022 | 2021 | 2022 | 2021
Authorised share capital | 1,600,000 | 1,600,000 | 1,808 | 1,808
Unissued share capital | 1,134,965 | 1,134,965 | 1,283 | 1,283
Issued share capital | 465,035 | 465,035 | 525 | 525

No changes occurred in the issued share capital and share premium in 2022 and 2021.

Changes in revaluation reserves |  |  |  |  |  |  |  |
in EUR million |  |  |  |  |  |  |  |
2022 |  | Property in own use reserve | Equity securities at fair value through other comprehensive income | Debt instruments at fair value through other comprehensive income | Cash flow hedge reserve | Net defined benefit assets/- liability remeasurement reserve | Credit liability | Total
Opening balance |  | 22 | 1,260 | -63 | 292 | 186 | -80 | 1,617
Unrealised revaluations |  | 1 | -112 | -201 |  |  | 165 | -147
Realised gains/losses transferred to the statement of profit or loss |  |  |  | -9 |  |  |  | -9
Realised revaluations reclassified to retained earnings |  |  | 23 |  |  |  | -15 | 8
Changes in cash flow hedge reserve |  |  |  |  | -2,200 |  |  | -2,200
Change in net defined benefit assets/liability |  |  |  |  |  | -131 |  | -131
Closing balance |  | 24 | 1,171 | -272 | -1,908 | 55 | 70 | -862
2021 |  |  |  |  |  |  |  |
Opening balance |  | 21 | 1,168 | 58 | 830 | 189 | -117 | 2,150
Unrealised revaluations |  | 1 | 95 | -99 |  |  | 37 | 34
Realised gains/losses transferred to the statement of profit or loss |  |  |  | -23 |  |  |  | -23
Realised revaluations reclassified to retained earnings |  |  | -3 |  |  |  |  | -3
Changes in cash flow hedge reserve |  |  |  |  | -538 |  |  | -538
Change in net defined benefit assets/liability |  |  |  |  |  | -4 |  | -4
Closing balance |  | 22 | 1,260 | -63 | 292 | 186 | -80 | 1,617

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> 18 Equity
ING Bank Annual Report 2022 249

Changes in legal and statutory reserves |  |  |  |  |
in EUR million |  |  |  |  |
2022 | Share of associates and joint ventures reserves | Currency translation reserve | Statutory reserves | Capitalised software | Total
Opening balance | 385 | -3,488 | 2,103 | 452 | -548
Result for the year |  |  | 161 |  | 161
Unrealised revaluations available-for-sale investments and other | -252 |  |  |  | -252
Realised gains/losses transferred to the statement of profit or loss | 25 |  |  |  | 25
Changes in cash flow hedge reserve | -701 |  |  |  | -701
Unrealised revaluation property in own use | -33 |  |  |  | -33
Changes in net defined benefit asset/liability remeasurement reserve | 112 |  |  |  | 112
Exchange rate differences and other | -94 | 1,183 |  |  | 1,088
Changes in composition of the group and other changes | 559 |  |  | -50 | 509
Closing balance | 0 | -2,305 | 2,264 | 402 | 361
2021 |  |  |  |  |
Opening balance | 1,398 | -3,631 | 1,912 | 505 | 185
Result for the year |  |  | 191 |  | 191
Unrealised revaluations available-for-sale investments and other | -57 |  |  |  | -57
Realised gains/losses transferred to the statement of profit or loss | -18 |  |  |  | -18
Changes in cash flow hedge reserve | -1,065 |  |  |  | -1,065
Unrealised revaluation property in own use | -14 |  |  |  | -14
Changes in net defined benefit asset/liability remeasurement reserve | 99 |  |  |  | 99
Exchange rate differences and other | 10 | 143 |  |  | 153
Changes in composition of the group and other changes | 32 |  |  | -53 | -21
Closing balance | 385 | -3,488 | 2,103 | 452 | -548

The Share of associates and joint ventures reserve includes the following components: Reserve for non-
distributable retained earnings of associates of EUR 938 million (2021: EUR 862 million), Revaluation reserve
of associates and joint ventures EUR -1,044 million (2021: EUR -83 million), Currency translation reserve of
EUR -89 million (2021: EUR 5 million) and Net defined benefit asset/liability remeasurement reserve of EUR
-286 million (2021: EUR -398 million).
Due to an increase in yield curves in 2022 the interest rate swaps had a negative revaluation of EUR -701
million recognised in the cash flow hedge reserve which is presented as part of share of participating
interests reserve in the parent company financial statements. Due to this negative revaluation, the share of
participating interest reserve became negative, which is not allowed under Dutch law, and is replenished out
of retained earnings (EUR 482 million, included in the line Changes in the composition of the group and
other changes).
The Statutory reserves include non-distributable reserves of EUR 2,264 million (2021: EUR 2,103 million)
related to the former Stichting Regio Bank and the former Stichting Vakbondspaarbank SPN that cannot be
freely distributed in accordance with the article 23.1 of the articles of association.

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> 18 Equity
ING Bank Annual Report 2022 250
Changes in the value of hedging instruments that are designated as net investment hedges, are included in
the line Exchange rate differences and other.

Changes in other reserves, retained earnings |  |
in EUR million | 2022 | 2021
Opening balance | 27,117 | 25,953
Transfer from unappropriated result | 2,661 | 2,321
Dividends | -3,684 | -1,207
Employee stock options and share plans | 27 | 28
Changes in the composition of the group and other changes | -1,054 | 23
Closing balance | 25,067 | 27,117

The reserve for cash flow hedges is included in the Share of associates and joint ventures reserve on a net
basis. The Revaluation reserve, Share of associates and joint ventures reserve and Currency translation
reserve cannot be freely distributed. Retained earnings can be freely distributed, except for an amount
equal to the negative balance in each of the components of the Revaluation reserve , Share of associates
and joint ventures reserve and the Currency translation reserve. Unrealised gains and losses on derivatives,
other than those used in cash flow hedges, are presented in the statement of profit or loss and are therefore
part of Retained earnings and are not included in Share of associates and joint ventures reserve.
The total amount of non-distributable reserves, in accordance with the financial reporting requirements per
Part 9 of Book 2 of the Dutch Civil Code, is EUR 8,408 million (2021: EUR 8,205 million).
Reference is made to Note 19 ‘Equity’ and Note 48 ‘Capital management’ in the ING Bank Consolidated
financial statements for additional information, including restrictions with respect to dividend and
repayment of capital.

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> 18 Equity
ING Bank Annual Report 2022 251
Notes to the Parent company statement of profit or loss
19 N et interest income

Net interest income |  |  |  |  |  |
in EUR million | 2022 | 2021 |  |  | 2022 | 2021
Interest income on loans | 9,511 | 6,865 |  | Interest expense on deposits from banks | 400 | 50
Interest income on impaired loans | 73 | 59 |  | Interest expense on customer deposits | 3,041 | 1,300
Negative interest on liabilities | 650 | 1,211 |  | Interest expense on debt securities | 501 | 489
Total interest income on loans | 10,233 | 8,135 |  | Interest expense on subordinated loans | 646 | 573
|  |  |  | Interest expense on securities at fair value through profit or loss | 565 | 274
Interest income on financial assets at fair value through OCI | 153 | 101 |  | Interest expense on non-trading derivatives (no hedge accounting) | 1,869 | 1,846
Interest income on financial assets at amortised cost | 275 | 210 |  | Interest expense on non-trading derivatives (hedge accounting) | 884 | 453
Interest income on securities at fair value through profit or loss | 763 | 299 |  | Other interest expense | 41 | 37
Interest income on non-trading derivatives (no hedge accounting) | 1,650 | 2,037 |  | Negative interest on assets | 313 | 563
Interest income on non-trading derivatives (hedge accounting) | 1,091 | 1,129 |  | Interest expense | 8,260 | 5,585
Other interest income | 17 | 19 |  |  |  |
Interest income | 14,182 | 11,930 |  | Net interest income | 5,922 | 6,345

Contents |  | Introduction |  | Report of Management Board |  | Our leadership and corporate governance |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information |  |

> 19 Net interest income
ING Bank Annual Report 2022 252
20 Investment income and results from participating interests

Investment income and results from participating interests |  |
in EUR million | 2022 | 2021
Results from shares and other non-fixed income securities | 141 | 142
Results from group companies | 2,193 | 3,029
Results from associates, joint ventures and other participations | 74 | 70
Impairment of associates and joint ventures | -192 | -3
| 2,215 | 3,239

Impairments
In 2022, Impairments of EUR 192 million is predominantly attributable to TTB of EUR 165 million.
21 Net fee and commission income

Fee and commission income |  |
in EUR million | 2022 | 2021
Payment services | 1,093 | 928
Securities business | 205 | 284
Insurance and other broking | 128 | 120
Portfolio Management fees | 259 | 259
Lending business | 299 | 279
Financial guarantees and other commitments | 301 | 284
Other | 118 | 93
| 2,402 | 2,248

Fee and commission expenses |  |
in EUR million | 2022 | 2021
Payment services | 292 | 252
Securities business | 107 | 99
Distribution of products (Externally) | 93 | 76
Other | 92 | 75
| 584 | 502

22 Results from financial transactions

Results from financial transactions |  |
in EUR million | 2022 | 2021
Results from securities trading portfolio | -382 | 787
Results from currency trading portfolio | -157 | 101
Results from non-trading derivatives | 1,742 | 68
Other | -519 | -484
| 683 | 473

I n 2022, Other includes EUR -288 million (2021: EUR -419 million) related to fair value changes on trading
derivatives.
23 Staff expenses

Staff expenses |  |
in EUR million | 2022 | 2021
Salaries | 2,127 | 2,124
Social security costs | 252 | 243
Pension costs and other staff related benefit costs | 294 | 305
Other staff expenses | 576 | 552
| 3,249 | 3,224

Remuneration of Senior management, Management board and Supervisory board
Reference is made to Note 46 'Related parties' in the ING Bank Consolidated financial statements.
24 Depreciation, amortisation and impairments

Depreciation and amortization |  |
in EUR million | 2022 | 2021
Depreciation of equipment | 183 | 213
Amortisation of software and other intangible assets | 155 | 166
Impairments and reversal of impairments | 67 | 29
| 405 | 408

2022 Impairments includes impairment of goodwill (EUR 32 million, 2021: nil), software (EUR 17 million,
2021: EUR 16 million) and equipment (EUR 19 million, 2021: EUR 15 million).

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> 20 Investment income and results from participating interests
ING Bank Annual Report 2022 253
25 Other expenses

Other expenses |  |
in EUR million | 2022 | 2021
Computer costs | 508 | 481
Office expenses | 110 | 104
Travel and accommodation expenses | 29 | 9
Advertising and public relations | 141 | 134
External advisory fees | 231 | 244
Regulatory costs | 609 | 707
Addition/(releases) of provision for reorganisations and relocations | 53 | 220
Other | 469 | 623
| 2,150 | 2,523

26 Taxation

in EUR million | 2022 | 2021
Current taxation | 743 | 682
Deferred taxation | (91) | 20
| 652 | 701

Reconciliation of the weighted average statutory income tax rate to ING Bank’s effective income tax rate
in EUR million | 2022 | 2021
Result before tax from continuing operations | 4,319 | 5,471
Weighted average statutory tax rate | 22.4% | 23.7%
Weighted average statutory tax amount | 967 | 1,296
Permanent differences affecting current tax |  |
Participation exemption | -548 | -809
Other income not subject to tax | -16 | 0
Expenses not deductible for tax purposes | 191 | 135
Current tax from previously unrecognised amounts | 10 | 61
State and local taxes | 22 | 32
Adjustments to prior periods | 5 | -17
Differences affecting deferred tax |  |
Impact on deferred tax from change in tax rates | 5 | 10
Deferred tax from previously unrecognised amounts | -3 | -18
Write-off/reversal of deferred tax assets | 21 | 11
Effective tax amount | 652 | 701
Effective tax rate | 15.1% | 12.8%

For more information on the reconciliation of the weighted average statutory income tax rate to ING Bank’s
effective income tax rate reference is made to Note 35 ‘Taxation’ in the ING Bank Consolidated financial
statements.

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> 25 Other expenses
ING Bank Annual Report 2022 254
27 Maturity of certain assets and liabilities

Analysis of certain assets and liabilities by maturity
in EUR million 2022 | Less than 1 month | 1–3 months | 3–12 months | 1–5 years | Over 5 years | Maturity not applicable | Total
Assets |  |  |  |  |  |  |
Loans and advances to banks | 34,312 | 2,655 | 7,968 | 15,828 | 7,000 | 16,222 | 83,985
Loans and advances to customers | 37,620 | 12,260 | 25,469 | 97,261 | 151,886 | 21,517 | 346,012
Liabilities |  |  |  |  |  |  |
Deposits from banks | 23,088 | 2,555 | 26,115 | 8,227 | 803 | 9,727 | 70,515
Customer deposits | 280,922 | 13,288 | 18,392 | 25,870 | 21,459 | 15,926 | 375,858
Debt securities in issue | 1,974 | 4,582 | 7,402 | 5,835 | 8,459 | 11,274 | 39,526
Subordinated loans |  |  | 760 |  | 16,243 | -1,132 | 15,871

Analysis of certain assets and liabilities by maturity
in EUR million 2022 | Less than 1 month | 1–3 months | 3–12 months | 1–5 years | Over 5 years | Maturity not applicable | Total
Assets |  |  |  |  |  |  |
Loans and advances to banks | 14,514 | 2,733 | 7,823 | 21,412 | 7,668 | 19,890 | 74,040
Loans and advances to customers | 38,244 | 18,995 | 29,066 | 85,614 | 155,917 | 22,367 | 350,202
Liabilities |  |  |  |  |  |  |
Deposits from banks | 24,817 | 1,088 | 3,012 | 52,539 | 929 | 8,862 | 91,247
Customer deposits | 279,257 | 15,129 | 8,342 | 18,808 | 20,483 | 21,142 | 363,162
Debt securities in issue | 2,490 | 8,200 | 9,518 | 3,769 | 8,026 | 17,116 | 49,117
Subordinated loans |  |  |  | 716 | 15,770 | 463 | 16,949

28 Assets not freely disposable

Assets not freely disposable |  |
in EUR million | 2022 | 2021
Equity and debt instruments | 12,662 | 14,026
Lending | 58,336 | 81,926
Banks | 15,932 | 9,236
Other assets | 538 | 733
| 87,468 | 105,921

The table includes assets relating to securities lending as well as sale and repurchase transactions
29 Contingent liabilities and other commitments

Contingent liabilities by type |  |
in EUR million | 2022 | 2021
Guarantees | 47,452 | 40,221
Irrevocable letters of credit | 13,180 | 14,295
Other | 0 | 0
Contingent debts | 60,632 | 54,517
Irrevocable facilities | 86,259 | 75,606
| 146,891 | 130,123

Contingent debts |  |
in EUR million | 2022 | 2021
Group companies | 27,902 | 23,260
Third parties | 32,730 | 31,257
| 60,632 | 54,517

Irrevocable facilities |  |
in EUR million | 2022 | 2021
Group companies | 3 | 3
Third parties | 86,256 | 75,603
| 86,259 | 75,606

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> 27 Maturity of certain assets and liabilities
ING Bank Annual Report 2022 255
30 Other
Guarantees
ING Bank has issued guarantees as participant in collective arrangements of national banking funds and as
a participant in required collective guarantee schemes. For example, ING Bank N.V. provided a guarantee to
the German Deposit Guarantee Fund (‘Einlagensicherundsfonds’ or ESF) under section 5 (10) of the by-laws
of this fund, where ING Bank N.V. indemnifies the Association of German Banks Berlin against any losses it
might incur as result of actions taken with respect to ING Germany. The ESF is a voluntary collective
guarantee scheme for retail savings and deposits in excess of EUR 100,000.
ING Bank N.V. has issued statements of liabilities in connection with Section 403 Book 2 of the Dutch Civil
Code (‘403 statements’) and issued third party guarantees (and third party letters of comfort/awareness) in
a limited number of cases. Third party guarantees are used when ING Bank N.V. is requested to issue a
guarantee to a third party creditor of one of its subsidiaries in order to guarantee the (financial)
performance of this subsidiary. 403 statements have been issued for the following Dutch subsidiaries:
•B.V. Deelnemings- en Financieringsmaatschappij 'Nova Zembla'
•B.V. Maatschappij van Onroerende Goederen 'Het Middenstandshuis'
•Bank Mendes Gans N.V.
•BMG monumenten B.V.
•Cofiton B.V.
•Entero B.V.
•ING Bank Personeel B.V.
•ING Hubs B.V.
•ING Commercial Finance B.V.
•ING Corporate Investments B.V.
•ING Corporate Investments Mezzanine Fonds B.V.
•ING Corporate Investments Participaties B.V.
•ING Corporate Investments Structured Finance B.V.
•ING Groenbank N.V.
•ING Lease (Nederland) B.V.
•ING Sustainable Investments B.V.
•ING Vastgoed Ontwikkeling B.V.
•Nationale-Nederlanden Hypotheekbedrijf N.V.
•Nationale-Nederlanden Intervest II B.V.
•WestlandUtrecht Verzekeringen B.V.
Claim agreements
In the ordinary course of business we have entered into a number of agreements whereby we are provided
indemnifications related to sale of our past businesses and agreements whereby we made detailed
arrangements regarding allocation and handling of claims.
Fiscal unity
ING Bank N.V. forms a fiscal unity with ING Groep N.V. and several Dutch banking entities for corporation tax
purposes. ING Bank N.V. and ING Groep N.V. and its banking subsidiaries that form part of the fiscal unity are
jointly and severally liable for taxation payable by the fiscal unity. Settlements of corporate income tax paid
or received are executed by ING Bank N.V.
31 Proposed appropriation of results
For 2022, it is proposed that the result, insofar at the disposal of the General Meeting, will be appropriated as
follows.

Proposed appropriation of result |
in EUR million | 2022
Net result | 3,667
- Addition to reserves pursuant to Article 24 of the Articles of Association | 161
- Proposed to be added to the Other Reserves pursuant to Article 24 of the Articles of Association |
- Available for dividend distribution | 3,506

The total dividend of EUR 3,506 million was paid in May 2022 (EUR 430 million), August 2022 (EUR 1,180
million), November 2022 (EUR 983 million) and in February 2023 (EUR 913 million) as an interim dividend.
32 Subsequent events
On 6 February 2023, a devastating earthquake with multiple aftershocks struck southern and central Turkey
and northern and western Syria causing a significant tragedy for the people and is causing disruption to
business and economic activity in the region. This qualifies as a non-adjusting subsequent event.

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> 30 Other
ING Bank Annual Report 2022 256
Authorisation of Parent company financial statements
Amsterdam, 6 March 2023
The Supervisory Board
G.J. (Hans) Wijers, chairman
A.M.G. (Mike) Rees, vice-chairman
J. (Juan) Colombás
M. (Mariana) Gheorghe
M. (Margarete) Haase
L.J. (Lodewijk) Hijmans van den Bergh
H.A.H. (Herman) Hulst
H.H.J.G. (Harold) Naus
H.W.P.M.A. (Herna) Verhagen
The Management Board Banking
S.J.A. (Steven) van Rijswijk, CEO and chairman
T. (Tanate) Phutrakul, CFO
L. (Ljiljana) Čortan, CRO
P. (Pinar) Abay, head of Market Leaders
A.J.M. (Andrew) Bester, head of Wholesale Banking
A. (Aris) Bogdaneris, head of Challengers & Growth Markets and head of Retail Banking
R.H.E. (Ron) van Kemenade, chief technology officer
M.A. (Marnix) van Stiphout, chief operations officer and chief transformation officer

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> Authorisation of Parent company financial statements
ING Bank Annual Report 2022 257
To: the General Meeting of the Shareholder and the Supervisory Board of ING Bank N.V.
Report on the audit of the financial statements 2022 included in the annual report
Our opinion
In our opinion:
—the accompanying consolidated financial statements give a true and fair view of the financial position of ING Bank
N.V. as at 31 December 2022 and of its result and its cash flows for the year then ended, in accordance with
International Financial Reporting Standards as adopted by the European Union (EU-IFRS) and with Part 9 of Book
2 of the Dutch Civil Code
—the accompanying parent company financial statements give a true and fair view of the financial position of ING
Bank N.V. as at 31 December 2022 and of its result for the year then ended in accordance with Part 9 of Book 2 of
the Dutch Civil Code.
What we have audited
We have audited the financial statements 2022 of ING Bank N.V. (the ’Company’ or ‘ING Bank’) based in Amsterdam. The
financial statements include the consolidated financial statements and the parent company financial statements.
The consolidated financial statements comprise:
1 the consolidated statement of financial position as at 31 December 2022;
2 the following consolidated statements for 2022: the statement of profit or loss, the statements of comprehensive
income, changes in equity and cash flows; and
3 the notes comprising a summary of the significant accounting policies and other explanatory information.
The company financial statements comprise:
1 the parent company statement of financial position as at 31 December 2022;
2 the parent company statement of profit or loss and the statement of changes in equity for 2022; and
3 the notes comprising a summary of the accounting policies and other explanatory information.
Basis for our opinion
We conducted our audit in accordance with Dutch law, including the Dutch Standards on Auditing. Our responsibilities
under those standards are further described in the ‘Our responsibilities for the audit of the financial statements’ section of
our report.
We are independent of ING Bank N.V. in accordance with the ‘Verordening inzake de onafhankelijkheid van accountants
bij assurance-opdrachten’ (ViO, Code of Ethics for Professional Accountants, a regulation with respect to independence)
and other relevant independence regulations in the Netherlands. Furthermore, we have complied with the ‘Verordening
gedrags- en beroepsregels accountants’ (VGBA, Dutch Code of Ethics).
We designed our audit procedures in the context of our audit of the financial statements as a whole and in forming our
opinion thereon. The information in respect of fraud, non-compliance with laws and regulations, going concern, climate-
related risks and the key audit matters was addressed in this context, and we do not provide a separate opinion or
conclusion on these matters.
We believe the audit evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
Information in support of our opinion
Summary

Materiality
—Group materiality of EUR 250 million (2021: EUR 250 million). —4.5% of profit before taxation from continuing operations (2021: 3.7% of profit before taxation from continuing operations).
Group audit
—83% of profit before taxation from continuing operations covered by audit procedures performed by component auditors (2021: 81%). —92% of total assets covered by audit procedures performed by component auditors (2021: 93%).

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KPMG Accountants N.V., a Dutch limited liability company registered with the trade register in the Netherlands under number 33263683, is a member firm of the global organization of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee.
2352201/23W00186397AVN 258

Fraud, non-compliance with laws and regulations, going concern and climate-related risks
—Fraud & non-compliance with laws and regulations related risks: in our audit we incorporated the pervasive presumed fraud risk of management override of controls and the fraud risk of management override specifically over the collective loan loss provisioning. —Going concern related risks: no going concern risks identified. —Climate-related risks: we have considered the impact of climate-related risks on the financial statements and described our approach and observations in the section ‘audit response to climate-related risks’.
Key audit matters
—Assessment of expected credit losses on loans and advances to customers and loans and advances to banks. —Risk of inappropriate access or changes to IT systems.
Opinion
Unqualified

Materiality
Based on our professional judgement we determined the materiality for the financial statements as a whole at EUR 250
million (2021: EUR 250 million). The materiality is determined with reference to profit before taxation from continuing
operations and represents 4.5% (2021: 3.7%) of that balance. We consider profit before tax from continuing operations as
the most appropriate benchmark based on our assessment of the general information needs of the users of the financial
statements and given the fact that ING Bank is a profit-oriented entity. We have also taken into account misstatements
and/or possible misstatements that in our opinion are material for the users of the financial statements for qualitative
reasons.
We agreed with the Audit Committee of the Supervisory Board that misstatements identified during our audit in excess of
EUR 12.5 million (2021: EUR 12.5 million) would be reported to them, as well as smaller misstatements that in our view
must be reported on qualitative grounds.
Scope of the group audit
ING Bank is at the head of a group of components. The financial information of this group is included in the consolidated
financial statements of ING Bank.
ING Bank is structured in 6 segments: Retail Netherlands, Retail Belgium, Retail Germany, Retail Other, Wholesale
Banking and Corporate Line Banking, each comprising of multiple legal entities and/or covering different countries.
Because we are ultimately responsible for the group audit, we are responsible for directing, supervising and performing
the group audit. In this respect, we have determined the nature and extent of audit procedures to be carried out for group
entities or so-called components.
Our group audit mainly focused on significant components. These components are either individually financially significant
due to their relative size in the group or because we identified a significant risk of material misstatement for one or more
account balances of these entities.
In addition, we included certain other non-significant components in the scope of our group audit in order to arrive at a
sufficient coverage over all significant account balances.
This resulted in a full or specific scope audit for 41 components globally, in total covering 17 countries. This resulted in a
coverage of 83% of profit before tax from continuing operations and 92% of total assets. For the remaining 17% of profit
before tax from continuing operations and the remaining 8% of total assets, procedures were performed at the group level
including analytical procedures in order to corroborate that our scoping remained appropriate throughout the audit.
The consolidation of components in the group, the disclosures in the financial statements and certain accounting topics
that are performed on a group level were further covered by the group audit team. Procedures performed by the group
audit team included, but were not limited to, substantive procedures with respect to equity and hyperinflation accounting,
and certain elements of the expected credit loss provisioning process.
All components in scope for group reporting are audited by KPMG member firms. We sent detailed audit instructions to all
component auditors, covering significant areas such as the identified risks of material misstatement on a group level and
further set out the information that is required to be reported to the group audit team.
We performed site visits with local management and local audit teams, also to perform file reviews in The Netherlands,
Belgium, Germany, Italy, Luxembourg, Poland, South Korea, and Turkey. We performed a remote file review for the USA
and Australia. We visited Singapore and Australia during the year to meet local management and local audit teams to
discuss the design and progress of their audit work.
For all components in scope of the group audit, we held our annual planning conference in The Netherlands. This was the
first time after the COVID-19 period. Our component auditors were directly informed by the Bank CFO, Bank CRO, Global
Head of Sustainability and Head of CSI on current developments. In addition, we had conference calls with these
component audit teams and we attended closing meetings with management for components in The Netherlands,
Belgium and Germany. During these meetings and calls, the planning, risk assessment, procedures performed, findings
and observations reported to the group auditor were discussed in detail and any further work deemed necessary by the
group audit team was then performed.
The group audit team set component materiality levels which ranged from EUR 20 million to EUR 95 million, based on the
mix of relative size and financial statement risk profile of the components within the group in order to reduce the
aggregation risk to an acceptable level.
By performing the procedures mentioned above together with additional procedures at group level, we have been able to
obtain sufficient and appropriate audit evidence about ING Bank’s financial information to provide an opinion about the
financial statements.
Our procedures as described above can be summarized as follows:

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Profit before tax from continuing operations
83% |  | 17%
Covered by audit procedures performed by component auditors |  | Covered by additional procedures performed at group level
Total assets
92% |  | 8%
Covered by audit procedures performed by component auditors |  | Covered by additional procedures performed at group level

Audit response to the risk of fraud and non-compliance with laws and regulations
Introduction
In chapters ‘Strategy and performance’ and ‘Risk management - non-financial risk and compliance risk’ of the annual
report and note 42 of the financial statements, the Management Board Banking describes its procedures in respect of the
risk of fraud and non-compliance with laws and regulations. In the Supervisory Board report the assessment by the Risk
Committee in respect of these topics is described.
As part of our audit, we have gained insights into the Company and its business environment and assessed the design
and implementation and where considered appropriate tested operating effectiveness of the Company’s internal controls
that mitigate fraud and non-compliance risks.
Our procedures included, among other things, assessing the Company’s code of conduct, the whistle blower process, and
its procedures to investigate indications of possible fraud and non-compliance. Furthermore, we performed relevant
inquiries with management, the Supervisory Board and other relevant functions, such as the General Legal Counsel and
the head of Compliance and Internal Audit.
In performing these procedures, we involved our forensic specialists.
As part of our audit procedures, we:
—obtained an understanding of how the Company uses information technology (IT) and the impact of IT on the
financial statements, including the potential for cybersecurity incidents to have a material impact on the financial
statements;
—assessed other positions held by Management Board Banking members and/or other employees and paid special
attention to procedures and governance/compliance in view of possible conflicts of interest;
—evaluated reports from Compliance and Internal Audit and investigation reports on indications of possible fraud and
non-compliance;
—evaluated correspondence with supervisory authorities and regulators as well as legal letters.
Non- compliance with laws and regulations
We performed procedures to obtain an understanding of the legal and regulatory frameworks that are applicable to the
Company and identified the following areas as those most likely to have a material effect on the financial statements:
—anti-money laundering and anti-terrorist financing law;
—sanctions law;
—data protection law;
—fraud, corruption and anti-bribery law; and
—prudential and supervision regulations from the European Central Bank and the Dutch Central Bank.
With respect to the bank wide Know Your Customer enhancement program (the ‘KYC enhancement program’) as
disclosed in the Management Board Banking report in order to improve governance, systems and tools around client due
diligence and transaction monitoring, we inquired with senior management, the General Legal Counsel and the heads of
Compliance and Internal audit.
We inspected the progress reports in relation to the KYC enhancement program and we evaluated and discussed internal
audit reports in relation to compliance. We also visited one of the Company’s hubs, in Slovakia, together with our forensic
specialist. This hub performs client due diligence and transaction monitoring activities on behalf of many ING Bank
companies. We deepened our understanding of the work performed in this hub.
We observed that the KYC enhancement program made further progress in 2022, and the finalisation of the KYC
enhancement program will continue to require ongoing attention from management, the Audit Committee and the
Supervisory Board.
We evaluated the fraud and non-compliance risk factors to consider whether those factors indicate a risk of material
misstatement in the financial statements.
Revenue recognition (a presumed risk)
We assessed the presumed fraud risk on revenue recognition. We disaggregated revenues and considered interest
income, fee and commission income, valuation results and net trading income, and other income. We considered the
relative size and nature of these revenue categories and based on that focused on interest income and fee and
commission income. For both revenue categories we assessed the composition of these revenues, taking into account
homogeneity, routine or non-routine characteristics, whether there is an estimation uncertainty in recognising income,
whether there is significant related party involvement and whether there are complexities in the related reporting.
Based on these procedures we concluded the fraud risk as irrelevant, because the accounting of interest income and fee
and commission income is predominantly based on automatically generated accruals based on static data taken from
source systems and therefore contain routine transactions not subject to management judgement. As a consequence, we
did not identify an incentive nor pressure for the Management Board Banking members to achieve certain results or
specific finance income targets and there appears to be limited perceived opportunity to commit a material fraud in this
area.
Based on the above and on the auditing standards, we identified the following fraud risks that are relevant to our audit and
responded as follows:

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Management override of controls (a presumed risk)
Management is in a unique position to manipulate accounting records and prepare fraudulent financial statements by
overriding controls that otherwise appear to be operating effectively, such as reporting fictitious journal entries. Although
the level of risk of management override of controls may vary from entity to entity, the risk nevertheless is present at all
entities, including at ING Bank level. A fraud risk is by nature considered a significant audit risk.
We evaluated the design and the implementation and were considered appropriate tested the operating effectiveness of
internal controls that mitigate fraud risks, such as processes related to journal entries and estimates related to loan loss
provisions.
We performed a data analysis of high-risk journal entries and evaluated key estimates and judgments for bias by the
Company’s management. Where we identified instances of unexpected journal entries or other risks through our data
analytics, we performed additional audit procedures to address each identified risk, including testing of transactions back
to source information.
We incorporated elements of unpredictability in our audit, including making changes to our high-risk criteria that we
applied to journal entry testing, varying the timing of audit procedures including testing of controls and a site visit to a
remote entity (South Korea).
Management override of collective loan loss provisioning (ECL)
With respect to the risk of fraud in relation to management override of Expected Credit Loss provision results, we refer to
the Key audit matter ‘Assessment of Expected Credit Losses on loans and advances to customers and loans and
advances to banks’.
We communicated our risk assessment, audit responses and results to the Management Board Banking and the Audit
Committee of the Supervisory Board. Our evaluation of procedures performed related to fraud and non-compliance with
laws and regulations did not result in an additional key audit matter.
Our audit procedures did not reveal indications and/or reasonable suspicion of fraud and non-compliance that are
considered material for our audit.
Audit response to going concern
The Management Board Banking has performed its going concern assessment and has not identified any going concern
risks. Our main procedures to assess the Management Board Banking’s assessment were:
—we considered whether the Management Board Banking’s assessment of the going concern risks includes all
relevant information of which we are aware as a result of our audit;
—we analysed the Company’s financial position as at year-end and compared it to the previous financial year in
terms of indicators that could identify going concern risks;
—we inspected documentation of stress testing of the economic and regulatory capital position performed during the
year by management;
—we inspected regulatory correspondence to obtain an understanding of the Company’s capital and liquidity
position, that underpins management’s assessment of the going concern assumption for financial reporting.
The outcome of our risk assessment procedures did not give reason to perform additional audit procedures on the
Management Board Banking’s going concern assessment.
Audit response to climate-related risks
In planning our audit, we considered the potential impact of risks arising from climate change on the Company’s business
and its financial statements. The Company has set out its commitments and ambitions relating to climate change in the
chapter ‘Strategy and performance’ (‘Sustainability at the heart’) of the annual report. The Company aims to reach net
zero in their own operations, to steer the most carbon-intensive parts of the loan portfolio towards net zero by 2050 or
sooner, and to finance and advise specific clients in line with a net-zero economy.
Management extensively assessed how climate-related risks and opportunities and the company’s own commitments and
ambitions could have a significant impact on its business or could impose the need to adapt its strategy and operations.
Management considered the impact of both transition and physical risks on the financial statements in accordance with
the applicable financial reporting framework, specifically the expected credit losses of loans and advances, as described
in the chapter ‘Risk management – environmental, social and governance risk’ and the section ‘Risk management –
climate and environmental risks in IFRS9 models’ of the annual report. Management disclosed considerations directly
impacting the financial statements captions as well as the medium to longer term risk drivers that do not have a material
direct impact on the 2022 financial statements.
Management prepared the financial statements, including considering whether the implications from climate-related risks
and commitments and ambitions have been appropriately accounted for and disclosed. In the Supervisory Board report,
the involvement of the Audit Committee and the ESG-Committee in overseeing the financial statement process in relation
to climate-related risks is reflected on.
The Management Board Banking is responsible for the analysis of the impact of climate-related risks on the Company’s
business and operations going forward and on the financial statements.
As part of our audit, we performed a risk assessment of the impact of climate-related risks, the commitments and
ambitions made by the Company in respect of climate change on the financial statements and our audit approach. In
doing this we performed the following:
—To understand management's processes, against the background of ING’s business and operations:
-we made inquiries with the Management Board Banking and other senior management and inspected relevant
documents to understand management's assessment of the potential impact of climate-related risk and
opportunities on the Company’s financial statements and the Company's preparedness for this;
-we inquired on this topic with members of the ESG Committee and the Audit Committee of the Supervisory
Board;
-we read the minutes of meetings of the Management Board Banking and the Supervisory Board. We also
inspected regulatory correspondence to obtain an understanding of management’s assessment of climate risk
and the related risk management thereof;
-we performed an analysis of the external environment and obtained an understanding of relevant sustainability
themes and issues relevant for ING;

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-we gained an understanding whether any current and/or future regulations may impact the Company, such as
greenhouse gas emission regulations, potential increases in taxes on current products and future climate
reporting obligations.
—We evaluated climate-related fraud risk factors on reporting inappropriate disclosures on climate-related risk and
pressures for management to meet the climate targets, since that such targets are linked to the Management
Board Banking’s remuneration.
—We used our climate change subject matter experts to assist in understanding how climate-related risks and
pressures for management to meet the climate targets and opportunities may affect the Company and its
accounting in the current year’s financial statements.
—We used our climate change subject matter experts and modelling experts to assist in gaining understanding how
climate-related risks are of impact on the expected credit loss estimation, including the credit risk models, as
determined by the Company.
Based on the procedures performed above we concluded that climate-related risks have no material impact on the 2022
financial statements under the requirements of the International Financial Reporting Standards as adopted by the
European Union (EU-IFRS) and with Part 9 of Book 2 of the Dutch Civil Code and no impact on our key audit matters.
Furthermore, we have read the ‘Other information’ with respect to climate-related risks as included in the annual report
and considered the material consistency with the financial statements, our knowledge obtained through the audit, as
described above and our knowledge obtained otherwise.
Our key audit matters
Key audit matters are those matters that, in our professional judgement, were of most significance in our audit of the
financial statements. We have communicated the key audit matters to the Audit Committee of the Supervisory Board. The
key audit matters are not a comprehensive reflection of all matters discussed.

Assessment of expected credit losses on loans and advances to customers and loans and advances to banks

Description
As discussed in the Credit Risk section on pages 64-96 and in Note 3 and Note 7 in the consolidated financial statements,
the loans and advances to customers amount to EUR 636 billion and loans and advances to banks amount to EUR 35
billion as at 31 December 2022. These loans and advances are measured at amortized cost, less expected credit losses
(‘ECL’) of EUR 6.0 billion.
Management estimated ECL using three components: probability of default (‘PD’), loss given default (‘LGD’) and exposure
at default (‘EAD’). Management 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 addressed by judgmental
overlays by management.
Our response
We identified the assessment of ECL on loans and advances to customers and loans and advances to banks as a key
audit matter because of the significant and complex auditor judgment and specialised skills and knowledge required to
evaluate the following elements of the overall ECL estimate:
—The judgements used to develop the PD, LGD, EAD, including model or manually determined expected future
recovery cash flow assessments of individual loan provisions for impaired loans.
—Use of forward-looking macroeconomic forecasts in ECL, including GDP, HPI and unemployment rate.
—The consistent identification and application of criteria for significant increase in credit risk (‘SICR’) in an increased
uncertain and worsened macroeconomic environment and geopolitical situation.
—Calculation of management overlays to the modelled ECL due to the increased uncertainty in the macroeconomic
outlook in the global economy. These management overlays included economic sector-based adjustments in the
Netherlands, second order impact adjustments for both wholesale bank and retail bank, and overlays to residential
mortgages.
The following are the primary procedures we performed to address this key audit matter.
—We evaluated the design and tested the operating effectiveness of certain internal controls related to the ECL
process for loans and advances to customers and loans and advances to banks. This included controls related to
the assumptions (including PD, LGD, EAD and macroeconomic forecasts), review of model outputs, the
application of the definition of default, the update of data history, governance and monitoring of the ECL,
reconciliations, determination of credit risk ratings, the estimated future recovery cash flows of individual loan
provisions and management overlays to the modelled ECL.
—We involved credit risk professionals with specialised skills and knowledge who assisted in evaluating the
assumptions to determine the PD, LGD, and EAD 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. In addition, we tested
management overlays recorded to the ECL, including economic sector-based adjustments in the Netherlands,
second order impact adjustments for both wholesale bank and retail bank, and overlays to residential mortgages.
We considered the impact these overlays have on model calculations and results when reaching our conclusions.
—We involved economic professionals with specialised skills and knowledge, who assisted in assessing the
Company’s methodology to determine the macroeconomic forecasts used in the ECL. We tested the
reasonableness of management’s forecasts against other external benchmarks and our own internal forecasts.
—We involved corporate finance professionals with specialised skills and knowledge, who assisted in examining the
methodologies, cash flows and collateral values used in expected future recovery cash flow assessments of
individual loan provisions for impaired loans. We challenged management’s use of recovery scenarios and
expected cash flows considering industry trends and comparable benchmarks, recalculated recovery amounts and
performed reconciliations.
—We evaluated the identification of SICR in loans 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 being credit impaired.

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—We assessed whether the credit risk management disclosures appropriately reflect and address the uncertainties
which exist in determining the ECL.
Our observation
Based on our procedures performed, we found management’s overall assessment relating to the valuation of loans and
advances to customers and banks within an acceptable range and adequately disclosed in Note 3 and Note 7 of the
financial statements.

Risk of inappropriate access or changes to information technology systems

Description
ING Bank is highly dependent on its IT environment for the continuity of its operations. Inappropriate access or changes
to an application or supporting infrastructure could compromise the continuity of ING Bank’s operations and the reliability
of financial data. The IT environment of ING Bank evolves over time. One of these changes regards the implementation of
automation to support control execution related to user access management and change management.
Due to the above, we consider the operation of IT systems relevant for financial reporting and the related internal controls
a key audit matter.
Our response
Our audit approach depends to a large extent on the effectiveness of automated controls and, therefore, procedures are
designed to test among others access and change management controls over IT systems. Given the IT technical
characteristics of this part of the audit, IT auditors are an integral part of our engagement team. As part of our risk
assessment and design of the IT audit approach we:
—examined the framework of governance over ING Bank’s IT organisations, the IT general (including cybersecurity)
controls and application controls;
—assessed the reliability and continuity of the IT environment when relevant for the scope of our audit of the financial
statements;
—took into account regulatory correspondence related to IT;
—determined which controls are required prior to using automation for control execution, in response to the
implementation of automation to support control execution related to user access and change management;
—held corroborative inquiries with the personnel at the Security Operations Center and with the Company’s Chief
Information Security Officer (CISO).
We performed testing of operating effectiveness of user access and change management controls. We developed our
understanding and tested key controls in the new automated tooling to support control execution related to user access
management and change management where relevant to our audit. We performed test procedures to respond to specific
risks such as the ongoing data migration to the ING Private Cloud and replacement of their global identify and access
management system.
We identified areas for improvement in the control execution relating to information used in the control, interface testing
and change management. Control deficiencies relate to both automated and manual control execution. Management has
put efforts to remediate identified control deficiencies. For those control deficiencies that were not remediated, we tested
compensating controls that addressed the same risk or mitigating controls that lowered the risk of the deficiency and
performed additional substantive testing.
As for the continuity of its operations and financial reporting ING Bank has established a framework to ensure operational
resilience in business and IT services and to mitigate the risks related to cybercrime. We developed our understanding of
key controls supporting their cyber operations. Incidents that occurred during 2022, were handled by management in
accordance with that framework and without impact to ING assets.
Our observation
The combination of the tests of the controls and the substantive tests performed, provided sufficient evidence to enable us
to rely on the adequate and continued operation of the IT systems for the purposes of our audit.
Report on the other information included in the annual report
In addition to the financial statements and our auditor’s report thereon, the annual report contains other information.
Based on the following procedures performed, we conclude that the other information:
—is consistent with the financial statements and does not contain material misstatements; and
—contains the information as required by Part 9 of Book 2 of the Dutch Civil Code for the management report and
other information.
We have read the other information. Based on our knowledge and understanding obtained through our audit of the
financial statements or otherwise, we have considered whether the other information contains material misstatements.
By performing these procedures, we comply with the requirements of Part 9 of Book 2 of the Dutch Civil Code and the
Dutch Standard 720. The scope of the procedures performed is less than the scope of those performed in our audit of the
financial statements.
The Management Board Banking is responsible for the preparation of the other information, including the information as
required by Part 9 of Book 2 of the Dutch Civil Code.
Report on other legal and regulatory requirements and ESEF
Engagement
We were engaged by the General Meeting of Shareholders as auditor of ING Bank N.V. on 11 May 2015, as of the audit
for the year 2016 and have operated as statutory auditor ever since that financial year. We have been reappointed by the
General Meeting of Shareholders on 23 April 2019 to continue to serve ING Bank as its external auditor for the financial
years 2020-2023.
No prohibited non-audit services
We have not provided prohibited non-audit services as referred to in Article 5(1) of the EU Regulation on specific
requirements regarding statutory audits of public-interest entities.

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Services rendered
For the period to which our statutory audit relates, in addition to this audit, we have provided the following services to the
Company and its controlled undertakings:
—agreed-upon procedures and assurance engagements for the benefit of external stakeholders, largely driven by
regulatory requirements.
European Single Electronic Format (ESEF)
ING Bank has prepared its annual report in ESEF. The requirements for this are set out in the Delegated Regulation (EU)
2019/815 with regard to regulatory technical standards on the specification of a single electronic reporting format
(hereinafter: the RTS on ESEF).
In our opinion the annual report prepared in XHTML format, including the (partly) marked-up consolidated financial
statements as included in the reporting package by ING Bank, complies in all material respects with the RTS on ESEF.
The Management Board Banking is responsible for preparing the annual report including the financial statements in
accordance with the RTS on ESEF, whereby the Management Board Banking combines the various components into one
single reporting package.
Our responsibility is to obtain reasonable assurance for our opinion whether the annual report in this reporting package
complies with the RTS on ESEF. We performed our examination in accordance with Dutch law, including Dutch Standard
3950N ’Assurance-opdrachten inzake het voldoen aan de criteria voor het opstellen van een digitaal
verantwoordingsdocument’ (assurance engagements relating to compliance with criteria for digital reporting). Our
examination included among others:
—Obtaining an understanding of the entity's financial reporting process, including the preparation of the reporting
package.
—Identifying and assessing the risks that the annual report does not comply in all material respects with the RTS on
ESEF and designing and performing further assurance procedures responsive to those risks to provide a basis for
our opinion including:
-obtaining the reporting package and performing validations to determine whether the reporting package
containing the Inline XBRL instance document and the XBRL extension taxonomy files have been prepared in
accordance with the technical specifications as included in the RTS on ESEF; and
-examining the information related to the consolidated financial statements in the reporting package to
determine whether all required mark-ups have been applied and whether these are in accordance with the RTS
on ESEF.
Description of responsibilities regarding the financial statements
Responsibilities of the Management Board Banking and the Supervisory Board for the financial
statements
The Management Board Banking is responsible for the preparation and fair presentation of the financial statements in
accordance with EU-IFRS and Part 9 of Book 2 of the Dutch Civil Code. Furthermore, the Management Board Banking is
responsible for such internal control as the Management Board Banking determines is necessary to enable the
preparation of the financial statements that are free from material misstatement, whether due to fraud or error. In that
respect the Management Board Banking, under supervision of the Supervisory Board, is responsible for the prevention
and detection of fraud and non-compliance with laws and regulations, including determining measures to resolve the
consequences of it and to prevent recurrence.
As part of the preparation of the financial statements, the Management Board Banking is responsible for assessing the
Company’s ability to continue as a going concern. Based on the financial reporting frameworks mentioned, the
Management Board Banking should prepare the financial statements using the going concern basis of accounting unless
the Management Board Banking either intends to liquidate the company or to cease operations or has no realistic
alternative but to do so. The Management Board Banking should disclose events and circumstances that may cast
significant doubt on the company’s ability to continue as a going concern in the financial statements.
The Supervisory Board is responsible for overseeing the Company’s financial reporting process.
Our responsibilities for the audit of the financial statements
Our objective is to plan and perform the audit engagement in a manner that allows us to obtain sufficient and appropriate
audit evidence for our opinion.
Our audit has been performed with a high, but not absolute, level of assurance, which means we may not detect all
material errors and fraud during our audit.
Misstatements can arise from fraud or error and are considered material if, individually or in the aggregate, they could
reasonably be expected to influence the economic decisions of users taken on the basis of these financial statements.
The materiality affects the nature, timing and extent of our audit procedures and the evaluation of the effect of identified
misstatements on our opinion.
A further description of our responsibilities for the audit of the financial statements is included in the appendix of this
auditor's report. This description forms part of our auditor’s report.
Amstelveen, 6 March 2023
KPMG Accountants N.V.
P.A.M. de Wit RA
Appendix:
Description of our responsibilities for the audit of the financial statements

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Appendix
Description of our responsibilities for the audit of the financial statements
We have exercised professional judgement and have maintained professional scepticism throughout the audit, in
accordance with Dutch Standards on Auditing, ethical requirements and independence requirements. Our audit included
among others:
—identifying and assessing the risks of material misstatement of the financial statements, whether due to fraud or
error, designing and performing audit procedures responsive to those risks, and obtaining audit evidence that is
sufficient and appropriate to provide a basis for our opinion. The risk of not detecting a material misstatement
resulting from fraud is higher than the risk resulting from error, as fraud may involve collusion, forgery, intentional
omissions, misrepresentations, or the override of internal control;
—obtaining an understanding of internal control relevant to the audit in order to design audit procedures that are
appropriate in the circumstances, but not for the purpose of expressing an opinion on the effectiveness of the
Company’s internal control;
—evaluating the appropriateness of accounting policies used and the reasonableness of accounting estimates and
related disclosures made by the Management Board Banking;
—concluding on the appropriateness of the Management Board Banking’s use of the going concern basis of
accounting, and based on the audit evidence obtained, whether a material uncertainty exists related to events or
conditions that may cast significant doubt on the Company’s ability to continue as a going concern. If we conclude
that a material uncertainty exists, we are required to draw attention in our auditor’s report to the related disclosures
in the financial statements or, if such disclosures are inadequate, to modify our opinion. Our conclusions are based
on the audit evidence obtained up to the date of our auditor’s report. However, future events or conditions may
cause a company to cease to continue as a going concern;
—evaluating the overall presentation, structure and content of the financial statements, including the disclosures; and
—evaluating whether the financial statements represent the underlying transactions and events in a manner that
achieves fair presentation.
We are solely responsible for the opinion and therefore responsible to obtain sufficient appropriate audit evidence
regarding the financial information of the entities or business activities within the group to express an opinion on the
financial statements. In this respect we are also responsible for directing, supervising and performing the group audit.
We communicate with the Supervisory Board regarding, among other matters, the planned scope and timing of the audit
and significant audit findings, including any significant findings in internal control that we identify during our audit. In this
respect we also submit an additional report to the audit committee in accordance with Article 11 of the EU Regulation on
specific requirements regarding statutory audits of public-interest entities. The information included in this additional report
is consistent with our audit opinion in this auditor’s report.
We provide the Supervisory Board with a statement that we have complied with relevant ethical requirements regarding
independence, and to communicate with them all relationships and other matters that may reasonably be thought to bear
on our independence, and where applicable, related safeguards.
From the matters communicated with the Supervisory Board, we determine the key audit matters: those matters that were
of most significance in the audit of the financial statements. We describe these matters in our auditor’s report unless law
or regulation precludes public disclosure about the matter or when, in extremely rare circumstances, not communicating
the matter is in the public interest.

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Articles of Association – Appropriation of results
Appropriation of results
The result is appropriated pursuant to Article 24 of the Articles of Association of ING Bank N.V., the
relevant stipulations of which state that the result shall firstly be appropriated to the Stichting Regio Bank
Reserve, respectively the Reserve Stichting Vakbondsspaarbank SPN or charged to that reserves in
proportion to the ratio between the Stichting Regio Bank Reserve, respectively the Reserve Stichting
Vakbondsspaarbank SPN and the company's equity at the end of the relevant financial year and that the
remainder shall be at the disposal of the General Meeting.

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> Articles of Association – Appropriation of results
ING Bank Annual Report 2022 266
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 the volatility and strength of the economic, business,
liquidity, funding and capital markets environments of the various geographic regions in which we
conduct business, including Russia and Ukraine, 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.
•ING’s business, results and financial condition have been, and may continue to be, adversely affected by
the Covid-19 pandemic.
•Interest volatility and other interest rate 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 in Europe and the United States, 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.
•Discontinuation of interest rate benchmarks may negatively affect our business, results and financial
condition.
•Inflation and deflation may negatively 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.
•We may incur losses due to failures of banks falling under the scope of state compensation schemes.
Risks related to the regulation and supervision of the Group
•Non-compliance with laws and/or regulations concerning financial services or financial institutions,
including with respect to financial economic crimes, could result in fines and other liabilities, penalties or
consequences for us, which could materially affect our business 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 activities.
•We are subject to additional legal and regulatory risk in certain countries where we operate with less
developed or predictable legal and regulatory frameworks.
•We are subject to the regulatory supervision of the ECB and other regulators 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 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.
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 with or proceedings or investigations
with respect to, tax laws.
•We may be subject to US tax investigation if we fail to comply with our obligations as a Participating
Financial Institution in respect of the Foreign Account Tax Compliance Act (“FATCA”) and as a Qualified
Intermediary in respect of other US tax regulations
•ING is exposed to the risk of claims from customers 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 internal or external aims or expectations 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 physical risks, including as a direct result of climate
change.
•ING’s business and operations are exposed to transition risks related to climate change.

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ING Bank Annual Report 2022 267
•Operational and IT risks, such as systems 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.
•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 monetize our internal innovations and restrict our ability to capitalize 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 or assumptions to model client behaviour for the
purposes of our market calculations may adversely impact our reputation or results.
•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 impact our liquidity, borrowing and capital positions,
as well as the cost of liquidity, borrowings and capital.

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ING Bank Annual Report 2022 268
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 most material risk factors have been presented first within each category, the order in which
the remaining 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.
ING Group is a holding company whose principal asset is its investments in the capital stock of ING Bank, its
primary banking subsidiary. As a result, the risks applicable to ING Bank are substantially similar to those
impacting ING Group.
Risks related to financial conditions, market environment and general economic trends
Our revenues and earnings are affected by the volatility and strength 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 around 37 million customers, corporate clients and financial institutions in over 40 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 most of our Retail Banking
markets. In Wholesale Banking, we provide specialised lending, tailored corporate finance, debt and equity
market solutions, payments & cash management, trade and treasury services. As a result, negative
developments in financial markets and/or countries or regions in which we operate, 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, securities prices, credit spreads, liquidity spreads,
exchange rates, consumer spending, changes in customer behaviour, climate change, business investment,
real estate values and private equity valuations, government spending the volatility and strength of the
capital markets, political events and trends, supply chain disruptions, shortages, terrorism, pandemics and
epidemics (such as the recent Covid-19 pandemic) or other widespread health emergencies 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. Certain of these risks are often
experienced globally as well as in specific geographic regions and are described in greater detail below
under the headings “–Interest rate volatility and other interest rate changes may adversely affect our
business, results and financial condition”, “–Inflation and deflation may negatively 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 in Europe and the United States, 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”. 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, Turkey, Poland and the
remainder of Eastern Europe, Southern Europe, East Asia (primarily Singapore among others) 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

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ING Bank Annual Report 2022 269
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. Further, while the Covid-19 pandemic and related response measures have eased, the effects of
these measures are still being felt in the financial performance and stability of certain of our business
customers. 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 have significantly impacted, and may continue to significantly
impact, Russia’s economy and have contributed to 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 the entire wholesale banking portfolio (e.g. commodities
financing, energy and utilities and energy-consuming clients).
Environmental and/or climate risks may also directly and indirectly impact ING, 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 (this includes, but is not limited to, greenwashing risk).
For further information on ING’s exposure to particular geographic areas, see Note 32 ‘Information on
geographical areas’ to the consolidated financial statements.
ING’s business, results and financial condition have been, and may continue to be,
adversely affected by the Covid-19 pandemic.
The Covid-19 pandemic and the related response measures introduced by various national and local
governmental authorities (such as restrictions on social activity, travel, movement and certain economic
activity) have had, and are expected to continue to have, adverse effects on global economic conditions,
including inflation, depressed global economic growth, disrupted supply chains, manufacturing, tourism,
reduced consumer spending, lower asset prices and higher unemployment levels, as well as increased
volatility and uncertainty across the global economy and financial markets.
If these effects are prolonged, or if new Covid-19 variants emerge which require reimplementation of the
response measures outlined above, the economies in which we and our customers and counterparties
operate may experience heightened stress and an increased risk of recession, which may increase the risk
of customer defaults and materially adversely affect ING’s business, results, financial condition and
prospects.
Additionally, as of December 31, 2022, a significant portion of our staff continue to work from home on a
full- or part-time basis. If due to illness, technical limitations or other restrictions, employees are unable to
work or are not able to operate as effectively and efficiently remotely as they did in the office, this may
adversely affect our business, results and financial condition.
In addition, a situation in which most or some of our employees continue working from home may raise
operational risks, including with respect to information security, data protection, availability of key systems
and infrastructure integrity. There is also a risk that we will not be effective in implementing regulatory or
strategic change programs in the current environment. The Covid-19 pandemic has led to new banking
behaviour from customers. There has been an increase in the digital behaviour of our customers leading to
reduced traffic in branches. Over 95% of our customers now interact with us via digital channels only. 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.
Interest rate volatility and other interest rate changes may adversely affect our
business, results and financial condition.
Changes in prevailing interest rates may negatively affect our business, including the level of net interest
revenue we earn, and the levels of deposits and the demand for loans. In response to rising inflation
globally, central banks (including the ECB, the US Federal Reserve and the RBA and RBNZ) have begun to
rapidly increase policy rates. This cycle is expected to continue throughout FY2023. This rapid rise in policy
rates may result in:
•a decrease in the demand for loans;
•higher interest rates to be paid on customer deposits and on debt securities that we have issued or may
issue on the financial markets from time to time to finance our operations, which would increase our
interest expenses and reduce our results;
•changes to customer demand, particularly an increase in the attractiveness of certain products, such as
fixed term deposits, which may lead to ING being required to pay higher rates on its liabilities;
•higher interest rates which can lead to lower investments prices and reduce the revaluation reserves,
thereby lowering IFRS equity and the capital ratios. Also the lower securities value leads to a loss of

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ING Bank Annual Report 2022 270
liquidity generating capacity which needs to be compensated by attracting new liquidity generating
capacity which reduces our results;
•prepayment losses if prepayment rates are lower than expected or if interest rates increase too rapidly
to adjust the accompanying hedges; and/or(depending on the position) a significant collateral posting
requirement associated with our interest rate hedge program.
Further, a sustained increase in the inflation rate in our principal markets and related interest rate volatility
may also reduce disposable income for households and may increase household and business financial
stress, and therefore negatively affect our business, results and financial condition. A failure to accurately
anticipate inflation on an ongoing basis and factor it into our product pricing assumptions may result in
mispricing of our products, which could materially and adversely impact our results.
Despite the recent rise in policy rates, in which policy rates in various jurisdictions in which we operate have
risen at a rapid pace as set out above, interest rates are still relatively low by historical standards and have
been low for a prolonged period, which has resulted in, and may (if the expected rate rises do not
materialise) continue to result in:
•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’s”) methodology for determining the ultimate forward rate;
•lower interest rates 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.
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 sometimes 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
reduce 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 in Europe and the United
States, 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, the availability and cost of credit, as well as credit spreads. In addition,
geopolitical issues, including trade tensions between the US and China, increasing protectionism between
key countries, and issues with respect to the Middle East and North Korea may all contribute to adverse
developments in the global capital markets and the economy generally. In addition, Russia’s invasion of
Ukraine 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

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ING Bank Annual Report 2022 271
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 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,
with issuers, including ourselves, that have exposure to the real estate, mortgage, private equity and credit
markets particularly affected. These events, market upheavals and continuing risks, including high levels of
volatility, have had and may continue to 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 to
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 rates benchmarks may negatively affect our business, including the level of net
interest revenue. Financial markets have historically relied on Interbank Offered Rates (‘IBORs’) benchmarks,
such as the London Interbank Offered Rate (‘LIBOR’), the Euro Over Night Index Average (‘EONIA’) and the
Euro Interbank Offered Rate (‘EURIBOR’). While some interest benchmarks have been reformed and will
continue to exist, such as EURIBOR, others such as EONIA, LIBOR and the Warsaw Interbank Offered Rate
(‘WIBOR’) have been or will be replaced by recommended alternative rates. EONIA ceased to be published on
3 January 2022, and is succeeded by €STR. All GBP, JPY, CHF and EUR LIBOR settings ceased on 31 December
2021.
The most used USD LIBOR tenors will continue to be published until 30 June 2023 to support existing
contracts, with the use of USD LIBOR for new contracts only allowed in limited circumstances.
Public authorities have recognised that many contracts do not contain reference to alternative rates, or
reference inappropriate alternatives, or cannot be renegotiated or amended prior to the cessation of the
relevant benchmark. In response the UK government has granted additional powers to the Financial
Conduct Authority (FCA) to enable the temporary publication of a ‘synthetic’ LIBOR using a different
methodology and inputs. The FCA used these powers to ensure GBP and JPY LIBOR continued to be available
using this “synthetic” methodology for a limited time to assist in transition. The FCA has proposed a
requirement for the LIBOR benchmark administrator to publish synthetic 1-, 3- and 6-month USD LIBOR until
30 September 2024 to support those contracts not transitioned by 30 June 2023. This proposal is currently
in consultation. The U.S has also passed legislation to assist in benchmark transition covering most contracts
governed by U.S law that involve USD LIBOR. The legislation has the effect, for those contracts that do not
include suitable “fallback” rate provisions, of amending the contractual terms to switch to the
recommended fallback rate for USD LIBOR (being the Secured Overnight Financing Rate), which is
economically similar to synthetic LIBOR.
Additionally, in 2022 the Polish National Working Group published a roadmap indicating that the market
should be prepared for a cessation of, among others, the WIBOR reference rate in 2025. It is expected that
the reform will be completed by the end of 2024, with the offering of financial products using the new
benchmark (WIRON) to progress gradually in 2023 and 2024.
The discontinuation of USD LIBOR, WIBOR and related interest rate benchmarks could result in a number of
risks for the Group, its customers, and the financial services industry more widely. These risks include legal
risks and costs in relation to changes required to documentation for existing transactions. In addition to the
heightened conduct and operational risks, the process of adopting new reference rates may expose the
Group to an increased level of financial risk, such as potential earnings volatility resulting from contract
modifications and changes in hedge accounting relationships.
It is not possible to determine the full impact of each of the USD LIBOR and WIBOR transitions on the Group.
However, the experience gained, solutions put in place for the other LIBOR rates, and specific project team

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ING Bank Annual Report 2022 272
established to manage the transition of WIBOR, together with our investment in and ability to offer a wide
range of products using the alternative rates of each of USD LIBOR and WIBOR, should help to limit any
material adverse effect on our business, results and financial condition.
ING continues to monitor market developments and reform plans for other rates to anticipate the impact on
our customers and any related risks.
Inflation and deflation may negatively affect our business, results and financial
condition.
Globally, inflation increased significantly during FY2022. If the increased in inflation are prolonged in our
principal markets, this could have multiple impacts on us and may negatively affect our business, results
and financial condition. For example, a sustained increase in the inflation rate may result in an increase in
market interest rates, which may:
•decrease 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/or
•a decrease in collateral values,
•result in increased withdrawal of certain savings products, particularly those with fixed rates below
market rates,
•require us, 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,
•result in further customer defaults as interest rate rises flow through into payment stress for lower credit
quality customers.
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.
In addition, a failure to accurately anticipate higher inflation and factor it into our product pricing may result
in a systemic mispricing of our products, which would negatively impact our results.
On the other hand, deflation could be experienced in our principal markets adversely affecting our financial
performance. Deflation may erode collateral values and diminish the quality of loans and cause a decrease
in borrowing levels, which would negatively affect our business and results.
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, with 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.
We may incur losses due to failures of banks falling under the scope of state
compensation schemes.
While prudential regulation is intended to minimize 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 DGS-fund is to grow to a target size of 0.8% of all deposits guaranteed
under the DGS, which is expected to be reached in July 2024. 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 pay to 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, 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 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’), (partly) replacing or complementing national compensation schemes in two or three phases.
Proposals contain elements of (re)insurance, mutual lending and mutualisation of funds. The new model is
intended to be ‘overall cost-neutral’.

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ING Bank Annual Report 2022 273
In February 2021, the European Commission issued a public consultation on the review of the bank crisis
management and deposit insurance (CMDI) framework, with a focus on three EU legislative texts: the Bank
Recovery and Resolution Directive (BRRD), the Single Resolution Mechanism Regulation (SRMR), and the
Deposit Guarantee Schemes Directive (DGSD). The anticipated 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. The
consultation period ran until May 2021. It is uncertain when the next steps towards revision of the CMDI
framework, including EDIS, can be expected.
Risks related to the regulation and supervision of the Group
Non-compliance with applicable laws and/or regulations, including with respect to
financial economic crimes, could result in fines and other liabilities, penalties or
consequences for us, which could materially affect our business and reduce our
profitability.
ING has faced, and in the future may continue to face, the risk of consequences in connection with non-
compliance with applicable laws and regulations. For additional information on legal proceedings, see Note
42 ‘Legal proceedings’ to the consolidated financial statements. There are a number of risks in areas where
applicable regulations may be unclear, subject to multiple interpretations or under development, or where
regulations may conflict with one another, or where regulators revise their previous guidance or courts
overturn previous rulings, which could result in our failure to meet applicable standards. Regulators and
other authorities have the power to bring administrative or judicial proceedings against us, which could
result, among other things, in suspension or revocation of our licenses, cease and desist orders, fines, civil
penalties, criminal penalties or other disciplinary action, which could materially harm our results and
financial condition as well as ING's reputation. If we fail to address, or appear to fail to address, any of these
matters appropriately, our reputation could be harmed and we could be subject to additional legal risk,
which could, in turn, 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 the commission of financial economic crimes, including with respect to sanctions
and 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 discussion of 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 activities.
We are subject to detailed banking laws and financial regulation in the jurisdictions in which we conduct
business. Regulation of the industries in which we operate is becoming more extensive and complex, while
also attracting supervisory scrutiny. Compliance with applicable and new laws and regulations is resources-
intensive, and may materially increase our operating costs. Moreover, these regulations intended to protect
our customers, markets and society as a whole and can limit 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 will continue to be impacted by
requirements relating to capital, additional loss-absorbing capacity, leverage, minimum liquidity and long-
term funding levels, requirements related to resolution and recovery planning, derivatives clearing and
margin rules and levels of regulatory oversight, as well as limitations 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 where we
operate with less developed or predictable legal and regulatory frameworks.
In certain countries in which we operate, judiciary and dispute resolution systems may be less effective. As
a result, in case of a breach of contract, we may have difficulties in making and enforcing claims against
contractual counterparties and, if claims are made against us, we might 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.
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, and other counterparties located in Russia. 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.

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ING Bank Annual Report 2022 274
We are subject to the regulatory supervision of the ECB and other regulators with
extensive supervisory and investigatory powers.
In its capacity as 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 to impose monetary and other sanctions. For example, under the
Single Supervisory Mechanism (SSM), the regulators with jurisdiction over the Group, including the ECB, may
conduct stress tests and have discretion to impose capital surcharges on financial institutions for risks that
are 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 supervisory actions, minimum capital requirements (including
buffer requirements) or with liquidity requirements, or if there are shortcomings in its governance and risk
management processes. A failure to comply with prudential or conduct regulations could 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 of the off-exchange derivatives market 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 pursuant to Dodd-
Frank and SEC regulations enacted thereunder with respect to security-based swaps and that became
required on 1 November 2021. 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 capital and margin security-based swap dealer rules instead of the CFTC capital and
margin security-based swap dealer rules which could be more capital intensive. Registration 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.
In March 2023, ING Capital Markets LLC determined that errors in its calculation of its regulatory capital
resulted in ING Capital Markets LLC holding less than the minimum capital required under CFTC rules during
prior periods and self-reported the issue to the CFTC and SEC. This issue could lead to regulatory
investigations, enforcement actions and sanctions by the CFTC and/or SEC.
On 15 December 2021, the SEC proposed new rules that would for the first time impose public reporting
requirements for some significant security-based swaps positions. The rules would apply even to trades
between non-US counterparties, including ING Bank, provided that the issuer of the reference securities
underlying the security-based swaps is organised in the US, the issuer of the reference securities underlying
the security-based swaps has its principal place of business in the US, or the securities are in certain
categories registered with the SEC.
These proposed regulations, if adopted in their current form, could constrain trading activity in security-
based swaps. In addition, there are, or may be in the future, regulatory requirements or limitations related
to other categories of equity derivatives, such as options or forwards, that could similarly constrain trading
activity in such instruments as well. These various requirements and limitations with respect to equity

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ING Bank Annual Report 2022 275
derivatives generally could have a significant impact on the liquidity and utility of these markets, materially
impacting ING’s business in this market.
In addition, position limit requirements under Dodd-Frank applicable to the derivatives market generally for
futures contracts based on any of 25 commodity futures contracts on physical commodities have been
imposed by the CFTC. On 1 January 2023, these position limits were extended to certain positions in swaps
that are “economically equivalent” to the enumerated futures contracts. The position limits on futures and
related swaps could limit ING’s position sizes in these futures contracts and similarly limit the ability of
counterparties to utilise certain of our products to the extent hedging exemptions from the position limits
are unavailable. In addition, position limits on swaps on the same physical commodities will become
effective in January 2023, which could further limit the ability of ING and its counterparties to enter into
such swaps. Such regulation of the derivative markets and market participants will likely result in increased
cost of hedging and other trading activities, both for ING and its customers, which could expose our business
to greater risk and reduce the size and profitability of our customer business. The imposition of these
regulatory restrictions and requirements, could also result in reduced market liquidity, which could in turn
increase market volatility and the risks and costs of hedging and other trading activities.
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 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),
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
“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" 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 rate-setting processes, notifications made by whistleblowers, increasing regulatory
and law enforcement scrutiny of ‘know your customer’ anti-money laundering, 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, 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, beginning in February 2022, the EU, UK and the US,
in a coordinated effort joined by several other countries, imposed a variety of new sanctions with respect to
Russia and various Russia-related parties. Despite significant similarities between these Russia-related
sanctions programmes, there are notable differences between the EU, UK and US sanctions programmes,
which have evolved and may continue to evolve and have required ING to implement new control measures
with related costs and risks of non-compliance. 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

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ING Bank Annual Report 2022 276
regulatory investigations and sanctions may have a material adverse effect on our business, results,
financial condition and/or prospects in any given period.
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
with or 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. On 7 June 2021, the Dutch
government received a formal notice of termination of the Dutch-Russian tax treaty from Russia, and as a
result, the tax treaty was terminated as of 1 January 2022. The termination of the Dutch-Russian tax treaty
or any other similar developments may have adverse effects on ING and ING’s customers.
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 recognized. 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.
We may be subject to US tax investigation if we fail to comply with our obligations as a
Participating Financial Institution in respect of the Foreign Account Tax Compliance Act
(“FATCA”) and as a Qualified Intermediary in respect of other US tax regulations
Due to the nature of its business, ING is subject to various provisions of US tax law. These include FATCA,
which requires ING to provide certain information for the US Internal Revenue Service (IRS), and the Qualified
Intermediary (QI) requirements, which require withholding tax on certain US-source payments. Failure to
comply with FATCA and/or QI 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, ING engages 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 may make 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, has 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 internal or external aims or expectations with respect to
ESG-related matters.
Environmental, Social and Governance (ESG) is an area of significant and increased 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 climate change, sustainability and other ESG-related matters,
including in relation to the financial sector’s operations and strategy. Such recent regulations include the EU
Sustainable Finance Disclosure Regulation (SFDR), EU Taxonomy regulation and EU Green Bond Standards,

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ING Bank Annual Report 2022 277
which broadly focus on disclosure obligations, standardized definitions and classification frameworks for
environmentally sustainable activities. These laws, regulations and legislative frameworks may directly and
indirectly impact the business environment in which ING operates and may expose ING to significant risks;
amongst others greenwashing risk.
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 from time to time
disclose ESG-related initiatives or aims in connection with the conduct of its business and operations.
However, there is no guarantee that ING will be able to implement such initiatives or meet such aims within
anticipated timeframes, or at all. ING may fail to fulfil internal or external ESG-related initiatives, aims or
expectations, or may be perceived to fail to do so, or may fail to adequately or accurately report
performance or developments with respect to such initiatives, aims or expectations. ING could therefore be
criticised or held responsible for the scope of its initiatives or goals regarding such matters. In addition, ING
might face requests for specific strategies, plans or commitments to address ESG-related matters, which
may or may not be viewed as satisfactory to the relevant internal and external stakeholders (including
NGOs). 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. 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 physical risks, including as a direct result
of climate change.
ING’s business and operations may be 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 the environmental
degradation, including loss of biodiversity, water or resources scarcity, pollution or waste management.
Such physical risks could 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 Western Europe in July 2021, the long-lasting bushfires in Australia in February
2021 or the severe flooding in the eastern states of Australia in early 2022, could lead to unexpected
business interruptions or losses for ING or its customers.
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 systems 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’s business and operations are exposed to transition risks related to climate change.
The transition to a low carbon or net zero economy may give 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. As a result, it might be unable to lend to certain prospective customers,
or might even lead to the termination of certain existing relationships with certain customers. This could
result in claims or legal challenges from such customers against ING. This transition may also adversely
impact the business and operations of ING’s customers and other counterparties. 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 implementation of 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 or susceptible to incorrect customer, third party or other data.
Any delay or failure in developing, implementing or meeting ING’s climate change-related commitments
and regulatory requirements may have a material adverse impact on our business, financial condition,

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ING Bank Annual Report 2022 278
operating results and reputation, and lead to climate change or ESG-related investigations, enforcement
proceedings or litigation.
Operational and IT risks, such as systems 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.
We face the risk that the design and operating effectiveness of our controls and procedures may prove to
be inadequate. Operational and IT risks are inherent to our business. Our businesses depend on the 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 by email and other electronic
means. Losses can result from inadequately trained or skilled personnel, IT failures (including due to a
computer virus or a failure to anticipate or prevent cyber attacks or other attempts to gain unauthorised
access to digital systems for purposes of misappropriating assets or sensitive information, corrupting data,
or impairing operational performance, or security breaches by third parties), 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. 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
computer 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’). 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 or accurately process,
store and transmit information, and may adversely impact 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.
Widespread outbreaks of communicable diseases 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, either or both of which could adversely impact our business. In addition, other events including
unforeseeable and/or catastrophic events can lead to an abrupt interruption of activities, and our operations
may be subject to losses resulting from such disruptions. 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 not able to be implemented, are not effective 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 is
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 techniques
used for such attacks are increasingly sophisticated. 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.
Cybersecurity, customer data and data privacy have become the subject of increasing legislative and
regulatory focus. The EU’s second Payment Services Directive (PSD2) and GDPR are examples of such
regulations. In certain locations where ING is active, there are additional local regulatory requirements and
legislation on top of EU regulations that must be followed for business conducted in that jurisdiction. Some
of these legislations and regulations may be conflicting due to local regulatory interpretations. We may
become subject to new EU and local 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 new and existing
legislation 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, computer viruses or other
malicious code, cyber attacks and other external attacks or internal breaches that 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.

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ING Bank Annual Report 2022 279
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 a number of 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 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. New entrants may rely on new
technologies, advanced data and analytic tools, lower cost to serve, reduced regulatory burden 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 monetize our internal innovations
and restrict our ability to capitalize 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 monetization of our internal
innovations.
We may also be subject to claims made by third parties for (1) patent, trademark or copyright infringement,
(2) breach of copyright, trademark or licence usage rights, or (3) misappropriation of trade secrets. Any such
claims and any resulting litigation could result in significant expense and liability for damages. If we were
found to have infringed or misappropriated a third-party patent or other intellectual property right, we
could in some circumstances be enjoined from providing certain products or services to our customers or
from utilizing 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 an 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, continuing low 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

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ING Bank Annual Report 2022 280
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 recent 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 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 Russian rouble (RUB). Remaining at risk for ING at year-end 2022 is €0.3 billion local equity and €2.5
billion credit exposures booked outside of Russia, and €0.5 billion 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. 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,
or impairments to the carrying value of, 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. 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. Also in this case, our credit risk may also be exacerbated
when the collateral we hold cannot be liquidated at prices sufficient to recover the full amount of the loan or
derivative exposure due to us, which is most likely to occur during periods of illiquidity and depressed asset
valuations, such as those experienced during the financial crisis of 2008. The termination of contracts and
the foreclosure on collateral may subject us to claims. Bankruptcies, downgrades and disputes with
counterparties as to the valuation of collateral tend to increase in times of market stress and illiquidity. Any
of these developments or losses could materially and adversely affect our business, results, financial
condition, and/or prospects.
Ratings are important to our business for a number of reasons, and a downgrade or a
potential downgrade in our credit ratings could have an adverse impact on our results
and net results.
Credit ratings represent the opinions of rating agencies regarding an entity’s ability to repay its
indebtedness. Our credit ratings are important to our ability to raise capital and funding through the
issuance of debt and to the cost of such financing. In the event of a downgrade, the cost of issuing debt will
increase, having an adverse effect on our net results. Certain institutional investors may also be obliged to
withdraw their deposits from ING following a downgrade, which could have an adverse effect on our
liquidity. They can also have lower risk appetite for our debt notes, leading to lower purchases of (newly
issued) debt notes. We have credit ratings from S&P, Moody’s Investor Service and Fitch Ratings. 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.

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> Risk factors
ING Bank Annual Report 2022 281
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 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’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 operates,
and globally for senior management, is intense. ING’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 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’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.
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 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 or assumptions to model client
behaviour for the purposes of our market calculations may adversely impact our
reputation or results.
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 reputation and results. In addition, we use assumptions in to model client behaviour for the 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 the mortgage and investment portfolios.
Assumptions based on past client behaviour may not always be a reliable indicator of future behaviour. The
realisation or 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 the laws and regulations governing the risk management practices
of financial institutions. For further 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 operates is becoming increasingly more extensive
and complex, while also attracting supervisory scrutiny. Compliance failures may lead to changes in the
laws and regulations governing the risk management practices and materially increase our operating costs.
We may be unable to manage our risks successfully through derivatives.
We employ various economic hedging strategies with the objective of mitigating the market risks that are
inherent in our business and operations. These risks include currency fluctuations, changes in the fair value
of our investments, the impact of interest rates, equity markets and credit spread changes, the occurrence
of credit defaults and changes in client behaviour. We seek to control these risks by, among other things,
entering into a number of derivative instruments, such as swaps, 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.

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ING Bank Annual Report 2022 282
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 (whether due to the ongoing euro crisis or otherwise), 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
impact our liquidity, borrowing and capital positions, as well as the cost of liquidity,
borrowings and capital.
Adverse capital market conditions have in the past affected, and may in the future affect, 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. Furthermore, although interest rates are still relatively low by
historical standards and have been since the financial crisis in 2008, interest rates are rising and we have
experienced, and may continue to experience, increased funding costs due in part due to the withdrawal of
perceived government support of financial institutions in the event of future financial crises. In addition,
liquidity in the financial markets has also been negatively impacted as market participants and market
practices and structures adjust to new regulations.
We need liquidity to fund new and recurring business, to pay our operating expenses, interest on our debt
and dividends on our capital stock, maintain our securities lending activities and replace certain 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
fund, repurchase agreements, commercial paper, medium- and long-term debt, subordinated debt
securities, capital securities and shareholders’ equity.
In addition, because 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 our 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 confidence could have an adverse effect on our liquidity
and capital position through withdrawal of deposits, in addition to our revenues and results. Because 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 needs, 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 ratings 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. Also see 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 funds 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, or to counterbalance the consequences of losses or increased regulatory capital and rating agency
capital requirements. This could force us to (1) delay raising capital, (2) reduce, cancel or postpone payment
of dividends on our shares, (3) 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

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ING Bank Annual Report 2022 283
profitability and our financial flexibility. Our results, financial condition, cash flows, regulatory capital and
rating agency capital position could be materially adversely affected by disruptions in the financial markets.
Furthermore, regulatory liquidity requirements in certain jurisdictions in which we operate are remain
stringent, undermining our efforts to maintain centralised management of our liquidity. These
developments may cause trapped pools of liquidity and capital, resulting in inefficiencies in the cost of
managing our liquidity and solvency, and hinder our efforts to integrate our balance sheet. An example of
such trapped liquidity includes our operations in Germany where German regulations impose separate
liquidity requirements that restrict ING’s ability to move a liquidity surplus out of the German subsidiary.

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ING Bank Annual Report 2022 284
Disclaimer
Certain of the statements contained herein are not historical facts, including, without limitation, certain
statements made of future expectations and other forward-looking statements that are based on
management’s current views and assumptions and involve known and unknown risks and uncertainties that
could cause actual results, performance or events to differ materially from those expressed or implied in
such statements. Actual results, performance or events may differ materially from those in such statements
due to a number of factors, including, without limitation: (1) changes in general economic conditions, in
particular economic conditions in ING’s core markets, including changes affecting currency exchange rates
and the regional and global economic impact of the invasion of Russia into Ukraine and related international
response measures (2) ongoing and residual effects of the Covid-19 pandemic and related response
measures on economic conditions in countries in which ING operates (3) changes affecting interest rate
levels (4) any default of a major market participant and related market disruption (5) changes in
performance of financial markets, including in Europe and developing markets (6) fiscal uncertainty in
Europe and the United States (7) discontinuation of or changes in ‘benchmark’ indices (8) inflation and
deflation in our principal markets (9) changes in conditions in the credit and capital markets generally,
including changes in borrower and counterparty creditworthiness (10) failures of banks falling under the
scope of state compensation schemes (11) 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 (12) geopolitical risks, political instabilities and policies and actions of governmental
and regulatory authorities, including in connection with the invasion of Russia into Ukraine and related
international response measures (13) legal and regulatory risks in certain countries with less developed legal
and regulatory frameworks (14) prudential supervision and regulations, including in relation to stress tests
and regulatory restrictions on dividends and distributions (also among members of the group) (15) ING’s
ability to meet minimum capital and other prudential regulatory requirements (16) changes in regulation of
US commodities and derivatives businesses of ING and its customers (17) application of bank recovery and
resolution regimes, including write-down and conversion powers in relation to our securities (18) 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 (19)
changes in tax laws and regulations and risks of non-compliance or investigation in connection with tax
laws, including FATCA (20) 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 (21) risks and challenges related to cybercrime including
the effects of cyberattacks and changes in legislation and regulation related to cybersecurity and data
privacy (22) changes in general competitive factors, including ability to increase or maintain market share
(23) inability to protect our intellectual property and infringement claims by third parties (24) inability of
counterparties to meet financial obligations or ability to enforce rights against such counterparties (25)
changes in credit ratings (26) business, operational, regulatory, reputation and other risks and challenges in
connection with climate change and ESG related matters (27) inability to attract and retain key personnel
(28) future liabilities under defined benefit retirement plans (29) failure to manage business risks, including
in connection with use of models, use of derivatives, or maintaining appropriate policies and guidelines (30)
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 (31) the other risks and uncertainties
detailed in the most recent annual report of ING Bank N.V. (including the Risk Factors contained therein) and
ING’s more recent disclosures, including press releases, which are available on www.ING.com. 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.
T his document is the PDF version of the 2022 Annual Repor t of ING made available on ing.com. Another
version of this document has been prepared in the European single electronic reporting format (ESEF) and
such ESEF reporting package is also available on ing.com. In the event of any discrepancies between this PDF
version and the ESEF reporting package, the ESEF reporting package governs.
Any forward looking statements made by or on behalf of ING speak only as of the date they are made, and
ING assumes no obligation to publicly update or revise any forward-looking statements, whether as a result
of new information or for any other reason.
This document does not constitute an offer to sell, or a solicitation of an offer to purchase, any securities in
the United States or any other jurisdiction.

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> Disclaimer
ING Bank Annual Report 2022 285