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ING Bank
Annual Report 2024
ING Bank Annual Report 2024 2

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

Contents

About this report | 3

Strategy 4

Our strategy | 5
Superior customer v alue | 6
Putting s ustainability at the heart | 9
How we are growing the difference | 11
Our operating environment | 15

Our financial performance 16

Our financial performance | 17
Retail Banking | 19
Wholesale Banking | 22

Our leadership and
corporate governance 24

Our leadership and governance | 25
Supervisory Board report | 28
Corporate governance | 37
Conformity Statement | 39

Capital Management 40

Capital Management | 41

Risk Management 43

Risk management | 44
Solvency risk | 52
Credit risk | 54
Market risk | 81
Funding and liquidity risk | 92
Environmental, social and governance risk | 94
Non-financial risk | 99
Compliance risk | 101
Model risk | 105
Business risk | 105

Consolidated financial statements 106

Consolidated statement of financial position | 108
Consolidated statement of profit or loss | 109
Consolidated statement of comprehensive income | 110
Consolidated statement of changes in equity | 111
Consolidated statement of cash flows | 114
Notes to the consolidated financial statements | 117

Parent company financial statements 208

Parent company statement of financial position | 209
Parent company statement of profit or loss | 210
Parent company statement of changes in equity | 211
Notes to the parent company financial statements | 212
Authorisation of Parent company financial statements | 230

Other information and appendices 231

Independent auditor's report | 232
Appendix - Alternative performance measures | 241
Articles of Association – Appropriation of results | 242
Risk factors | 243
Disclaimer | 259

ING Bank Annual Report 2024 3

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

About this report
ING’s purpose is empowering people to stay a step ahead in life and in
business. In this integrated report we disclose our results, strategy and
management approach in the context of external developments, as well
as emerging and existing impacts, risks and opportunities.
This integrated report is intended to inform stakeholder groups that have an impact on, or are affected by,
our business. This includes our employees, customers, investors, planet and society (e.g. non-governmental
organisations and supervisors) and suppliers & partners.
It covers the period beginning 1 January to 31 December 2024. We published our previous annual report on
7 March 2024, which covered the year 2023. This report covers the year 2024, and was published on 6 March
2025. This integrated report consists of:
• Report of the Management Board, which includes the section ‘Strategy’, 'Our financial performance', ‘Our
leadership and corporate governance’, 'Capital management' and ‘Risk management';
• Consolidated financial statements;
• Parent company financial statements; and
• Other information and appendices.
The consolidated financial statements included in this report have been prepared in accordance with
International Financial Reporting Standards (IFRS) and the relevant articles of Part 9 of Book 2 of the Dutch
Civil Code. The 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. Reasonable assurance for the
consolidated financial statements and the company financial statements is provided by KPMG Accountants
N.V. (KPMG). See the 'Independent auditor’s report' for further details.
This document is the PDF version of the 2024 Annual Report of ING Bank made available on ing.com. Another
version of this document has been prepared in the European single electronic reporting format (ESEF). This
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 takes precedence.
Strategy
ING Bank Annual Report 2024 5

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

Our strategy
Our strategy is focused on Growing the difference by providing superior
value for our customers and putting sustainability at the heart of what we
do.
This evolved strategy is a result of ING’s entrepreneurial spirit, collaborative attitude and customer focus,
built on the strong foundation we laid with the previous phase of our strategy, called ‘Making the difference’.
These key ingredients make us uniquely ING and ready to grow.
Growing the difference is about building scale and impact in more market segments and the economies we
operate in. We want to become more relevant to our customers, so we’ll invest to expand our services, grow
our customer base and deepen our customer relationships. We also continue to strive to make banking as
easy and frictionless as possible.
Our goal is to accelerate growth, increase impact and deliver value to become the best European bank for all
our stakeholders. This is how we want to be valued by investors and analysts compared to our banking
peers. Our businesses in Asia Pacific and the Americas are instrumental to our strategy.
Growing the difference is translated into business-specific strategies. In Retail, being the best European bank
is to ‘Be First’, becoming the most loved, most impactful and most valued retail bank. For Wholesale Banking,
it’s about continuing to leverage the ING difference, building on our network strength, sector expertise and
sustainability leadership.
Our strategy is guided by our purpose – empowering people to stay a step ahead in life and business. This
represents our belief in people’s potential. However big or small, modest or grand, we empower people and
businesses to realise their own vision for a better future.
Our two overarching priorities are providing superior value for customers and aiming to put sustainability at
the heart of what we do. These priorities are supported by our four ‘enablers’.
Providing superior value for customers
Banking is a relationship just like any other, and the best relationships are those in which people feel valued,
confident, empowered and in control. That’s how we want customers to feel at every step with us. Growing
the difference means focusing more specifically on growing customer value, moving from more one-size-
fits-all services to a more tailored approach for different customer segments. In Retail Banking, that means
giving our customers the right services, at the right time, in the right way. In Wholesale Banking, we aim to
provide ever more value to our clients by growing as their strategic partner and core bank.
Putting sustainability at the heart of what we do
We have a role in 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 life on our planet, including its
people, many of whom also struggle with inequality, poor financial health and a lack of basic human rights.
ING wants to build a sustainable future for our company, our customers, society and the environment. We
aim to lead by example by striving for net zero in our own operations. And we play our part in the low-
carbon transformation that’s necessary to achieve a sustainable future, aiming to steer financing towards
meeting global climate goals and working with clients to achieve their own sustainability goals.
Four enabling priorities
Providing seamless digital services
We can serve our customers better if we use ‘always-on’ channels, providing data-enabled personalised
experiences and end-to-end digital processes, with human intervention only where needed or desired.
Using scalable technology and operations
A technology and operations foundation that is modular and scalable brings many benefits, including
superior customer experience and safety.
Staying safe and secure
Trust is 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 to attract, develop and retain the right fit-for-future talents and skills. We believe our people can
thrive in a diverse, inclusive environment, where a superior employee experience can help unlock their time
and energy to grow the difference.
ING Bank Annual Report 2024 6

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

Superior customer value
Providing superior value for customers is one of our two overarching
priorities. For Retail Banking, delivering superior customer value means
making banking simple and expertise accessible, offering the right
products, at the right time, in the right way. For Wholesale Banking,
delivering superior customer value means building on our network
strength, sector expertise and sustainability leadership.
Retail Banking
In Retail Banking, we service customers across three pillars: Private Individuals, Business Banking and Private
Banking. Equipped with leading digital capabilities, we aim to provide a digital-first, frictionless and relevant
banking experience, shaped to specific client needs for all of these pillars.
Private Individuals
ING offers retail banking products and services to cover the needs of individual retail banking customers. We
serve nearly 40 million customers in 10 countries: the Netherlands, Belgium, Luxembourg, Germany, Spain,
Italy, Türkiye, Poland, Romania and Australia.
Growing the difference means focusing more specifically on growing customer value. As part of our strategy,
we aim to expand our offering with a more tailored approach and develop relevant propositions for our
customers. Priority areas include making ourselves the bank of choice for Gen Z and affluent customers,
growing our subscription business through products and services that provide superior value for customers,
diversifying our Private Individuals lending portfolio, and partnering to create full-service retrofitting offers to
support homeowners in making their homes more sustainable.
ING aims to build 'primary relationships' with customers, earning their loyalty to the extent that they
consider us as the first bank for their financial business. In Retail Banking, we define a primary relationship as
one where customers hold an active payment account with recurrent income and at least one other active
product with us.
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. In 2024, the number of primary customers increased by 0.8 million to 16.2 million.
Through our products and services, we aim to provide a seamless digital, mobile-led experience. We want to
engage with our customers on mobile at every stage of their journey and give them personalised products
and services based on relevant, data-driven insights. Mobile adoption is growing and customers are
expecting more from digital services. In 2024, over 84 percent of customers used mobile as their preferred
channel (mobile device login through the app or website), compared to 79 percent in 2023. High adoption of
mobile banking is especially visible in Türkiye (93 percent), Romania (92 percent) and the Netherlands (91
percent).
This has resulted in more mobile primary customers, who are primary customers with at least one mobile
interaction through our app or mobile website per quarter. In 2024, in line with our mobile-first ambition, we
grew our mobile primary customer base by 1.1 million to 14.4 million. Particularly strong growth was
achieved in Germany (+314,000), the Netherlands (+174,000) and Spain (+152,000). Mobile primary
customers now represent 89 percent of our 16.2 million primary customers.
Our customers logg ed in more than eight billion times to our digital platforms in 2024, up by 6 percent
versus 2023, with m obile representing 96 percent of total interactions. This increasing engagement offers us
the opportunity to further increase the relevance and value we provide to our customers.
Business Banking
Business Banking serves customers in eight markets: the Netherlands, Belgium, Luxembourg, Poland, Romania,
Türkiye, Germany and most recently Australia where we began offering Business Banking services in 2024.
Our ambition is to be the first choice for customers to manage and grow their businesses, contributing to
their financial health and sustainable future through relevant, seamless, trusted and tailored financial
solutions and expertise in key moments.
Our needs-based customer segmentation approach differentiates between basic and more complex and/or
specific needs. We offer our customers solutions through a range of service models, from ‘self-service’
through our digital platform to remote and face-to-face advice, with the emphasis on deepening client
relationships and offering deep sector knowledge and advice.
As with all our segments, we aim to deliver superior customer value in Business Banking. For example, we
offer digital onboarding and instant lending in five of our markets (the Netherlands, Belgium, Poland,
Romania, Türkiye) for certain customer groups. The Netherlands, Belgium and Poland have an e-commerce
offer to support online sales of our customers.
ING Bank Annual Report 2024 7

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

> Superior customer value
Private Banking
Private Banking offers banking services and personalised wealth management to affluent and (ultra) high-
net-worth individuals and their entities in the Netherlands, Belgium and Luxembourg. This is offered through
digital channels, supplemented by dedicated relationship managers and the support of product specialists.
Private Banking aims to give customers access to a diverse range of products and services suited to their
specific needs.
We aim to lead the way to redefine private banking by leveraging digital engagement and data to be able to
scale wealth management. In doing so, we endeavour to drive a step-change in delivering customer value,
with interactive, digital and enabling tools.
In Private Banking, we see ourselves as the bank of choice for entrepreneurs looking to grow their wealth.
Our ambition is to become the leader in business-originated wealth by providing a one-stop solution with a
segmented approach, leveraging our strong position in Business Banking.

| Customer Experience (CX) day As part of ING’s focus on continuous improvement of the customer journey, ING this year held its fifth global CX day where more than 6,800 colleagues from across the bank, alongside customers, put their collective minds together to come up with tangible ideas to delight our customers. The event attracted employees from Retail Banking, Wholesale Banking and support functions all around the world. They identified more than 270 improvements, some of which were created and tested on the day. |

Wholesale Banking
Growing the difference for our customers means we strive to be the best - and in this case, the best
European wholesale bank. We define ‘best’ by having a high net promoter score (NPS) (in the industry top
quartile), aim to lead in sustainability, in our digital service offering and as an employer, and achieving
sustainable returns. Our work begins in providing corporate clients and financial institutions with the
financial solutions they need across their value chains. Underpinning this is the ‘ING difference’, three major
characteristics that offer value to clients:
1. Our global reach, with local experts: no matter where clients are, our network of experts offers 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 don’t just aim to be leaders in sustainable finance; we work hand-in-
hand with clients to address some of the most pressing issues in the world today.
ING’s Wholesale Banking network serves clients around the world and operates from 36 countries across
three regions: EMEA, APAC and the Americas. Our global reach is reflected in the fact that 58 percent of our
income is cross-border. Clients benefit from our deep sector knowledge of eight sectors and 29 sub-sectors,
including: commodities, food and agriculture; corporate sector coverage; energy; financial institutions;
infrastructure and real estate; sustainable value chains; technology, media, telecom and healthcare; and
transport and logistics. Together with our target sector research capabilities and our client segmentation
model, we aim to help clients navigate the highs and lows of economic cycles, providing them with relevant
advice, data-driven insights and customised, integrated solutions that support their business ambitions.
As a large wholesale bank, with billions of euros flowing through our balance sheet, ING aims to play an
important role in accelerating our clients’ transitions to net zero by 2050. In addition to the financial support
and incentives we provide, we help and advise clients by putting our climate-action experience and other
sustainability-related insights to work for them.
Given the significant level of sustainable finance needed for the energy transition, banks have an
opportunity and an imperative to increase the available level of finance. This is why in 2024 we set a new
sustainable volume mobilised target of €150 billion per annum by 2027, up from our previous target of €125
billion by 2025.
In 2024, our Wholesale Banking team was recognised by Global Finance as Best Bank for Cash Management
and Best Bank for Sustainable Project Finance in Western Europe, and Best Bank for Sustainable Finance in
the Netherlands. The Digital Banker recognised ING as the Best Wholesale/Transaction Bank for Sustainable
Finance in South-East Asia and the Netherlands, and ING ranked as CEE's Best Bank for Sustainable Finance
according to Euromoney.
How we aim to become the best European wholesale bank
We've identified other ‘must-wins’ for us to become the best European wholesale bank. For our sustainable
returns ambition, we are scaling our product foundations to increase our fee income, particularly in
Transaction Services, Financial Markets and Capital Markets & Advisory (CMA). Regarding our lending income,
we're improving our capital efficiency and digitalising our deal execution processes. And as part of our
Transaction Services, we aim to continue growing our volumes and deposits, as well as diversifying our
product mix and growing trade finance. The emphasis in our Financial Markets platforms is to harmonise our
product suite and increase our green and regular product offerings. Finally, as part of our CMA work, we're
benefiting from a greater loan distribution and a broader capital markets product mix, and have been
building our capabilities to have more CMA teams closer to our clients.
To improve our digital delivery, we are standardising our lending capabilities through digitalisation and have
brought together all our payment capabilities under one platform. Pilot projects have also begun to
ING Bank Annual Report 2024 8

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

> Superior customer value
investigate how generative artificial intelligence (GenAI) can support credit pack reviews and make our know
your customer (KYC) and customer due diligence (CDD) processes more efficient.
Not only have we been able to absorb volume growth and navigate regulatory changes in 2024, we've also
made progress on our capital management activities. We’ve continued to optimise our portfolio, drawing on
our three ‘ING difference’ characteristics to help us assess where our capital can generate the highest
returns. And by improving our models and the tools we use to distribute capital, we're in a stronger position
to continue increasing our income over risk-weighted assets.

| Our NPS performance One of the ways we measure our ability to deliver superior customer value is through the net promoter score (NPS). The NPS indicates whether customers would recommend ING to others. We compare our NPS to selected peers in each market. Our ambition is to achieve a number one NPS ranking in all our Retail markets. In 2024, ING ranked number one in five of our Retail markets: Australia, Poland, Germany, Romania and Spain. ING ranks in the top three in another two markets: Italy (ranked second) and the Netherlands (ranked third). We ran an NPS programme in 32 Wholesale Banking (WB) markets throughout 2024, to ensure a broad coverage of our client base, and achieved a 76 percent response rate. ING's WB NPS score rose to 74 (on a scale of -100 to +100), compared to a score of 72 in 2023. The insights from the survey showed how our sector expertise, global reach and local experts are highly appreciated by clients and important reasons for why they chose ING. We also asked clients how satisfied they were with our product areas, people, processes and digital offering, with the highest scores going to our product offering, relationship management and client support. Off the back of these results, we will continue to prioritise building strong relationships with excellent execution, simplifying and automating our KYC processes and optimising our digital offering. |

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Sustainability at the heart
Sustainability is one of the biggest challenges for society. ING aims to
play a leading role in accelerating the transition to a low-carbon
economy. We want to build a sustainable future for our company, our
customers, society and the environment. That’s why we’re striving to
put sustainability at the heart of what we do: it is a pillar of our strategy
and central to our long-term success.
The urgency of climate change and biodiversity loss is becoming more evident all the time. Sustainability, in
all its forms, is under threat, endangering the welfare of the planet and its people. The challenges do not
only come from extreme weather events and rising ocean temperatures, but also as people struggle with
inequality, poor financial health and even a lack of basic human rights.
As such, the need to build a more sustainable, climate-resilient future is a mission facing us all. As the
challenges increase, there’s a growing sense of urgency that governments and businesses should step in
and help tackle them.
As a systemically important financial institution, we can contribute to the transition of society. We aim to do
this by playing a leading role in financing the changes needed in the transition to a low-carbon economy.
We focus on this because it matters to us as a bank, to our clients and to society.
We do this by bringing aspects of climate change, nature and respecting human rights into our dialogue with
clients and financing decisions. We engage with clients to help them transition their businesses in line with net-zero
goals and halt nature loss in their operations, and take a risk-and-rights-based approach to human rights that
supports a just transition. We aim to be a frontrunner in financing the future economy and we want to find ways to
empower people to prepare for the future, with financial health and inclusion a focus of our social approach.
Putting sustainability at the heart of what we do also means embedding sustainability into our decision-making
processes, our risk-management frameworks, our own operations and our company culture. We strive to lead by
example by aiming for net zero in our own operations well before 2050, and we’re working to improve
sustainability in our supply chain. We manage our material sustainability risks and are building up an effective
sustainability culture through education, upskilling and other employee-engagement initiatives.
A successful transition demands systems-level solutions. Together with our partners, we advocate for the
changes that need to happen and we want to collaborate with all those who have a role to play in
contributing to solutions and accelerating progress. We also aim to take a leading role in driving collective
efforts to set sustainability standards for the financial sector, working with partners, peers and the industry
on new frameworks for helping to decarbonise and transform the sectors we’re active in.
Focus on climate action
Our climate-action activities are focused on the three areas where we believe we can make the greatest
impact, based on what needs to happen in the transition: helping to drive down emissions to meet the global
goal of net zero by 2050; building up the financing of the new technologies and sustainable systems of the
future; and finding ways to enable people to play their part in the transition.
Driving down emissions: supporting businesses in their transition to net
zero
As a bank, the most significant contribution we can make to help drive down global emissions is to engage
with our clients and steer our portfolios for net-zero alignment. In our recent Climate Progress Update, we
shared how we have developed our engagement with clients to accelerate their plans for transition – and
how we intend to strengthen that engagement in the future. Our analysis of clients’ climate disclosures and
transition planning guides our decision-making and informs discussions with clients about their transition
strategy and how ING can support them. We also have in place our 'Terra' approach, through which we steer
our portfolios in high-emitting sectors towards net-zero alignment by 2050.
While our main impact is in our financing and working with our clients, we also strive to lead by example by
having an environmental programme in place that works towards net zero in our own operations. This
means bringing our buildings, data centres and business travel in line with the net-zero economy of the
future. We measure and steer our progress towards this ambition through our environmental programme. In
2024, our total operational footprint (scope 1, 2 and scope 3 business travel) was 27 kilotonnes (kt) of CO 2 e.
This is a reduction of 2 kt of CO 2 e compared to our 2023 CO 2 e emissions.
We consistently apply the same methodology and emission factors to track our progress towards our global
ambition of a 75% emission reduction, compared to our 2014 baseline. In 2025 we will update our baseline
to align with the latest emission factors and methodologies.
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> Sustainability at the heart
Building up a sustainable future: financing technologies and solutions for a
low-carbon world
We have a role to play in mobilising the finance needed to make the low-carbon transition a reality,
including backing the technologies and solutions that will contribute to a low-carbon world. We continue to
evolve and innovate our approach to sustainable financing. This includes how we strive to make connections
and support collaboration, both within particular value chains and across them, with the goal of supporting
the development of the systemic solutions necessary to accelerate the transition.
In 2023 we tripled our target for financing of renewable power generation to €7.5 billion annually by 2025,
up from our earlier €2.5 billion target set in 2022, where financing refers to the amount we commit to our
clients, either as ING or via other parties involved in the transaction.
Including everyone in the transition: finding new ways to enable people to
stay a step ahead on climate
We believe most people want to play a role in the transition and our climate action approach includes
finding ways to enable people to play their part, starting with existing and prospective retail customers. This
includes empowering mortgage customers to make their homes more sustainable and advocating for
change in housing policy.
Progress can only be driven through collaborative action and partnering and advocating for change. We do
this by working together across the industry and sectors, with governments, policymakers and civil society.
We continue to play an active role in the development and adoption of methodologies and frameworks that
support decarbonisation at sector level.
The low-carbon transition cannot happen overnight. Even though we finance a lot of sustainable activities,
we still finance more that’s not, which is a reflection of the global economy. We strongly believe we can
make the most impact by engaging with clients, talking to them about their climate and nature goals, and
helping finance what they need to reach them.
Climate action is a fast-changing, dynamic landscape, and our approach needs to evolve to keep pace. For
instance, in our approach to take climate action we take the links and interdependencies into account
between climate-change mitigation, climate adaptation, nature and biodiversity, human rights and just
transition.
ING Bank Annual Report 2024 11

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How we are growing the difference
We focus and continue to work on our four key enablers that will help us
grow the difference: providing seamless digital services, using scalable
technology and operations, staying safe and secure, and unlocking our
people’s full potential.
Providing seamless digital services
Through our ‘Growing the difference’ strategy, we strive to build on our success of making banking easy. One
of the ways we aim to do this is by making banking as frictionless and relevant as possible. We can serve our
customers better if we use ‘always-on’ channels, providing data-enabled personalised experiences and end-
to-end digital processes, with human intervention only where needed or desired. For Private Individuals, for
example, we seek to simplify customer journeys through digitalisation and to lead in using data and GenAI.
In Private Banking and Business Banking, our ambition is to lead the digital way to service our clients. And as
part of our aim to be the best European wholesale bank, we place a strong emphasis on digital leadership.
We use data analytics and machine learning to personalise digital services for customers. Personalising
customer interactions helps them make more informed financial decisions and supports mobile sales, while
also reducing the need to use other channels. In 2024, 77 percent of our communication to retail customers
was personalised. Given the importance of data in offering personal and relevant services, data security and
privacy protection are crucial.
Data analytics
We use advanced analytics and artificial intelligence (AI) as a way to fulfil our strategy. Our ING Analytics
organisation, which delivers analytics and AI products across our markets and domains, is made up of four
specialist areas that reflect the priorities of the bank in the analytics domain (Retail, Wholesale, Operations
and Platforms).
In 2024, we extended our AI capabilities with GenAI. The new technology has the potential to transform
banking and unlock significant value for our colleagues and customers. At the same time, it comes with
challenges and risks, which demand a responsible approach to capture its opportunities.
We currently focus on GenAI projects in five high-value areas: contact centres, hyper personalisation in
marketing, KYC, software engineering and Wholesale Banking lending – with risk, tech, people and
governance being our enablers on this journey. In 2024, as part of the responsible scaling of the new
technology, we worked on the challenges that come with multiple platforms and models in use, and
launched a number of important solutions such as a brand-new GenAI chatbot in our contact centres.
To scale responsibly with GenAI, we identified a need for standardised risk assessments that can be
efficiently and effectively applied across multiple GenAI use cases. In 2024, we executed several pilots
(including customer facing), providing a solid foundation for 2025. A virtual AI Risk Center of Excellence (CoE)
comprising expertise in model risk, non-financial risk and compliance was also established to support AI risk
assessments and ensure consistent application.
We recognise that investing in people and talent is as vital as investing in technology. To this end, in 2024,
we launched a mandatory GenAI e-learning. 92 percent of ING’s global workforce completed this training,
with insights into the opportunities and risks of the new technology. Also, more than 4,000 ING employees
are now trained in data fluency through internal e-learnings, to be able to draw on data and analytics for
informed decision-making.
We also initiated ‘AI Future Leaders programmes’ for employees who want to professionalise their AI
capabilities. The aim is to build a healthy pipeline of future AI leaders throughout the organisation, and 'AI
pivot' for employees who want to enhance their AI capabilities. Through these initiatives, we aim to
empower our talent to actively contribute to innovation at ING and to take advantage of GenAI through
learning and development initiatives. We are also continuing our partnerships with academia, including the
University of Amsterdam and the University of Twente, to foster collaboration on advanced research in the
GenAI domain.
Within Retail Banking, we applied AI and GenAI in areas like loans, mortgages and marketing personalisation.
As in previous years, we delivered several AI capabilities that increased the percentage of loans provided
instantly to both our retail and business banking customers. In marketing personalisation, we tested the use
of GenAI in creating highly personalised campaigns for our customers in Spain and Germany.
In the contact-centre area, we upgraded traditional chatbots, empowering them with GenAI, with the aim of
improving straight-through-processing (STP) and customers’ NPS.
Our AI and GenAI initiatives are delivering significant business impact. We successfully introduced a
programme that identifies affluent customers based on their transactional behaviour across units, yielding
promising results. Key outcomes include a 40 percent increase in term deposit selling, a 40 percent growth in
deposit volume per deposit and a 20 percent higher cross-sell performance in payment account campaigns.
In 2025, we will scale a GenAI tool that will enable marketeers to create personalised campaigns globally.
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> How we are growing the difference
Our team will continue to support and protect our bank against increasingly sophisticated fraud efforts
through AI-based detection models globally. We're implementing AI to strengthen our ability to fight
Financial Economic Crime and support the Retail Banking and COO domain in automating processes. To
support the analysis of transactions, we also deployed an AI model, which we plan to scale in 2025.
In Wholesale Banking, we continued to build analytics products, supporting sustainability initiatives. In this
domain, GenAI can make CDD more efficient, allowing analysts to spend less time on data gathering and
more on customer analysis. We launched a project that provides the CDD transaction profile report, which
was further developed in 2024. This initiative saves our front office an average of two hours per client and is
now operational across 19 countries. We are also exploring a GenAI-powered solution aiming to boost
productivity while maintaining risk effectiveness.
Scalable technology and operations
ING uses scalable technology and operations that enable us to reach the market faster, achieve volume
more quickly, maintain consistent and higher quality, and enhance productivity. This also helps us attract
and retain talent by offering employees the opportunity to not only work with technology but also
collaborate across countries and make an impact globally. Scalable technology allows ING to create specific
and local propositions that serve our customers, while leveraging ING’s scale when it comes to engineering,
security and data experts.
Scalable technology
Our scalable technology platform provides a foundation for the IT modular components we use to build and
operate propositions. It allows ING countries to introduce propositions quickly and easily, while providing the
opportunity to add local flavour.
In 2024, we reconfirmed our direction, further growing our scalable technology platform. The ING technology
vision is one of a unified technology platform (ING ‘Scalable Tech Platform’) that provides a key competitive
advantage. To reach the full potential of our scalable technology platform, the Chief Technology Office
defined three major goals to set the tone for ‘Banking with impact’.
The three goals are:
• increase our productivity by reducing complexity;
• excel in customer experience by driving for customer satisfaction; and
• be a top employer for engineering talents by cultivating a strong engineering mindset.
Our scalable technology is divided into three parts: ING’s private cloud infrastructure (IPC), our engineering
pipeline (OnePipeline) and our banking technology platform. IPC is where we store and manage applications
and data such as channel applications, core banking systems and other banking applications. We measure
IPC adoption by the percentage of physical cores – also known as processing cores or CPU cores – in IPC
compared to the total number of physical cores in ING data centres globally. By the end of 2024, 67 percent
of all physical cores in ING were on IPC (2023: 63 percent).
OnePipeline, our continuous integration and delivery pipeline, provides engineers with a consistent and
secure global capability to develop, test and deploy software. At the end of 2024, 85 percent of applications
were onboarded to this pipeline (2023: 63 percent) out of the total number of applications registered in our IT
management platform across all ING entities. As part of our strategy, we structurally evolve towards a
hybrid cloud set-up, optimising our infrastructure landscape using both private as well as public cloud to run
our applications.
Touchpoint is part of our banking technology platform, providing a set of reusable shared services, used by
engineers to deliver business solutions like Instant Payments and Open Banking quicker and easier. We
measure the Touchpoint-enabled customer online traffic using the Touchpoint authentication, represented
by the number of Touchpoint-enabled unique customer authentications against the total ING number of
unique customer authentications. At the end of 2024, approximately 75 percent of customer logins used
Touchpoint (2023: approximately 64 percent).
Digital access
In a digital society, customers expect to have round-the-clock access to digital channels, including their
banking services. To live up to their expectations, we strive to provide uninterrupted access to our banking
services, while allowing for scheduled maintenance and downtime. We are evaluating ways to broaden the
scope of Retail Countries to be included in our Channel Availability calculations, taking into account technical
feasibility. For 2024, we expanded our Retail scope to include Germany, in addition to the Netherlands and
Belgium. The combined digital channel availability of the Netherlands, Belgium and Germany was 99.86
percent.
For Wholesale Banking clients worldwide, the availability for our Inside Business Payments channel was
99.82 percent and for our Inside Business Connect channel (file transfer), 100 percent. These figures are
based on outputs of availability monitoring processes, which are run with a high frequency per hour.
Scalable operations
Our scalable operations are driven by digitalisation and capability hubs, focusing on becoming fully STP,
removing friction towards a seamless experience for our customers in a safe and secure way. In all we do,
our customers are our point of departure. Our processes, both digital and non-digital, are designed and
executed to embed excellent customer experience. We apply the same mindset to all our employee
journeys.
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> How we are growing the difference
Digitalising key customer journeys allows us to enable superior customer value at a reduced cost-to-serve,
while measuring impact through NPS and cost efficiency. In 2024, our digi index score was 77.2 percent. The
digi index score concerns a figure that reflects the average of STP rates of key customer journeys that are
handled without manual intervention.
Capability hubs provide shared services and solutions across ING worldwide, leveraging expertise and using
scale, and sharing productive, quality services across the ING network. The hubs are mainly located in the
Netherlands, Poland, Romania, Slovakia, the Philippines and Türkiye.
By enabling self-service through mobile and increasing the use of chatbots, we reduced inbound contacts to
contact centres by 26 percent in 2024 (versus 2021).
We are boosting scalability with advanced analytics and (Gen)AI developments, supporting the bank with
intelligence and insights to enrich our operational and decision-making processes.
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 their data. Keeping these safe, and maintaining this
trust, is crucial.
A comprehensive risk management framework helps to ensure that material risks to our business are
identified, measured and managed. Alongside this, our Risk Appetite Framework (RAF) helps us to pursue our
‘Growing the difference’ strategy in a safe, secure and compliant way while meeting regulatory
requirements at all times. And as we look to do business with more customers, it's important to know
exactly who they are in order to protect our organisation, our clients and the financial system as a whole. As
part of our ongoing anti-money laundering (AML) efforts, we screen customers, carry out due-diligence
checks and monitor transactions for unusual or suspicious behaviour. While we deliver on this priority, we
are also putting an increased emphasis on providing superior customer value in our processes. Alongside
AML, we play an important role in preventing and detecting fraud. By deploying innovative solutions, we
seek to limit the number of fraud victims and the impact of fraud loss on our clients and society.
Cybercrime remains a continuous threat to companies and financial institutions in particular. We monitor
the cyberthreat landscape closely and invest in cybersecurity capabilities in all domains (prediction,
prevention, detection, response and recovery). We continuously test both our technical and operational
resilience, and perform crisis management as well as red-team exercises to improve our response to attacks.
In 2024, we identified no cyber incidents on ING infrastructure that required public disclosure as soon as
possible. However, earlier in the year we reported to the authorities that our login web channel in Spain
suffered an unsuccessful attack, which was controlled by our cyber-defence capabilities. We reported
another incident to authorities when an IT change resulted in limited non-personal data disclosure for a
dozen clients. We are currently not aware of any threats in our environment that are likely to materialise in
the near future.
As a global financial institution, we process personal data belonging to our customers, employees, suppliers
and business partners. They trust us with confidential and personal information, so it’s important that we
maintain that trust and keep this data safe from loss or misuse. Ethical standards are always evolving, so we
closely monitor regulatory compliance and potential new requirements to gain an ‘outside-in’ view on data
ethics. And to provide further protection, we encourage employees to speak up when confronted with
unethical, undesirable or illegal behaviour, which they can do anonymously through a variety of reporting
channels.
For more information on ING’s policies and processes to stay safe and secure, see ‘Risk management’.
Unlocking our people’s full potential
Unlocking our people’s full potential is a key enabler of our strategy as we believe we have an abundance of
talent and potential at ING. We attract, develop, retain and reward the right fit-for-future talents and skills.
We strive to deliver a superior employee experience to unlock our people’s time and energy to grow the
difference. We are dedicated to fostering a safe and inclusive environment for our 60,000+ employees, as we
aim to create a friendly, collaborative workplace that mirrors the diverse world we operate in. This is
reinforced by our Orange Culture and Orange Behaviours. We ask our people to act with honesty, prudence
and responsibility, and that they strive to ‘take it on and make it happen’, ‘help others be successful’, and are
‘always a step ahead’.
In 2024, we continued to focus on unlocking our people’s potential through three strategic pillars: ‘talent &
leadership’, ‘culture & organisation’ and ‘employee experience’.
Talent & leadership
To grow the difference and keep ING fit for the future, we need the right people with the right skills and a
readiness to learn and develop. That’s why we make it easy for employees to upskill, something we’ve seen
a strong desire for in 2024. The positive trend for non-mandatory training has continued, with more people
electing to learn new skills and build capabilities relevant to their job and function.
Our focused attention on training complements our efforts to build strong, diverse talent pipelines. Through
our strategic global talent reviews, conducted for approximately 5,000 senior employees, each domain
evaluated their contributions to growing the difference and identified the talent, leadership and capability
needs to advance our ING goals and help future-proof our talent pipelines. One example is our Global
Leadership Accelerator, run in partnership with the IMD Business School, where, following completion,
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> How we are growing the difference
participants are demonstrating increased readiness for senior roles. But as we strengthen the talent of
today, we can also look ahead with confidence: the International Talent Programme continues to welcome
new trainees to ING to develop their banking skills, cultivate professional expertise and support their personal
growth. This rigorous, global two-year programme is just one of our investments in helping to grow our
future experts and leaders.
Our commitment to a fair and transparent performance and rewards process supports our talent and
leadership goals. Our focus for 2024 was on providing our people with more clarity and consistency. We
introduced a new five-point performance rating scale in our performance evaluation scheme and clearly
linked remuneration decisions to performance outcomes. These changes also included the upskilling of our
managers to make our pay decisions more objective.
As of 2025 ING is using a transparent and communicated variable remuneration pay structure. This means
that all employees eligible for variable remuneration (over 35,000 employees) will have a variable
remuneration target, including our Wholesale Banking employees. Previously, variable remuneration awards
were fully discretionary within Wholesale Banking, but from 2025, the annual variable remuneration will be
based on a set percentage (target) of fixed pay. This will provide managers with a decision framework for
determining variable remuneration rewards equitably, while having enough flexibility to differentiate
outcomes for individual performance. Employees will see increased transparency and better understand
how their personal performance influences their variable remuneration.
Culture & organisation
Teams and leaders that reflect the world we operate in are crucial in creating a diverse and inclusive
environment. We aim to increase diverse representation and inclusive behaviours through our diversity,
inclusion and belonging (DIB) policy, strategies, standards and trainings. Another effort includes aiming to
increase the number of women in leadership roles. We define this leadership scope based on our Global Job
Architecture (GJA), a globally applicable approach to describe and evaluate all ING jobs. In 2024, the number
of women in senior positions (GJA 22+) was 32 percent, up from 31 percent at year-end 2023, and the
number of women in the leadership pipeline (GJA 19-21) was 30 percent, up from 28 percent at year-end
2023. To further support our DIB efforts, we have structured feedback mechanisms, including our annual
global Inclusion Index, and hold continuous dialogues with our employees via our Employee Resource
Groups, of which there are over 45 globally relating to culture, disability, gender, generations, LGBTQI+, and
race and ethnicity.
Furthermore, good mental and physical wellbeing can also contribute to an inclusive environment and a
healthy and engaged workforce. We promote a flexible way of working among our employees, are piloting
personalised healthy ‘Working Habits’, and equip managers to support their teams with their wellbeing.
Equally important is the role feedback plays in sustaining our Orange Culture. We maintain a continuous
listening framework, which gives our people formal channels to provide feedback on our strategy, working
conditions, behaviours and experiences. Our Organisational Health Index (OHI) is the most comprehensive of
these listening tools. In 2024, we held two OHI surveys and received feedback from 80 percent of our
workforce, achieving our highest response rate ever. We saw sustained engagement among our employees,
and feedback showed that our people continue to value and appreciate their colleagues, the ability to work
hybrid and the opportunities that support their wellbeing.
Employee experience
Providing superior customer value starts by delivering a superior employee experience. We aim to pave the
way for our people to focus on the things that are truly important while enabling sustainable high-
performance. In 2024, we focused on designing easier, more personal and relevant services for employees
through the collective efforts of the Employee Experience Design Board, with representatives from Human
Resources, Facilities Services, Operations, Information Technology and Global Communications. For example,
we introduced large-scale projects to onboard new countries to our global people management systems and
improved our process automation, resulting in a 45 percent reduction in manual employee notifications and
an 18 percent decrease in Human Resources support tickets filed. Initiatives like these have enhanced the
employee experience by reducing administrative burdens and allowing our people to focus on more
meaningful work.
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Our operating environment
It's essential that our business is resilient, adapting to and navigating
the changing environment we operate in, including new consumer and
banking sector trends, economic shifts and geopolitical volatility.
We continuously adapt the implementation of our strategy, taking into account changes affecting the
banking sector, including technological advancements, competition and disruption, sustainability
developments, regulatory demands and the battle for talent. While the trends outlined below are certainly
not new, some intensified in 2024. By proactively addressing developments around us, we can mitigate risks
while increasing impact and value for our customers.
Technology drives evolving consumer demands
Technology is transforming consumer expectations in banking by emphasising seamless, personalised and
on-demand services. With increased reliance on mobile apps, AI-powered customer service and data-driven
insights, consumers expect banks to offer an excellent customer experience. ING’s digital-first approach
(predominantly in Retail) provides customers with easy, instant, personal and relevant interactions. We’ll
continue to build on our position of strength and invest in digital infrastructure to make sure our services are
simple and accessible. Generative artificial intelligence (GenAI) has the potential to revolutionise banking and
unlock significant value. We recognise GenAI’s potential and are taking a prudent and responsible approach
to using it in a safe and secure way. But the new technology comes with challenges and risks. We recognise
that the increased digitalisation of banking requires us to strengthen our measures to protect consumers,
invest in cybersecurity capabilities and continue to focus on operational resilience.
Competition from banks and non-banks is intensifying
We face increasing competition from traditional and non-banking entities, including fintechs and digital-only
banks. Competitors are capitalising on advanced technologies, low operating costs and flexible regulatory
environments, enabling disruption in areas such as payments, lending and investment services. This
competition pushes us to innovate, as new entrants challenge traditional banking models. We’ll continue to
focus on brand loyalty, enhancing digital services and customer experience and build on our strong
customer base as we aim to become the best European bank for all our stakeholders.
Sustainability is moving to the core of society
The need to build a more sustainable, climate-resilient future is a mission facing the whole of society. As the
challenges increase, governments and businesses should step in and help tackle them. ING aims to play a
leading role in accelerating the transition to a low-carbon economy. We want to build a sustainable future
for our company, our customers, society and the environment. That’s why we’re striving to put sustainability
at the heart of what we do; it is a pillar of our strategy and central to our long-term success.
Regulatory demands are growing and fragmented
The complex and fragmented regulatory landscape we operate in requires us to be highly adaptable,
ensuring robust controls and investing in compliance technology. We must also stay ahead of emerging
regulations in data privacy & ethics, cybersecurity and ESG. We adapt to these evolving regulatory
requirements to manage risk and stay competitive.
The battle for talent is globalising
Our sector faces significant talent shortages, particularly in technology and specialised areas such as
cybersecurity, AI and sustainability. To stay competitive, we invest in a range of global recruitment and
internal development programmes to develop our people’s capabilities and skills and build a diverse and
capable workforce. We have to use talent pools more globally to make sure the best people are considered
for the job.
Dynamic geopolitical environment
The past year was a ‘super election year’, as nearly half of the global population went to the polls. In Europe,
there was a broad political shift that could alter future EU policies. Following the US elections in November,
we have seen significant shifts in foreign policy and economic policy from the new administration. This
includes policy changes that have heightened concerns about long-term support for Ukraine. In 2024, the
war there led to continued energy market and supply chain disruption. Tensions in the Middle East escalated,
intensifying the suffering endured by civilians in Gaza and neighbouring areas and leading to military
engagements between Israel and Iran. A six-week ceasefire agreed in early 2025 between Israel and militant
group Hamas has provided temporary relief and helped stabilise oil prices, while efforts continue toward a
permanent truce. However, the situation remains fragile, increasing uncertainty and risk of renewed
hostilities, possibly affecting regional stability and consequently global trade
ING Bank Annual Report 2024 16
Our financial
performance
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Our financial performance
In 2024, we have again delivered strong results and are executing well
on our strategy to accelerate growth, increase impact and deliver value
for all stakeholders. Our net result of €6,187 million reflects resilient total
income, supported by double-digit growth in fee income and strongly
increased customer lending and customer deposit volumes. Higher
expenses show the continued investments in the growth of our
business, as well as inflationary effects on staff expenses. Risk costs
remained below our through-the-cycle average.

Consolidated results
| 2024 | 2023 | Change
Profit or loss (in € million) |  |  |
Net interest income | 14,749 | 15,809 | -7%
Net fee and commission income | 4,002 | 3,586 | 12%
Total investment and other income | 3,584 | 3,006 | 19%
Total income | 22,334 | 22,401 | 0%
Expenses excl. regulatory costs | 11,234 | 10,521 | 7%
Regulatory costs | 882 | 1,042 | -15%
Operating expenses | 12,116 | 11,563 | 5%
Gross result | 10,219 | 10,838 | -6%
Addition to loan loss provisions | 1,194 | 520 | 130%
Result before tax | 9,025 | 10,318 | -13%
Taxation | 2,580 | 2,926 | -12%
Non-controlling interests | 258 | 235 | 10%
Net result 1 | 6,187 | 7,157 | -14%
Key financial metrics |  |  |
Net core lending growth (in € billion)2 | 27.7 | 8.6 |
Net core deposits growth (in € billion)2 | 47.4 | 10.6 |
Cost/income ratio | 54.2% | 51.6% |
Risk costs in bps of average customer lending | 18 | 8 |

1 Net result reflects the net result attributable to shareholders of the parent.
2 For a reconciliation of net core lending growth and net core deposits growth to customer lending growth and customer deposits
growth respectively, see the appendix 'Alternative performance measure'.
ING Bank Annual Report 2024 18

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

> Our financial performance
Total income
Total income rose to a record €22,334 million. This was supported by continued growth of our customer
base, double-digit growth in fee income and sharply increased lending and deposit volumes.
We recorded outstanding commercial growth in 2024. Net core lending growth (which is the increase in
customer lending adjusted for currency impacts and excluding Treasury and the run-off portfolios) was
€27.7 billion. We were particularly successful in increasing our residential mortgages portfolio, by €18.9
billion, spread across all our retail countries. In addition, we also grew our consumer lending and business
lending books (by €6.9 billion in total). And we recorded a net growth in Wholesale Banking of €1.8 billion,
while we continued to optimise our capital usage.
Net core deposits growth (which excludes FX impacts and movements in Treasury deposits) was a record
€47.4 billion in 2024, with strong contributions from both Retail Banking and Wholesale Banking. At the end
of 2024, 69% of our balance sheet was funded by customer deposits.
Net interest income (NII) from lending and liabilities held up well; however, total NII declined 6.7% to €14,749
million due to lower NII in Financial Markets and Treasury. Lending NII rose by €139 million, reflecting volume
growth at a stabilising margin. Liability NII declined by €318 million as deposit growth could not entirely
offset the impact of normalising margins. Financial Markets NII was €494 million more negative than in 2023
as higher interest rates led to an increase in funding costs. This impacted NII while the income from related
positions is reflected in other income due to accounting asymmetry. NII in Treasury dropped by €443 million,
primarily impacted by the ECB’s adjustment in September 2023 of the remuneration on the minimum
reserve requirements to zero basis points as well as by less favourable conditions in the money markets.
Other NII included a one-off income of €70 million in Wholesale Banking and a €-39 million impact from the
Polish mortgage moratorium. The net interest margin was 1.42% in 2024, which is 13 basis points lower than
in 2023, mainly due to a lower NII in Financial Markets and Treasury.
Net fee and commission income strongly increased in line with our ambition to diversify our income and was
up 12% to over €4 billion. Fee income from retail investment products was significantly up, reflecting an
increase in accounts, in assets under management and customer trading activity. Daily banking fees rose on
the back of strong growth in the number of customers and an updated pricing for payment packages. The
increase in fee income for Wholesale Banking was mainly attributable to a higher income from Capital
Markets issuance.
Total investment and other income increased 19% to €3,584 million. This was mainly due to the positive
effect of accounting asymmetry in Financial Markets, as well as to a smaller IAS 29 impact (reflecting lower
inflation in Türkiye). Furthermore, in 2024 we recorded €77 million as our share in the one-off profit of an
associate in Belgium and a €53 million receivable (recorded in the Corporate Line) related to a prior
insolvency of a financial institution in the Netherlands.
Operating expenses
Operating expenses increased 4.8% to €12,116 million. Expenses in 2024 included €882 million of regulatory
costs, a decline of €160 million year-on-year, mainly because no contribution to the eurozone’s Single
Resolution Fund was required in 2024 and because the Dutch deposit guarantee fund reached its target level
in 2024. Furthermore, expenses in 2024 included €178 million of incidental items (largely related to
restructuring provisions) compared with €247 million of incidental items in 2023.
Expenses excluding regulatory costs and incidental items rose 7.6%, mainly attributable to the impact of
inflation on staff expenses and the implementation of the ‘Danske Bank’ ruling on VAT in the Netherlands. In
Retail Banking, this was coupled with investments in digitalisation and in client acquisition to support growth.
Wholesale Banking expenses also reflect front office growth in Capital Markets & Advisory and Transaction
Services, as well as investments to enhance the digital experience and the scalability of our systems. The
cost/income ratio came out at 54.2% in 2024 compared with 51.6% a year earlier.
Addition to loan loss provisions
Net additions to loan loss provisions increased to €1,194 million compared with €520 million in 2023. This is
equivalent to 18 basis points of average customer lending, and below our through-the-cycle average of 20
basis points.
The increase year-on-year was largely due to additions for a number of Stage 3 files in Wholesale Banking.
This was partly compensated by a net release from loan loss provisions in Stage 1 and 2, mainly reflecting a
partial release of management overlays.
Net result
The net result (attributable to shareholders of the parent) in 2024 was €6,187 million compared with €7,157
million in 2023. The effective tax rate in 2024 was 28.6% compared with 28.4% in 2023.
ING Bank Annual Report 2024 19

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

Retail Banking

Retail Banking
| Total Retail Banking | Retail Netherlands | Retail Belgium | Retail Germany | Retail Other
in EUR million | 2024 | 2023 | Change | 2024 | 2023 | Change | 2024 | 2023 | Change | 2024 | 2023 | Change | 2024 | 2023 | Change
Net interest income | 11,449 | 11,459 | 0% | 3,027 | 3,096 | -2% | 1,959 | 2,063 | -5% | 2,647 | 2,862 | -8% | 3,817 | 3,437 | 11%
Net fee and commission income | 2,694 | 2,337 | 15% | 1,049 | 959 | 9% | 603 | 502 | 20% | 433 | 357 | 21% | 609 | 519 | 17%
Total investment and other income | 1,113 | 1,272 | -13% | 835 | 945 | -12% | 189 | 117 | 62% | -173 | -67 |  | 263 | 277 | -5%
Total income | 15,256 | 15,069 | 1% | 4,910 | 5,001 | -2% | 2,751 | 2,683 | 3% | 2,906 | 3,152 | -8% | 4,688 | 4,233 | 11%
Expenses excl. regulatory costs | 7,361 | 6,938 | 6% | 2,011 | 1,923 | 5% | 1,605 | 1,642 | -2% | 1,215 | 1,147 | 6% | 2,532 | 2,227 | 14%
Regulatory costs | 668 | 771 | -13% | 114 | 212 | -46% | 206 | 211 | -2% | 88 | 96 | -8% | 261 | 252 | 4%
Operating expenses | 8,030 | 7,709 | 4% | 2,124 | 2,135 | -1% | 1,811 | 1,852 | -2% | 1,303 | 1,243 | 5% | 2,792 | 2,479 | 13%
Gross result | 7,226 | 7,360 | -2% | 2,786 | 2,866 | -3% | 941 | 830 | 13% | 1,604 | 1,909 | -16% | 1,896 | 1,754 | 8%
Addition to loan loss provisions | 566 | 607 | -7% | -8 | 5 | -260% | 134 | 169 | -21% | 149 | 119 | 25% | 291 | 313 | -7%
Result before taxation | 6,660 | 6,753 | -1% | 2,793 | 2,861 | -2% | 807 | 661 | 22% | 1,455 | 1,790 | -19% | 1,605 | 1,441 | 11%
Taxation | 1,819 | 1,912 | -5% | 723 | 740 | -2% | 210 | 182 | 15% | 505 | 631 | -20% | 381 | 359 | 6%
Non-controlling interests | 223 | 174 | 28% | 0 | 0 |  | 0 | 0 |  | 1 | 0 |  | 221 | 174 | 27%
Net result IFRS | 4,618 | 4,667 | -1% | 2,070 | 2,121 | -2% | 597 | 479 | 25% | 949 | 1,159 | -18% | 1,002 | 908 | 10%
Key figures |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Net core lending growth (in € billion) | 25.9 | 9.7 |  | 9.6 | 2.3 |  | 3.7 | 1.4 |  | 4.4 | 1.7 |  | 8.2 | 4.3 |
Net core deposits growth (in € billion) | 31.6 | 18.5 |  | 5.0 | -1.6 |  | 6.4 | -1.3 |  | 7.5 | 8.5 |  | 12.7 | 12.9 |
Cost/income ratio | 52.6% | 51.2% |  | 43.3% | 42.7% |  | 65.8% | 69.1% |  | 44.8% | 39.4% |  | 59.6% | 58.6% |
Risk costs in bps of average customer lending | 12 | 13 |  | 0 | 0 |  | 14 | 18 |  | 14 | 12 |  | 26 | 29 |
Return on equity based on 12.5% CET1 2 | 24.3% | 24.8% |  | 32.1% | 33.4% |  | 13.7% | 11.2% |  | 30.1% | 33.3% |  | 20.6% | 20.1% |

1 After-tax return divided by average equity based on 12.5% of risk-weighted assets.
Retail Banking had another excellent year, with a net result of €4,618 million, close to the record level
achieved in 2023 (€4,667 million). The result before tax came out at €6,660 million.
Retail Banking maintained strong commercial momentum in 2024. The mobile primary customer base
increased by 1.1 million, and this was coupled with a record growth in customer lending and an
exceptionally high growth in customer deposits.
Net core lending growth (which excludes currency impacts, Treasury and run-off portfolios) was €25.9 billion.
This was particularly driven by a further increase of our mortgage portfolio across all markets. We also
further grew our consumer lending and business lending portfolios.
We were very successful in attracting deposits in 2024. Net core deposits growth (which is the increase in
customer deposits excluding FX impacts and movements in Treasury deposits) was €31.6 billion. All of our
countries contributed, with the largest increases coming from Germany and Belgium following successful
campaigns.
ING Bank Annual Report 2024 20

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

> Retail Banking
Total net interest income was resilient in 2024. The strong increase in lending and deposit volumes, in
combination with improved liability margins outside the eurozone, had a favourable impact on our NII. This
compensated for the impact of normalising liability margins in the eurozone.
Net commission and fee income rose 15% to €2,694 million. This strong increase was mainly attributable to
higher fee income from daily banking services and investment products. We benefited from more customers
choosing ING for their banking products, from an updated pricing for payment packages, as well as from
growth in assets under management and in the number of brokerage trades. In addition, we also recorded
double-digit growth in fee income from lending and insurance products.
Total investment and other income decreased 13% to €1,113 million, reflecting a drop in Treasury-related
other income. This was partly offset by €77 million for our share in the one-off profit of an associate in
Belgium.
Operating expenses amounted to €8,030 million and were up 4.2%. Regulatory costs were €103 million lower
year-on-year, mainly because no contribution to the eurozone’s Single Resolution Fund was required in 2024
and because the Dutch deposit guarantee fund reached its target level in 2024. Expenses in 2024 included
€86 million of incidental items (largely related to restructuring provisions) compared with €131 million of
incidental items in 2023. Expenses excluding regulatory costs and incidental items rose 6.9%, mainly
attributable to higher staff and client acquisition expenses, as well as to higher VAT costs after the
implementation of the ‘Danske ruling’.
Net additions to loan loss provisions for Retail Banking declined to €566 million in 2024 and were 12 basis
points of average customer lending. Risk costs were positively impacted by continued strong asset quality, a
partial release of management overlays and a strong improvement in the housing markets.
Retail Netherlands
Retail Netherlands posted a result before tax of €2,793 million compared with €2,861 million in 2023. The
2.4% decline was due to lower Treasury-related income, while expenses were broadly flat and risk costs
showed a small net release.
Net interest income was €3,027 million, or 2.2% lower than a year earlier. The decline was attributable to
lower Treasury-related interest income, reflecting the impact of the ECB’s adjustment of the remuneration
on the minimum reserve requirement to zero basis points in September 2023 as well as less favourable
money market conditions. Net interest income from lending increased, supported by significant growth in
the mortgage portfolio.
Net fee and commission income was strong and rose 9.4% to €1,049 million. This was driven by growth in
the number of customers, higher fees for payment packages and a double-digit increase in assets under
management. Other income decreased due to lower other income from specific money market and FX
transactions in Treasury.
Net core lending growth (which excludes movements in Treasury and in the WestlandUtrecht Bank run-off
portfolio) was €9.6 billion, driven by strong growth of the mortgage portfolio. Customer deposits (excluding
Treasury) grew by €5.0 billion.
Operating expenses slightly decreased to €2,124 million. Regulatory costs declined by €98 million because
no contribution to the Single Resolution Fund was required in 2024 and because the Dutch deposit guarantee
fund in the Netherlands reached its target level in 2024. This more than compensated for a higher bank tax
in the Netherlands. Expenses excluding regulatory costs rose 4.6% to €2,011 million. This included higher
internal staff expenses due to collective labour agreement (CLA) increases, partly offset by savings on
external staff.
In 2024, a net release from loan loss provisions was recorded of €-8 million. This was attributable to a net
release for mortgages, driven by a strong improvement in the housing market and a partial release of
management overlays.
Retail Belgium
The result before tax for Retail Belgium (which includes our retail activities in Luxembourg) rose 22% to €807
million. The increase was attributable to higher income, coupled with lower operating expenses and a decline
in risk costs.
Net interest income decreased by €104 million or 5.0%, mainly due to lower Treasury-related interest
income. In addition, net interest income was impacted by higher funding costs for mortgages.
Net fee and commission income rose by €101 million or 20%, supported by an increase in assets under
management and lower commissions paid. Investment and other income was strongly up because 2024
included €77 million for our share in the one-off profit of an associate.
Customer lending (excluding Treasury) rose by €3.7 billion, reflecting a €2.7 billion increase in business
lending and €1.0 billion of growth in the mortgage portfolio. Customer deposits (excluding Treasury)
increased by €6.4 billion, driven by a €5.5 billion inflow from our successful term deposit campaigns
(exceeding the €2.6 billion outflow we saw in 2023 when customers bought bonds issued by the Belgian
government).
ING Bank Annual Report 2024 21

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

> Retail Banking
Operating expenses amounted to €1,811 million, including €206 million of regulatory costs (versus €211
million in 2023) and €59 million of incidental item costs related to restructuring and a further optimisation of
the branch network (compared with €76 million for this in 2023). Expenses excluding regulatory costs and
incidental items declined 1.3%, as the impact of automatic salary indexation was offset by FTE reductions.
The net addition to the provision for loan losses amounted to €134 million, or 14 basis points of average
customer lending, down from €169 million in 2023. Risk costs for mortgages and consumer lending declined
while risk costs for business lending were stable.
Retail Germany
The result before tax for Retail Germany was €1,455 million, a decline of 19% year-on-year, which was
mainly due to lower income from liabilities.
Net interest income decreased 7.5% to €2,647 million, as higher client rates on savings led to a narrowing of
the liability margin in comparison to the elevated levels we had seen in 2023. This was partly offset by
volume growth in both lending and deposits.
Net fee and commission income increased 21% to €433 million, mainly fuelled by investment products,
where we recorded a higher number of trades and exceeded the milestone of €100 billion in assets under
management in 2024. The increase in fee income was also attributable to higher fees from daily banking
and mortgage brokerage. Total investment and other income declined, reflecting lower Treasury-related
income.
Net core lending growth (which excludes Treasury) was €4.4 billion. Next to €3.6 billion in mortgages we
grew our other lending portfolio by €0.8 billion, with an increase in both our consumer lending and business
lending portfolio.
Customer deposits (excluding Treasury) increased by €7.5 billion following a successful campaign to attract
new savings and private customers, as well as a net inflow of €0.8 billion in Business Banking.
Operating expenses rose 4.8% to €1,303 million. Excluding €88 million of regulatory costs (down from €96
million in 2023) and €20 million of incidental items for restructuring costs and staff allowances recorded in
2023, cost growth was 7.8%. This was due to higher staff expenses and investments in business growth.
Net additions to loan loss provisions amounted to €149 million (14 basis points of average customer lending)
and were primarily related to consumer lending.
Retail Other
Retail Other consists of the Other Challengers & Growth Markets. For Retail Other, result before tax increased
11% to €1,605 million, mainly thanks to higher income.
Total income rose 11% to €4,688 million. Net interest income was up 11% to €3,817 million, supported by
growth in both lending and deposit volumes in all countries, coupled with higher margins on liabilities
outside the eurozone. Net interest income in 2024 included a €-39 million impact from the Polish mortgage
moratorium, following amendments to the regulation that offers some customers the right to suspend up to
four instalment payments on their mortgage loan.
Net fee and commission income increased 17% to €609 million. This was driven by higher fees in daily
banking, reflecting an increase in the number of customers and an updated pricing for payment packages,
combined with higher fee income from investment products. Other income decreased due to lower
Treasury-related income.
Net customer lending growth (adjusted for currency effects and Treasury) was €8.2 billion in 2024, with
growth in all countries, but particularly in Australia, Poland, Spain and Italy. Net core deposits growth (also
excluding currency impacts and Treasury) was €12.7 billion, primarily driven by net inflows in Poland, Spain
and Australia.
Operating expenses in 2024 amounted to €2,792 million. Excluding regulatory costs (which were slightly up
on 2023) and restructuring costs and impairments (€17 million in 2024 versus €36 million in 2023), expenses
increased by 15%. This was due to inflationary pressure (particularly in Türkiye), higher client acquisition
expenses and investments in further business growth.
The net addition to loan loss provisions was €291 million, or 26 basis points of average customer lending,
compared with €313 million in 2023. Risk costs in 2024 were primarily attributable to net additions in Poland
and Spain.Retail Banking had another excellent year, with a net result of €4,618 million, close to the record
level achieved in 2023 (€4,667 million). The result before tax came out at €6,660 million.
ING Bank Annual Report 2024 22

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

Wholesale Banking

Wholesale Banking
in EUR million | 2024 | 2023 | Change
Net interest income | 3,259 | 4,028 | -19%
Net fee and commission income | 1,317 | 1,259 | 5%
Total investment and other income | 2,405 | 1,771 | 36%
Total income | 6,981 | 7,057 | -1%
of which: |  |  |
Lending | 3,278 | 3,224 | 2%
Daily Banking & Trade Finance | 1,954 | 2,153 | -9%
Financial Markets | 1,417 | 1,280 | 11%
Treasury & Other | 332 | 401 | -17%
Total income | 6,981 | 7,057 | -1%
Expenses excl. regulatory costs | 3,346 | 3,043 | 10%
Regulatory costs | 212 | 271 | -22%
Operating expenses | 3,558 | 3,313 | 7%
Gross result | 3,423 | 3,744 | -9%
Addition to loan loss provisions | 627 | -92 |
Result before taxation | 2,796 | 3,836 | -27%
Taxation | 693 | 900 | -23%
Non-controlling interests | 35 | 61 | -43%
Net result IFRS | 2,068 | 2,875 | -28%
Key figures |  |  |
Net core lending growth (in € billion) | 1.8 | -1.2 |
Net core deposits growth (in € billion) | 15.8 | -7.9 |
Cost/income ratio | 51.0% | 47.0% |
Risk costs in bps of average customer lending | 33 | -5 |
Return on equity based on 12.5% CET1 1 | 11.0% | 15.4% |

1 After-tax return divided by average equity based on 12.5% of risk-weighted assets.
Wholesale Banking achieved a gross result of €3,423 million. Total income was resilient, supported by
increased lending and deposit volumes and strong results in Financial Markets, which compensated for
margin compression in Payments & Cash Management. Expenses rose, primarily due to the impact of
collective labour agreements, inflation and investments in business growth and in our product foundations.
We remained disciplined in capital management, with a modest increase of €1.9 billion in risk-weighted
assets, fully due to the strengthening of the US dollar, and income over average risk-weighted assets was
resilient at 458 basis points. The net result declined 28% to €2,068 million, mainly due to higher risk costs
versus a net release in 2023. The return on equity came out at 11.0% in 2024.
Net core lending growth was €1.8 billion in 2024, with the increase being softened by loan sales and other
ongoing efforts to optimise our capital usage. Net core deposits growth was €15.8 billion in 2024, mainly
attributable to strategic initiatives in Payments & Cash Management and Money Markets.
Total income in 2024 amounted to €6,981 million and was almost stable year-on-year. Our focus on income
diversification yielded positive results, as evidenced by higher income from Financial Markets and an
increase in fee income. Our Capital Markets & Advisory business continued to grow, following investments to
further build on our expertise. Income from Payments & Cash Management declined, reflecting lower
margins.
Total income in Lending rose 1.7% to €3,278 million, with an increase in both net interest income and in fee
income. We further optimised our capital efficiency and kept our risk-weighted assets flat despite the
strengthening of the US dollar, leading to an improvement in income over average risk-weighted assets.
In Daily Banking & Trade Finance we were successful in attracting deposit balances. Income declined year-
on-year, reflecting lower margins for Payments & Cash Management. This was partly offset by income
growth for Trade Finance Services, on the back of higher margins and increased fee income.
Financial Markets had a strong year, with income increasing 11% to €1,417 million. This was primarily driven
by increased Capital Markets issuance income and an enhanced performance in Global Securities Finance
products.
Income from Treasury & Other declined, largely due to a lower remuneration on the ECB minimum reserve
requirement, while Treasury had also benefited from the rapid increase in interest rates in 2023. This was
coupled with lower results from Corporate Investments, and partly offset by a €70 million one-off income.
ING Bank Annual Report 2024 23

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

> Wholesale Banking
Total operating expenses increased 7.4% to €3,558 million. Regulatory costs were lower, mainly because no
contribution to the eurozone’s Single Resolution Fund was required in 2024. Excluding regulatory costs and
incidental item costs (€10 million in 2024 versus €17 million in the year before), expenses increased 10%.
This was due to the impact of collective labour agreements, inflation and front office growth in Capital
Markets & Advisory and Transaction Services, as well as investments to enhance the digital customer
experience and the scalability of our systems.
The net addition to loan loss provision amounted to €627 million in 2024 (33 basis points of average
customer lending). This compares to a net release of €92 million in 2023, when €218 million of provisions for
our Russia-related portfolio could be released, mainly due to a reduction of our exposure. Risk costs in 2024
were primarily related to individual Stage 3 provisioning. Additions for a number of unrelated files in Stage 3
were partly offset by releases from collective provisions in Stage 1 and 2 (including a partial release of
management overlays).
Our leadership
and corporate governance
ING Bank Annual Report 2024 25

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

Our leadership and corporate governance
Effective governance is essential for ING to realise its strategic ambitions
and to safeguard the interests of customers and other stakeholders. Our
leadership plays a pivotal role in this: the Supervisory Board (SB)
supervises and advises the Management Board Banking (MBB) and
oversees the activities of ING and the business connected with it.
We aim for a balanced composition of our SB and MBB, with the boards consisting of a diverse selection of
people with knowledge, skills and executive experience, preferably gained in the banking sector, in large
stock-listed companies and in the political and social environment in which such companies operate.
There should also be a balance of experience and affinity with the nature and culture of the business of ING.
The boards play a role in setting and promoting the culture, underlying values and behaviours and code of
conduct that all help to run our business in a way that contributes to sustainable long-term value creation
for our customers, our people, our shareholders and society.
ING has a matrix structure combining hierarchical and functional lines that work together to achieve a
common goal, with dedicated roles and responsibilities and mechanisms for delegation, decision making and
escalation. ING’s risk governance safeguards the functioning of the matrix structure and is based on the
three lines of defence model, which has segregated duties and independent internal control functions.
Read more on ING’s risk governance and three lines of defence in 'Risk management'.
ING Bank Annual Report 2024 26

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

> Our leadership and corporate governance
Members of the Supervisory Board

Karl Guha (chairperson) Born: 1964 Nationality: Dutch Term expires: 2027 |  | Mike Rees (vice-chairperson) Born: 1956 Nationality: British Term expires: 2027 |  | Juan Colombás Born: 1962 Nationality: Spanish Term expires: 2028 |  | Margarete Haase Born: 1953 Nationality: Austrian Term expires: 2025 |  | Lodewijk Hijmans van den Bergh Born: 1963 Nationality: Dutch Term expires: 2025 |  | Herman Hulst Born: 1955 Nationality: Dutch Term expires: 2028 |  | Harold Naus Born: 1969 Nationality: Dutch Term expires: 2028 |  | Alexandra Reich Born: 1963 Nationality: Austrian Term expires: 2027 |  | Herna Verhagen Born: 1966 Nationality: Dutch Term expires: 2027
Karl was appointed chairperson of the SB at the General Meeting in April 2023. He started in July 2023. Karl is chairperson of the Nomination and Corporate Governance Committee and member of the Remuneration Committee, the Risk Committee, the Audit Committee, the ESG Committee and the Technology & Operations Committee. |  | Mike was appointed a member of the SB at the General Meeting in April 2019. Mike is vice-chairperson of the SB, chairperson of the Risk Committee and member of the Nomination and Corporate Governance Committee and the Audit Committee. |  | Juan was appointed a member of the SB at the General Meeting in April 2020. He started in October 2020. Juan is chairperson of the Technology & Operations Committee and member of the Risk Committee, the Audit Committee and the ESG Committee. |  | Margarete was appointed a member of the SB at the General Meeting in May 2017. Margarete is chairperson of the Audit Committee and member of the Risk Committee and the Remuneration Committee. |  | Lodewijk was appointed a member of the SB at the General Meeting in April 2021. Lodewijk is chairperson of the ESG Committee and member of the Risk Committee. |  | Herman was appointed a member of the SB at the General Meeting in April 2020. Herman is member of the Audit Committee, the Risk Committee and the ESG Committee. |  | Harold was appointed a member of the SB at the General Meeting in April 2020. Harold is member of the Remuneration Committee, the Risk Committee and the Technology & Operations Committee. |  | Alexandra was appointed a member of the SB at the General Meeting in April 2023. Alexandra is member of the Risk Committee, the Technology & Operations Committee and the ESG Committee. |  | Herna was appointed a member of the SB at the General Meeting in April 2019, and started in October 2019. Herna is chairperson of the Remuneration Committee and member of the Nomination and Corporate Governance Committee.
Former position: CEO of Van Lanschot Kempen Relevant CRD IV position(s) ▪ Chairperson of the SB ▪ Member of the supervisory board of SHV Holdings N.V. Other ancillary positions ▪ Member of the supervisory board of Rijksmuseum Fonds |  | Former position: Deputy CEO of Standard Chartered Bank PLC. Relevant CRD IV position(s) ▪ Vice-chairperson of the SB ▪ Non-executive chairperson of the board of directors of Travelex International Limited ▪ Non-executive chairperson of the board of directors of Midlands Mindforge Other ancillary positions ▪ Non-executive chairperson of the board of directors of Mauritius Africa FinTech Hub |  | Former position: Chief operations officer and executive board member of the board of directors of Lloyds Banking Group Relevant CRD IV position(s) ▪ Member of the SB ▪ Non-executive member of the board of directors of Azora Capital S.L. ▪ Non-executive chairperson of the board of directors of Bluserena Spa Other ancillary positions ▪ Member of the global alumni advisory board of the Institute de Empresa (IE) Business School |  | Former position: CFO of Deutz AG Relevant CRD IV position(s) ▪ Member of the SB ▪ Chairperson of the supervisory board of ams- OSRAM AG ▪ Member of the supervisory board of Fraport AG Other ancillary positions ▪ Chairperson of the employers association of Kölnmetall ▪ Member of the German Corporate Governance Commission |  | Former position: Partner/member of the management committee of De Brauw Blackstone Westbroek N.V. Relevant CRD IV position(s) ▪ Member of the SB ▪ Deputy chairperson of the supervisory board of HAL Holding N.V. ▪ Member of the supervisory board of Heineken N.V. Other ancillary positions ▪ Chairperson of the board of Utrecht University Fund (the Netherlands) ▪ Chairperson of the executive committee of Vereniging Aegon |  | Former position: Global vice-chairperson EY Japan Relevant CRD IV position(s) ▪ Member of the SB Other ancillary positions ▪ None |  | Former position: Global head of Trading Risk Management and general manager Market Risk of ING Bank Relevant CRD IV position(s) ▪ Member of the SB ▪ CEO of Cardano Asset Management N.V. ▪ CEO of Cardano Risk Management B.V. ▪ Member of the executive board of Cardano Holding Limited Other ancillary positions ▪ None |  | Former position: CEO of Telenor Thailand Relevant CRD IV position(s) ▪ Member of the SB ▪ Member of the non- executive board of directors of Cellnex Telecom S.A. ▪ Member of the non- executive board of directors of Salt Mobile S.A. ▪ Member of the non- executive board of directors of DELTA Fiber Other ancillary positions ▪ None |  | Former position: Member of the supervisory board of SNS Reaal N.V. (now: SRH N.V.) Relevant CRD IV position(s) ▪ Member of the SB ▪ CEO of PostNL N.V. ▪ Member of the supervisory board of Koninklijke Philips N.V. Other ancillary positions ▪ Member of the supervisory board of Het Concertgebouw N.V. ▪ Member of the advisory council of Goldschmeding Foundation

ING Bank Annual Report 2024 27

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

> Our leadership and corporate governance
Members of the Management Board Banking

Steven van Rijswijk (CEO) Born: 1970 Nationality: Dutch |  | Tanate Phutrakul (CFO) Born: 1965 Nationality: Thai |  | Ljiljana Čortan (CRO) Born: 1971 Nationality: Croatian |  | Pinar Abay Born: 1977 Nationality: Turkish |  | Andrew Bester Born: 1965 Nationality: British/South African |  | Marnix van Stiphout (COO) Born: 1970 Nationality: Dutch |  | Daniele Tonella (CTO) Born: 1971 Nationality: Swiss |  |  |  |
Steven was appointed CEO and chairperson of this Board in July 2020. Prior to his appointment as CEO and chairperson of this Board, he was the chief risk officer. Steven is responsible for ING's strategy including ESG and sustainability, decision- making, results, governance, culture, branding, reputation and people. |  | Tanate was appointed as chief financial officer and member of the Management Board Banking in February 2019. Tanate is responsible for ING's financial strategy, budgeting, cost control and the financing of the company. |  | Ljiijana was appointed as chief risk officer and a member of the Management Board Banking effective January 2021. Ljiijana is responsible for ING's risk activities including formulating our risk framework and risk appetite, risk culture and awareness, risk governance and policies and compliance. |  | Pinar was appointed a member of the Management Board Banking in January 2020. She is also head of Retail, Market Leaders and Challengers & Growth Markets. She was appointed as non- executive member of the board of ING in Belgium in March 2021 and was chairperson of that board from May 2022 until December 2023. In May 2023, Pinar was appointed a member of the supervisory board of ING-DiBa AG. Pinar is responsible for defining strategy and priorities for global retail banking and driving performance, operations and compliance of retail, market leaders and challengers & growth markets. |  | Andrew was appointed a member of the Management Board Banking and head of Wholesale Banking in April 2021. Andrew is responsible for ING's wholesale banking activities globally. |  | Marnix was appointed a member of the Management Board Banking and chief operations officer in September 2021. Marnix is responsible for translating, overseeing and implementing ING's strategies into a strategy for the operations function. |  | Daniele joined ING's Management Board Banking as chief technology officer on 5 August 2024. Daniele is responsible for overseeing and managing the total IT landscape and advising on technology-driven business opportunities. |  |  |  |
Relevant CRD IV position(s) CEO and chairperson of the EB and the MBB Other ancillary positions ▪ Member of the Management Board of the Nederlandse Vereniging van Banken (NVB) ▪ Member of the Cyber Security Council (CSR) |  | Relevant CRD IV position(s) CFO and member of the EB and the MBB Other ancillary positions ▪ None |  | Relevant CRD IV position(s) CRO and member of the EB and the MBB Other ancillary positions ▪ None |  | Relevant CRD IV position(s) Member of the MBB, non- executive member of the board of ING Belgium N.V./S.A., member of the supervisory board of ING-DiBa A.G. and member of the board of EPI Company SE Other ancillary positions ▪ None |  | Relevant CRD IV position(s) Member of the MBB Other ancillary positions ▪ None |  | Relevant CRD IV position(s) Member of the MBB Other ancillary positions ▪ None |  | Relevant CRD IV position(s) Member of the MBB Other ancillary positions ▪ None |  |  |  |

ING Bank Annual Report 2024 28

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

Supervisory Board report
This section contains the Supervisory Board report, with information on
the meetings of the SB and its committees, attendance of SB members
and the MBB and SB annual self-evaluation.
Meetings of the Supervisory Board
The Supervisory Board (SB) met 11 times in 2024 and focused in particular on growth, strategy, risk,
geopolitical developments, people & succession, and operational and regulatory resilience. The Management
Board Banking (MBB) were present at regular SB meetings. The SB also had sessions without the MBB when
this was justified by the nature of the topics on the agenda. The purpose of these sessions and SB-only
meetings is to allow the SB to reflect independently on and consider important matters in the absence of the
MBB. The SB also had so-called ‘Restricted SB meetings’, with only the CEO attending, except when matters
concerning the CEO were discussed. Topics addressed were primarily nomination- and remuneration- related
matters such as target setting and performance assessments with, among others, additional attention for
strategic and governance topics.
In regular SB meetings, ING staff and the internal and external auditors are frequently asked to provide
presentations on specific topics. Examples of such topics are progress of ING’s performance in the various
countries and business lines, supervisory developments including the ECB’s Supervisory Review and
Evaluation Process (SREP), geopolitical developments, the financing of ING in accordance with ING’s capital
and liquidity adequacy, ING’s dividend and distribution policy, ING’s financials, investor relations updates,
strategy including M&A ambitions, risk appetite, audit plans, ING’s risk culture and regulatory themes with a
global ING scope, such as ESG-related matters, operational resilience, IT, cybersecurity and ransomware and
the use of (generative) artificial intelligence.
The SB was also informed throughout the year of potential financial, non-financial and compliance risks for
ING, including the political and economic developments in various countries and regions, climate- and ESG-
related risks, cybersecurity and ransomware. The year 2024 was marked by continued uncertain market
conditions and geopolitical tensions, against a backdrop of deglobalisation and geographic shifts in cross-
border trade. The operating environment was challenged by a struggling global economy, decreasing
interest rates, tightening monetary conditions and elections in various countries. The SB closely monitored
those macroeconomic developments in 2024 and discussed the potential consequences for ING's operations.
With respect to ING's strategy, the SB regularly discusses intent and execution with the CEO. The SB
challenges and advises on the strategy and priority setting. In June 2024, ING hosted a Capital Markets Day
(CMD), where it presented the next phase of its strategy. The SB had an active and continuous dialogue with
the EB and MBB in the preparation for the CMD. Under the headline ‘Growing the difference’, ING presented
its ambition to be the best European bank by accelerating growth, increasing impact and delivering value.
For more, see 'Our strategy'.
As one of the key enablers of ING’s strategy, the SB closely monitored progress related to scalable
technology and operations. The aim is to achieve scalable technology and operations that provide for a
superior customer experience, while preventing technological failures, resolving the issues that do occur and
addressing their root causes. The SB has a general and continuous focus on operational resilience. In addition
to the updates on operational resilience, the SB regularly discussed the availability and reliability of ING's
channels, including how (senior) management addressed any setbacks. Not only do scalable technology and
operations require available and reliable channels, they also require systems that are safe for use for clients
and employees. For that reason, cybersecurity warranted further attention in 2024.
Another core pillar of ING's strategy is putting sustainability at the heart of what we do. The management of
climate and ESG risks is a priority. ING’s focus on climate action and the ‘Terra’ approach were discussion
items. The SB oversees these topics and challenges where necessary. Apart from this, ESG-related matters,
including sustainability and climate risk, are intertwined in many other discussions and topics.
In addition to reviews by the SB of the composition and succession planning of the SB and MBB, the SB also
discussed broader people development and diversity and inclusion matters. This included topics such as the
organisational health within ING and a strategic session on 'Unlocking our people's full potential', which is a
critical enabler of ING's strategy, and should ensure an inclusive culture where everyone has the opportunity
to develop and have impact for ING's customers and society. In the SB’s discussions with HR and MBB, the
focus is on talent and leadership, culture and organisation, including the bank-wide diversity and inclusion
approach, and on operational excellence. Plans to develop, attract and retain diverse talent have been part
of those discussions, as well as gender diversity targets.
The SB discusses and reconfirms all of its members’ outside positions on an annual basis. In addition, it
discusses any intended outside positions and assesses if such positions can be approved while safeguarding
the level of engagement.
ING Bank Annual Report 2024 29

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

> Supervisory Board report
Attendance of SB members
The attendance rates in 2024 of SB members for SB and SB committee meetings, as well as the number of
meetings held, are listed in the following table. The continued high attendance demonstrates that SB
members are engaged with ING and are able to devote sufficient time and attention to overseeing its affairs.

SB attendance 2024 1,2 |  |  |  |  |  |  |
| SB | RiCo 3 | AC | NCGcom 4 | RemCo | ESGcom | T&Ocom
Karl Guha (chairperson) | 11/11 | 6/6 | 7/7 | 11/11 | 7/7 | 4/4 | 3/3
Mike Rees (vice-chairperson) | 11/11 | 6/6 | 6/7 | 11/11 |  |  |
Juan Colombás | 11/11 | 6/6 | 7/7 |  | 4/4 7 | 4/4 | 3/3
Margarete Haase | 11/11 | 6/6 | 7/7 |  | 3/3 7 |  |
Lodewijk Hijmans van den Bergh | 11/11 | 6/6 |  |  |  | 4/4 |
Herman Hulst | 11/11 | 6/6 | 7/7 |  |  | 4/4 |
Harold Naus | 11/11 | 6/6 |  |  | 7/7 |  | 3/3
Alexandra Reich | 11/11 | 6/6 |  |  |  | 4/4 | 3/3
Herna Verhagen 5 | 11/11 |  |  | 11/11 | 7/7 |  |
Total attendance 6 | 100% | 100% | 97% | 100% | 100% | 100% | 100%

1 This SB attendance overview shows the SB (committee) meetings that took place during the year. In addition to these meetings,
there were 10 Restricted SB meetings in 2024 in view of nomination and remuneration matters, with a total attendance rate of 98
percent. These are not shown separately in the overview for year-on-year, like-for-like comparison purposes.
2 Abbreviations used: RiCo = Risk Committee, AC = Audit Committee, NCGcom = Nomination and Corporate Governance Committee,
RemCo = Remuneration Committee, ESGcom = ESG Committee; T&Ocom = Technology & Operations Committee
3 In addition to the six regular RiCo meetings, in 2024, two RiCo meetings were held in combination with the RemCo on remuneration
matters that also required a risk view.
4 In 2024, one NCGcom meeting was held in combination with the RemCo.
5 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 prior
to the meetings to allow them to provide feedback.
7 Margarete Haase replaced Juan Colombás as a member of the RemCo as of 1 July 2024. Their attendance is shown relative to their
tenure.
In addition to the information included in this SB report, information on the SB can be found in ‘Our
leadership’ and ‘Corporate governance’.
SB committee meetings and composition
There are currently six SB committees: the Risk Committee, the Audit Committee, the Nomination and
Corporate Governance Committee, the Remuneration Committee, the ESG Committee and the Technology
and Operations Committee. In general, SB committee meetings take place prior to the SB meetings. The
committees report to the SB on their deliberations and findings, prepare discussion and decision items, and
thereby play a significant role in supporting the SB in its oversight and supervisory activities, allowing it to
operate effectively. As such, all relevant items discussed by the committees were reported to the SB, with
the SB approving those items as required from a governance perspective.
There was frequent interaction between the chairpersons of the relevant SB committees and the members
of the MBB to ensure that everyone was up to date on the most recent developments. Furthermore, the
chairpersons of the Risk Committee and the Audit Committee continued their informal interaction with the
chairpersons of the local risk and audit committees of ING’s five largest subsidiaries to enrich the SB dialogue.
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 reviewed and updated throughout the year for priority-
setting and forward-looking purposes. These plans all feed into the SB’s annual meeting cycle.

Composition of the SB committees on 31 December 2024 |
Supervisory Board | Risk Committee | Audit Committee | Nomination and Corporate Governance Committee | Remuneration Committee | ESG Committee | Technology & Operations Committee
Karl Guha (chairperson) | Member | Member | Chairperson | Member | Member | Member
Mike Rees (vice- chairperson) | Chairperson | Member | Member | — | — | —
Juan Colombás | Member | Member | — | — | Member | Chairperson
Margarete Haase | Member | Chairperson | — | Member | — |
Lodewijk Hijmans van den Bergh | Member | — | — | — | Chairperson | —
Herman Hulst | Member | Member | — | — | Member | —
Harold Naus | Member | — | — | Member | — | Member
Alexandra Reich | Member | — | — | — | Member | Member
Herna Verhagen | — | — | Member | Chairperson | — | —

ING Bank Annual Report 2024 30

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

> Supervisory Board report
Risk Committee
The Risk Committee met eight times in 2024, and two of these meetings were combined with the
Remuneration Committee to address remuneration-related proposals that include risk methodology
elements, such as those relating to the Variable Remuneration Accrual Model (VRAM) (see also
‘Remuneration Committee’). Eight out of the nine SB members are member of the Risk Committee, due to
the continued importance of risk and how this is managed and supervised.
The Risk Committee assists and advises the SB with the performance of its duties in relation to overseeing
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, the effectiveness of the internal risk management and
control systems and other related risk management topics.
At each quarterly Risk Committee meeting financial and model risks, non-financial risks and compliance risks
were discussed. This included the status of ING’s accompanying metrics, such as 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 macroeconomic and geopolitical impact and the
changing interest rate environment on ING’s credit portfolio, capital and liquidity position, and updates on
credit developments in certain countries and portfolios. The non-financial and compliance risk discussions
were supported by updates of the bank-wide KYC enhancement and maturity efforts, a variety of topical
dashboards such as on IT (risk), cybersecurity, sourcing, data quality and data privacy (including GDPR) and
the status of implementation of related regulatory programmes. The Risk Committee also regularly
discussed the status of reported whistleblower concerns, the annual review of the Risk Appetite Framework
and reviewed and discussed the annual update to ING’s Recovery Plan.
Thematic sessions were organised on a variety of topics to focus specifically on themes that needed further
attention and/or are forward looking with respect to emerging risks and developments. Also, five deep dives
were organised for the Risk Committee in 2024 to contribute to a more in-depth understanding of, among
others, ING’s risk models and climate and environmental risk management in ING.
Read more on how ING manages its risks in ‘Risk management’.
Audit Committee
The Audit Committee met seven times in 2024. The Audit Committee assists and advises the SB with the
performance of its duties in relation to the integrity and quality of ING’s financial and non-financial reporting
and the effectiveness of ING’s internal risk management and control systems in relation to financial
reporting.
The Audit Committee addressed, among other things, the following recurring topics:
• Financial reporting, including the interim accounts and the financial statements and the Annual Report;
• Judgmental accounting topics;
• Key audit matters, as included in the auditors’ reports;
• The external auditor’s audit plan, engagement letters, independence reporting and fees;
• The overall internal control environment, the internal controls over financial reporting, the internal and
external auditor reports;
• The internal audit plan and 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; and
• ING’s dividend and distribution policy.
Specific attention was paid to, among other things, the following topics:
• A review of interest rate sensitivity of ING's balance sheet;
• IFRS 9, ESG-disclosures;
• CSDDD and CSRD. These topics were discussed as a combined session with the ESG Committee; and
• Transition process towards the newly appointed external auditor as of reporting year 2026.
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 and the group controller. The chairperson also met with various senior managers.
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.
ING Bank Annual Report 2024 31

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

> Supervisory Board report
Nomination and Corporate Governance Committee
The Nomination and Corporate Governance Committee met 12 times in 2024. The Nomination and
Corporate Governance Committee assists the SB in performing its duties, including the selection and
nomination of members for the SB and MBB, as well as overseeing talent management and the effectiveness
of ING’s governance arrangements.
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 the performance of the individual members of the MBB (also
serving as input to the Remuneration Committee), MBB and SB composition, bench strength and medium- to
long-term succession planning. 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, there are various aspects to take into account
regarding the board composition, such as regulatory requirements, suitability considerations, banking and
other industry knowledge, outside positions, independence, potential conflicts of interest and availability.
Also considered are 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. The generic
profiles of the SB aim to capture these elements. The profiles can be found on ing.com. Find more on the
boards’ composition in the ‘Composition of the Management Board Banking and Supervisory Board’ and in
the 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. 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 feed into the individuals’ coaching and
development plans.
With regard to corporate governance, the Nomination and Corporate Governance Committee discussed
among other things the suitability frameworks and procedures and their global implementation, ING’s
Governance Framework as well as organisational effectiveness, annual updates to the corporate board
charters and ING’s decision structure.
Remuneration Committee
The Remuneration Committee met seven times in 2024. The Remuneration Committee assists the SB with
the performance of its duties in relation to remuneration, the remuneration policies and their application
and compliance. 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 and alignment to shareholder expectations in order to further improve it. In addition, the
Remuneration Committee discussed the progress and performance on the annual targets set for the MBB, the
SB remuneration policy update, SB remuneration matters including the benchmarking results, the identified staff
and high earner-related remuneration matters based on ING’s remuneration governance structure, the variable
remuneration and the application of ING’s accompanying VRAM and updates to ING’s Remuneration Regulations
Framework.
ESG Committee
The ESG Committee was established in 2022 as an ad hoc committee. In 2024, the SB resolved to make the
ESG Committee a permanent committee. The ESG Committee met four times in 2024.
The ESG Committee assists the SB with matters relating to the various areas of ESG, including but not limited
to, the development of ESG and its integration in the company and its strategy and ESG-related disclosures,
reporting and assurance (the latter together with the Audit Committee). In addition, the ESG Committee
assists the SB by monitoring and advising on potential impediments as well as relevant trends and
developments on ‘environmental’, ‘social’ and ‘governance’ topics and how to connect them with ING’s
response, actions and targets on the basis of ING's ESG dashboard.
In 2024, the ESG Committee discussed, among other things ESG strategy updates, ESG dilemmas, progress of
sustainability targets and ING's Climate Progress Update 2024, which explains how ING’s financing impacts
climate change. It includes ING’s progress on steering the most carbon-intensive sectors in its loan portfolio
towards global climate goals (Terra approach) and how ING engages with clients to help them in their
transitions. The ESG Committee monitored this progress.
Given the dynamic and continuously evolving nature of ESG, deep dives were held to contribute to a more in-
depth understanding on certain topics, for example on net-zero housing.
ING Bank Annual Report 2024 32

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

> Supervisory Board report
Technology and Operations Committee
In the second quarter of 2024, the SB established a Technology and Operations Committee. The Technology
and Operations Committee assists the SB in relation to oversight of ING's use of technology. This includes the
technology strategy, major technology initiatives and programmes and other technology and operations
related topics.
The Technology and Operations Committee met three times in 2024 and discussed, among other things the
implementation of the Digital Operational Resilience Act within ING, ING's data centre strategy,
developments around the ING Hubs and ING’s generative artificial intelligence (GenAI) programme and in
particular the use of GenAI within KYC. The Technology and Operations Committee was also provided with an
outside-in view on quantum computing.
Continuous dialogue with stakeholders
The SB acknowledges the responsibility it has in view of ING's role in society to consider and balance the
interests of ING's customers and other stakeholders of ING. It makes sure to take this into account in its
oversight of the delivery on the strategic priorities.
At ING, we seek out open dialogue and maintain continuous interaction with our stakeholders, responding to
their views and concerns, to drive increased collaboration. We aim to strike a balance between the interests
of all stakeholders, including customers, shareholders, employees, regulators, supervisors and society at
large. In 2024, the SB had periodic conversations with various stakeholders, including our clients and
shareholders, employees, supervisors and the MBB. The SB exercised its oversight role, which aimed to
ensure that actions resulting from these conversations were embedded in the organisation and were
followed up effectively. Examples of topics covered in 2024 in this respect are cybersecurity, availability and
reliability of ING's channels, use of generative artificial intelligence, climate risks and other ESG-related
topics.
The dialogue between ING and external supervisors and regulators was a regular agenda item for the SB
throughout the year. This included several discussions between the SB and MBB 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 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.
Permanent education and other knowledge sessions
To further strengthen their knowledge, continuous learning is organised for the SB and MBB in combined
sessions. Board members participate in permanent education sessions to exchange knowledge and
information on a regular basis with ING’s business and external experts. The sessions are aimed at keeping
the board up to date on ING-relevant knowledge, skills and expertise and at increasing the understanding of
and engagement with ING’s business operations and stakeholders.
For 2024, a balance was sought in the specific topics of the sessions in which at least one of the following
elements are covered: (i) outside-in views, (ii) new developments relevant for ING and (iii) ongoing topics
within ING requiring a more in-depth view. Sessions were organised on the following subjects: a range of
strategic topics, market developments, energy transition and climate change, geopolitical updates,
operational resilience and technology related topics including artificial intelligence.
In addition to the permanent education sessions, the SB committees held deep dives which are sessions
tailored to their respective areas of oversight. Deep dives are technical discussions that contribute to a more
in-depth understanding of key topics in the remit of the respective committee.
As part of the annual business visit, the entire SB, together with the MBB, visited the ING locations in Spain
and Italy in September 2024. This visit allowed the board members to get a better understanding of local
clients, business challenges and the country-specific market opportunities, also contributing to a better
mutual understanding and alignment on what matters most to ING and its stakeholders.
The various educational sessions and the business visits provided opportunities for SB members to interact
with senior management, subject-matter experts and local talent.
ING Bank Annual Report 2024 33

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> Supervisory Board report
Management Board Banking and Supervisory Board annual
collective self-evaluation
In 2024 the MBB and SB conducted the annual collective self-evaluation. This was facilitated by an
independent external party and with anonymous input from frequent attendees to the respective MBB and
SB meetings.
Approach
During the October 2024 meetings, the MBB and SB discussed and approved the annual collective self-
evaluation process and design for 2025. In December 2024, input was gathered from the MBB and SB
members and a group of frequent attendees. This, together with the outcome of the 2024 mid-year review,
the bilateral interactions between MBB members and the interaction of the SB chairperson with individual SB
members, formed the basis for the collective MBB and SB self-evaluation dialogue in January 2025. During
this dialogue the MBB and SB determined their collective positive points to maintain and its 2025 priorities for
further improvement. This forms part of the MBB’s and SB’s practice to regularly deliberate on its collective
performance i.e. towards year-end, halfway through the year and at the start of the year.
Results Management Board Banking
The MBB’s collective dialogue centred around the following questions:
1. Positive points: are the positive points previously identified still valid? Where has the MBB further
improved?
2. Priorities to improve: what would be the priority areas the MBB needs to further improve in 2025?
The MBB’s agreed priorities for 2024 included:
1. (i) strategy and performance: when discussing strategy and performance continue to strengthen external
insights and data; and (ii) people and talent: continue focus on attraction, development and retention of
diverse talent to strengthen talent pipelines.
2. (i) consider opportunities to further enhance strategic focus of meeting agendas, managing the volume
of operational reviews, with deep dives on priority areas where needed; (ii) continue to focus on
developing MBB team dynamics; and (iii) continue to prioritise content of meeting agendas.
During 2024, the MBB addressed the above and, where applicable, embedded enhancements in its standard
working practice. Item 1(i) was addressed by bringing enhanced insights into discussions, also in preparation
for Capital Markets Day 2024, and by holding dedicated sessions on key topics (e.g. geopolitics, AI/Gen AI),
which remains a priority for 2025. Item 1(ii) was addressed by significantly increasing focus on talent
management with dedicated sessions, and increased engagement with the SB on talent and succession
planning. Items 2(i) and 2(iii) were addressed by enhanced strategic focus of board agendas and quality of
content. Item 2(ii) was addressed by investing time in team dynamics and effective onboarding of a new
chief technology officer.
Looking ahead, the MBB concluded that several priorities of 2024 are still relevant. Consequently, in 2025 the
MBB will continue to focus its attention on:
• external environment (including threats and opportunities) with specific focus on competition and digital
developments, as well as broader macroeconomic and geopolitical trends;
• customers and relevant developments;
• strategy and growth opportunities, ensuring the organisation has appropriate structure and capacity to
scale; and
• people and talent to enhance bench strength.
The MBB agreed to a number of specific actions for 2025 to contribute to its performance, such as:
1. Strategy and growth: continue to enhance strategic focus of meeting agendas.
2. Education/professional development: dedicated sessions to provide outside-in perspectives, including
technology updates on key topics.
The MBB is of the opinion that the above contributes to ING delivering on its ambitions to keep transforming
in line with the strategy.
Results Supervisory Board
The SB's collective dialogue was centred around the following questions:
1. Positive points: are the positive points previously identified still valid? Where has the SB further improved?
2. Priorities to improve: what would be the priority areas the SB needs to further improve in 2025?
The SB’s agreed priorities for 2024 included:
1. (i) continue to improve the workings and effectiveness of the SB and its committees; and (ii) continue with
the focus on business, market and (geo)political developments as well as stakeholder engagement.
2. (i) further enhance the SB’s effectiveness in ING’s people and talent management process including the
talent pipeline; and (ii) continued attention to succession and composition of the SB, EB and MBB.
ING Bank Annual Report 2024 34

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> Supervisory Board report
The results of the review were positive overall and compared to previous years, various positive points are
still valid. The following points were identified:
• SB effectiveness at overseeing, challenging and advising the EB and MBB;
• SB composition including the interface between the Committees and the SB;
• Effective decision making through SB dialogues and interactions with the EB and MBB;
• Oversight of risk including the monitoring of macroeconomic and geopolitical developments;
• Continued focus on ESG and increased focus on technology; and
• Taking into account the views of key stakeholders.
Compared to previous years, it was concluded that some priorities are still relevant and require further
attention during 2025. The following points were identified:
• Continued focus on key topics with specific attention for strategy, governance, leadership & people,
(geo)political developments and digital & data;
• Continue to improve the workings and effectiveness of the SB and its committees; and
• Further improve the quality of board meeting materials through more focused and concise materials.
Key priorities for the coming year were identified as follows:
• Further deepen the focus on strategy and business performance including customer dimension and the
monitoring of the competitive environment;
• Increase the focus on technology and digitalisation;
• Further enhance SB oversight on governance; and
• Maintain the focus on people and talent including EB/MBB succession planning – with an eye on longer-
term strategy and ING’s ambitions.
Overall, the SB agreed to a number of specific actions for 2025 to contribute to its performance:
1. Enhance the effectiveness of oversight by performing a periodic review of ING’s governance model and
corporate structure.
2. Increase oversight in strategic focus related to technology and digitalisation through its newly formed
Technology & Operations Committee.
3. Deepen the SB’s views on key topics by including additional external insights.
The SB is of the opinion that the above contributes to overseeing and constructively challenging ING in its
strategic ambitions.
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. ING
believes that over 2024 its boards were well composed and balanced. At the 2024 General Meeting, the SB
proposed to shareholders to reappoint Juan Colombás, Herman Hulst and Harold Naus. These proposals
were approved. On 5 August 2024, Daniele Tonella became the Chief Technology Officer of ING Bank N.V. and
a member of the MBB. Daniele Tonella succeeded Marnix van Stiphout who held the role ad interim since 1
November 2023, in addition to his role as Chief Operations Officer.
The Nomination and Corporate Governance Committee and the SB will continue to strive for an adequate
and balanced composition of the SB when selecting and nominating new members for appointment, taking
into account ING’s diversity policy and other factors. Read more in 'Corporate governance' on the
composition of the SB.
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 the extent to which 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 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.
ING Bank Annual Report 2024 35

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> Supervisory Board report

Management Board (MBB)
| Diversity | Competences
Year of birth | Gender | Nationality | Executive experience | International experience | Banking | Finance/audit | Risk | Operations | IT & Cybersecurity | ESG
Steven van Rijswijk CEO | 1970 | Male | Dutch |  |  |  |  |  |  |  |
Tanate Phutrakul CFO | 1965 | Male | Thai |  |  |  |  |  |  |  |
Ljiljana Čortan CRO | 1971 | Female | Croatian |  |  |  |  |  |  |  |
Pinar Abay Head of Retail, Market Leaders and Challengers & Growth Markets | 1977 | Female | Turkish |  |  |  |  |  |  |  |
Andrew Bester Head of Wholesale Banking | 1965 | Male | British/ South African |  |  |  |  |  |  |  |
Marnix van Stiphout Chief operations officer, chief transformation officer | 1970 | Male | Dutch |  |  |  |  |  |  |  |
Daniele Tonella CTO | 1971 | Male | Swiss |  |  |  |  |  |  |  |
Meets the required knowledge/experience criteria for the role and it implies the capacity to take educated decisions on the relevant matters
In addition is considered an expert in relation to previous or current roles

MBB
7
Board Members
6
Nationalities
28%
Female
54
Average age
3.5
Average board
tenure (years)
SB

Supervisory Board
| Diversity | Competences
Year of birth | Gender | Nationality | Executive experience | International experience | Banking | Finance/audit | Risk | Operations | IT & Cybersecurity | ESG
Karl Guha Chairperson | 1964 | Male | Dutch |  |  |  |  |  |  |  |
Mike Rees Vice-chairperson | 1956 | Male | British |  |  |  |  |  |  |  |
Juan Colombás | 1962 | Male | Spanish |  |  |  |  |  |  |  |
Margarete Haase | 1953 | Female | Austrian |  |  |  |  |  |  |  |
Lodewijk Hijmans van den Bergh | 1963 | Male | Dutch |  |  |  |  |  |  |  |
Herman Hulst | 1955 | Male | Dutch |  |  |  |  |  |  |  |
Harold Naus | 1969 | Male | Dutch |  |  |  |  |  |  |  |
Alexandra Reich | 1963 | Female | Austrian |  |  |  |  |  |  |  |
Herna Verhagen | 1966 | Female | Dutch |  |  |  |  |  |  |  |
(*) As defined by the Dutch Corporate Governance Code
Meets required knowledge/experience criteria for the role and it implies the capacity to take educated decisions on the relevant matters
In addition is considered an expert in relation to previous or current roles

100%
Independent
board
members*
9
Board
members
62
Average age
4
Nationalities
4
Average
board tenure
(years)
33%
Female
ING Bank Annual Report 2024 36

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> Supervisory Board report
Appreciation for management and employees
The SB would like to thank the management and the employees for their hard work and collaboration to
drive growth and deliver value for all stakeholders during the year. ING delivered a strong financial
performance in 2024, despite the uncertain economic and volatile geopolitical circumstances.
The business made significant progress with the implementation of the next phase of the strategy, Growing
the difference. The SB would like to express its sincere appreciation to all for their relentless focus and
dedication and its confidence in our collective ability to navigate challenges and seize opportunities in 2025.
Amsterdam, 3 March 2025
ING Bank Annual Report 2024 37

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

Corporate governance
This section comprises ING Bank N.V.’s Corporate Governance
Statement, together with the paragr aph 'U nlocking our people’s full
potential', the below-mentioned booklets and other parts of this Annual
Report to which reference is made in the booklets, comprise the
corporate governance statement ref erred to in section 2a of the Dutch
Decree on information in the management board report (Besluit inhoud
bestuursverslag).
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 (FY2024)’, 6 March 2025, 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
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.
ING's internal controls over financial reporting include 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).
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 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 of
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 2024, three out of nine members of the Supervisory Board were female. ING believes 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 2024 was 56 - 44%.
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 predominantly 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
ING Bank Annual Report 2024 38

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> Corporate governance
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.
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 Group to
set appropriate and ambitious targets for gender diversity in its Executive Board and senior management.
ING Group has given effect to that obligation on behalf of ING Bank. ING Group considers the Management
Board Banking to be part of this senior management 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'.
Relevant positions pursuant to CRD IV
Members of the Management Board Banking may hold other positions, including directorships, either paid or
unpaid. CRD IV restricts the total number of supervisory board positions or non-executive directorships with
predominantly commercial organisations that may be held by a Management Board Banking member to
two. 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.
Information on the members of the Management Board Banking
Reference is made to the Our leadership and corporate governance section for information on the members
of the Management Board Banking, which information is deemed incorporated by reference.
ING Bank Annual Report 2024 39

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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 to 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. 2024 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. 2024 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 2024 of ING Bank 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, 3 March 2025
The Management Board Banking
S.J.A. (Steven) van Rijswijk
CEO, chairperson of the Management Board Banking
T. (Tanate) Phutrakul
CFO
L. (Ljiljana) Čortan
CRO
P. (Pinar) Abay
Head of Retail, Market Leaders and Challengers & Growth Markets
A.J.M. (Andrew) Bester
Head of Wholesale Banking
M.A. (Marnix) Stiphout
Chief operations officer
D. (Daniele) Tonella
Chief technology officer
Capital
management
ING Bank Annual Report 2024 41

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

Capital management
ING's capital management strategy ensures sufficient capital to cover
risks, including economic risks, at all levels and comply with local and
global regulations, while delivering value for our shareholders and to
support the commercial business activities to serve our client needs.
ING’s capital position remained strong despite the uncertain geopolitical
environment. At both the consolidated and entity level, ING has
sufficient buffers to withstand various stressed scenarios.
Capital management strategy
Group Treasury (“GT”) 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 executing
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 takes into account both regulatory and internal, economic-based
metrics and requirements as well as the interests of key stakeholders, such as customers, shareholders and
rating agencies.
ING 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.
• ING's fully loaded CET1 ratio target is built on the CET1 requirements specified for ING, potential increase
in the regulatory requirement of the countercyclical buffer, the potential impact of a standardised and
pre-determined stress scenario and available mitigating actions, and general uncertainties.
• Leverage ratio (LR) is defined as Tier 1 capital divided by the leverage exposure
Processes for managing capital
GT aims to ensure adherence to ING’s solvency risk appetite statements by capital planning and executing
capital management transactions. The ongoing assessment and monitoring of capital adequacy is
embedded in the capital planning process as part of the ICAAP framework. As part of the dynamic business
planning process, ING prepares a capital and funding plan on a regular basis for all its material businesses,
and continuously assesses the timing, need and feasibility for capital management actions in scope of its
execution strategy. Sufficient financial flexibility should be preserved to meet important financial objectives.
Risk appetite statements are at the foundation of the capital plan and are cascaded to the different
businesses in line with ING’s risk management framework. Contingency capital measures and early warning
indicators are in place - in conjunction with ING’s contingency and recovery plan - to support the strategy in
times of stress.
Adverse planning and stress testing, which reflect the outcome of the annual risk assessment, are integral
components of ING’s risk and capital management framework. It allows us to (i) identify and assess potential
vulnerabilities in ING’s business model, business portfolios or operating environment; (ii) understand the
sensitivities of the core assumptions used in ING’s strategic and capital plan; and (iii) improve decision-
making and business steering through balancing risk and return following a forward looking and prudent
management approach.
ING Bank Annual Report 2024 42

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> Capital management
Capital position as per 31 December 2024

ING Bank capital position according to CRR II / CRD V
in € million | 2024 | 2023
Shareholders’ equity 1 | 42,743 | 40,191
- Interim profits not included in CET 1 capital | 0 | -766
- Other adjustments | -2,146 | -1,029
Regulatory adjustments | -2,146 | -1,795
Available common equity Tier 1 capital | 40,597 | 38,396
Additional Tier 1 securities | 7,967 | 6,962
Regulatory adjustments additional Tier 1 | 106 | 86
Available Tier 1 capital | 48,671 | 45,444
Supplementary capital Tier 2 bonds 2 | 9,853 | 9,115
Regulatory adjustments Tier 2 | 81 | 54
Available Total capital | 58,604 | 54,613
Risk weighted assets | 334,770 | 321,358
Common equity Tier 1 ratio | 12.1% | 11.9%
Tier 1 ratio | 14.5% | 14.1%
Total capital ratio | 17.5% | 17.0%

1 Shareholders' equity is determined in accordance with IFRS-EU.
2 All T2 securities are CRR/CRD V-compliant for 2024.
Capital developments
ING Bank’s capital ratios at the end of the year increased compared to 2023 primarily due to higher available
CET1 capital. Risk-weighted assets were mainly impacted by higher volume, currency movements,
improvement in book quality and model impacts.
ING Bank paid €5.0 billion to ING Group, which includes €2.5 billion for additional distribution to shareholders
by ING Group. ING Bank N.V. had a CET1 ratio of 12.1% as of December 2024 versus an overall CET1
requirement (including buffer requirements) of 9.83%. The Bank’s Tier 1 ratio increased from 14.1% to 14.5%
compared to last year. The Banks’s Total capital ratio increased to 17.5%.
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 SREP CET1 requirement (including buffer requirements) for ING Bank N.V. at a consolidated level
was 9.83% at the end of 2024. This requirement is the sum of a 4.5% Pillar I requirement, a 2.5% capital
conservation buffer (CCB), a 0.83% countercyclical buffer (CCyB) and a 2.0% O-SII (Other Systemically
Important Institutions) buffer (based on December 2024 positions). The requirement increased compared to
the end of 2023 (7.50%), mainly due to the inclusion of the O-SII buffer requirement. As of 1 January 2025,
the capital requirement for ING Bank will further increase due to the applicability of the Pillar 2 requirement
(1.65%) following the 2024 SREP decision.
Ratings
ING’s credit ratings and outlook are shown in the table below. Each of these ratings only reflects the view of
the applicable rating agency at the time the rating was issued. Any explanation of the significance of a
rating may be obtained only from the rating agency.

Main credit ratings of ING Bank N.V. at 31 December 2024
| S&P | Moody’s | Fitch
ING Bank N.V. |  |  |
Issuer rating |  |  |
Long-term | A+ | A1 | AA-
Short-term | A-1 | P-1 | F1+
Outlook | Stable | Positive | Stable
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 judgement, circumstances so warrant. ING accepts no responsibility for the
accuracy or reliability of the ratings.
Risk
management
ING Bank Annual Report 2024 44

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

Risk management
As a global financial institution with a strong European base, offering
banking services, ING is exposed to a variety of risks. We manage these
through a comprehensive risk management framework that integrates
risk management into strategic planning and daily business activities.
This aims to safeguard ING’s financial strength and reputation by
promoting the identification, measurement and management of risks at
all levels of the organisation. Taking measured risks aligned with its risk
appetite is core to ING’s business.
This section sets out how ING manages its risks on a day-to-day basis. It explains how the risk management
function is embedded within the organisation based on the ‘three-lines-of-defence’ (3 LoD) model. It
describes the key risks that arise from ING’s business model and how these are managed by dedicated risk
management departments, with specific areas of expertise. The section provides qualitative and quantitative
risk disclosures on solvency, credit, market, funding and liquidity, ESG (environmental, social and
governance), operational, information technology (IT), compliance, model, and business and strategy risks.

| Basis of disclosures (*) The risk management section contains information relating to the nature and extent of the risks of financial instruments as required by International Financial Reporting Standards (IFRS) 7 'Financial Instruments: Disclosures'. These disclosures are an integral part of the ING 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 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. 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 top (already existing) and emerging risks that 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 new or future risk that might challenge ING.
Therefore, these risks require proactive identification and monitoring. The impact on the organisation is
therefore more difficult to assess compared to other risks.
The topics mainly originated from 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 2024 risk assessment confirmed our top and emerging risks. The top risks in 2024 relate to geopolitical
risk, people risk, cybercrime, inflation risk, IT risk, and model risk. Environmental risk remains an emerging
risk, and reflects the impact that climate change may have on ING’s financial position and/or reputation.
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> Risk management
Geopolitical risk
Geopolitical risk is an important concern for ING. Election outcomes in major economies such as the US and
in Europe can lead to policy shifts that impact financial markets, regulatory environments, and trade
relations. Economic growth was generally restrained in 2024, although eurozone growth faced significant
challenges marked by sustained inflation and political instability in major countries. Ongoing conflicts, such
as the war in Ukraine and conflict in the Middle East further heighten uncertainty, often causing market
volatility, disrupting cross-border transactions, and increasing already elevated oil prices.
In 2024, ING conducted ad hoc risk assessments on significant geopolitical events for potential risk
management measures if needed.
International elections
There were an unprecedented number of national elections in 2024, with nearly half of the global population
voting. This surge in electoral activity has led to significant political shifts worldwide, creating both
opportunities and challenges for banks and their clients. These developments are likely to introduce new
economic policies and reshape public policy, impacting trade, immigration, and the climate agenda. In
Europe, particularly in the Netherlands, a broad political shift emerged, reflecting growing support for parties
that could influence future EU policies and regulatory frameworks, including trade agreements and financial
regulation. Meanwhile, political instability in France and Germany further added uncertainty, with potential
implications for policy coordination, economic decision-making, and investor confidence across the region.
Similarly, the outcome of the US elections in November signaled a shift in political power, potentially
affecting for global economic policy, trade relations, and financial markets.
US-EU-China relations and regional tensions
US-China relations face renewed strain as the United States moves to reintroduce tariffs on Chinese imports,
raising concerns over potential retaliatory measures from China. These trade restrictions not only increase
costs for businesses reliant on international supply chain but also risk triggering a cycle of escalating tariffs,
as each side responds with countermeasure. This dynamic can disrupt global trade flows, pressure industries
that depend on cross-border trade, and contribute to broader economic uncertainty.
Beyond tensions between US and China, trade frictions between the US, the EU, and China have also
intensified, with tariffs and regulatory disputes affecting key industries. The US and the EU remain at
disagreement over tariffs on steel, aluminium, and technology products, reflecting broader concerns about
trade imbalances and industrial competitiveness. Simultaneously, the EU is considering imposing tariffs on
Chinese electric vehicles and other industrial goods, citing market distortions and state subsidies. In
response, China has signaled potential countermeasures, adding to uncertainty for global industries reliant
on Chinese manufacturing and export markets.
These economic conflicts are further compounded by regional tensions, particularly in the Asia-Pacific
region. Chinese military exercises near Taiwan and the Philippines have raised regional security concerns,
prompting stronger US commitments to defend Taiwan and strengthen its alliance with the Philippines.
Further tensions may escalate into further financial disconnection between major economies, causing
significant disruption to global economic markets.
Deglobalisation
The period of Western-based liberalisation and globalisation is being challenged by a global trend towards
polarisation and more assertive political policies. The rise of nationalism, protectionism, populist movements
and anti-global sentiments in recent years has created an environment of increasing uncertainty. This could
potentially lead to a reversal or slowdown of globalisation.
The war in Ukraine
The war in Ukraine continued to pose a significant geopolitical risk in 2024. The conflict has intensified, with
Russian forces making advances and Ukraine conducting attacks on Russian territory. This escalation has
heightened concerns among global leaders about sustaining military support, especially in light of potential
policy shifts under the new US administration. The conflict has disrupted energy markets and supply chains,
with an increased risk of further sanctions affecting global trade and increasing operational risk for
businesses with exposure to the region. For further detailed information on sanctions see ‘Compliance risk’.
Exposure in Russia
In March 2022, we announced a decision to no longer do new business with Russian counterparties.
Nevertheless, ING’s remaining operations in Russia and with Russian counterparties are subject to various
risks, including, but not limited to, credit risk, changes in laws and regulations including sanctions and
counter sanctions as well as conflicts of law, potential litigations and deconsolidation events.
In December 2024, ING’s remaining credit exposures to Russian counterparties, booked outside of Russia, is
€1.0 billion (2023: €1.3 billion).
On 28 January 2025, ING announced it had reached an agreement on the sale of its business in Russia to
Global Development JSC, a Russian company owned by a Moscow-based financial investor with a
background in factoring services. This transaction will effectively end ING’s activities in the Russian market.
Under the terms of the agreement, Global Development will acquire all shares of ING Bank (Eurasia) JSC,
taking over all Russian onshore activities and staff. Global Development intends to continue to serve
customers in Russia under a new brand. The transaction, which has been preceded by extensive due
diligence, is subject to various regulatory approvals and is expected to be closed in the third quarter of 2025.
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> Risk management
ING expects a negative P&L impact of around €0.7 billion post tax. This includes an estimated book loss of
around €0.4 billion, representing the difference between the sale price and the book value of the business,
which would have a negative impact of around 5 basis points on ING’s CET1 ratio. It also includes an
estimated negative impact of around €0.3 billion from recycling the currency translation adjustment
through P&L. The latter does not affect CET1 capital.
During 2024 a trend emerged whereby Russian parties are holding Western banks liable in Russian courts.
The Russian parties claim that such banks, by complying with sanctions imposed by the EU, US and other
authorities, have caused damage to the Russian party. There have also been instances where Russian courts
ruled in favour of the Russian party. In these cases, Russian courts did not recognise such sanctions, did not
respect the choice of law and courts pursuant to the applicable contracts, and held Russian subsidiaries of
Western banks liable for acts by other entities in that banking group. For more information on litigation
involving ING, see Note 39 ‘Legal proceedings’.
Exposure in Ukraine
In Ukraine, our credit exposure was approximately €550 million (2023: €600 million), mainly with Central
Bank liquidity facilities and other lending. A significant part is guaranteed by international parents or benefits
from strong collateral.
Middle East tensions
Tensions in the Middle East escalated, specifically between Israel and Iran, leading to significant military
engagements and intensifying the suffering endured by civilians in Gaza and neighbouring areas. Israel
launched retaliatory airstrikes on Iranian military sites, following a series of escalations beginning with the
assassination of key members of militant groups in the Middle East. Meanwhile, Iran, under economic
sanctions, further heightened tensions with its nuclear ambitions. A six-week ceasefire between Israel and
militant group Hamas has provided temporary relief and helped stabilise oil prices, while efforts continue
toward a permanent truce. However, the ceasefire remains fragile as both sides accuse each other of
violations, increasing uncertainty and risk of renewed hostilities. Market volatility, energy price shocks, and
shifting sanction policies continue to pose significant risks for financial institutions and their clients, affecting
operational stability, lending exposure, and regulatory compliance.
People risk
People risk remains as a significant concern for ING in 2024. Competitive pressures, especially in digital and
specialised finance roles, make it challenging to attract and retain top talent. Also, employee concerns on
compensation and benefits are amplified by the rising cost of living, leading to further retention challenges.
Additionally, there is a growing demand for flexible work arrangements and enhanced career development
opportunities, adding to the complexity of managing workforce stability.
Cybercrime risk
Cybercrime risks continue to grow in scope and complexity, driven by geopolitical tensions and technological
advancements. Cybercrime risk was the highest risk in the 2024 risk assessment. As technology evolves, ING
faces increased exposure to cybersecurity threats such as malware, ransomware, and distributed denial of
services (DDoS) attacks. The emergence of generative AI heightens this risk, enabling threat actors to quickly
develop and refine new attack methods. The number of threat actors is also expected to rise as barriers to
entry for cyberattacks decrease.
Vulnerabilities in the cybersecurity of ING’s third-party providers present additional risks. Cyber incidents
impacting these providers could disrupt their ability to deliver critical services for ING.
Regulatory measures such as the EU’s Data Act, Cyber Resilience Act (CRA), and Digital Operational
Resilience Act (DORA) mandate proactive management of cyber, IT, and data-related risks. These measures
require banks to maintain comprehensive frameworks and protocols to ensure resilient hardware and
software infrastructures.
ING mitigates this risk by implementing relevant controls, regularly identifying and monitoring potential
threats. For more details and mitigation actions, see ‘Non-financial risk’.
Inflation risk
Inflation rates continued to moderate globally, prompting major central banks to adjust monetary policies
accordingly. The European Central Bank and the Bank of England implemented rate cuts as inflation
gradually approached target levels, marking a shift from the aggressive tightening cycles seen in previous
years. In the US, the Federal Reserve implemented rate cuts with caution, influenced by mixed economic
signals and the potential impact of the recent presidential election. Political shifts following the election will
most likely add to inflation outlook uncertainty, as new policies could affect trade, taxation, and fiscal
spending. Despite signs of easing, central banks remain cautious, balancing the need to support economic
recovery with the goal of maintaining price stability in a complex environment.
This evolving inflation landscape can significantly influence banks’ credit quality, funding costs and liquidity
premia. Persistent inflation risk can erode borrowers’ debt-servicing capacity, particularly in sectors sensitive
to interest rate changes. Additionally, inflation and resulting volatility in interest rates can affect funding
costs and asset valuations, impacting profitability. Furthermore, persistent inflation uncertainty can elevate
risk premiums, tighten market liquidity, and increase refinancing risks for both public and private borrowers.
IT risk
IT risks stem from potential failures in maintaining and protecting the IT infrastructure. This risk includes
system design flaws, physical damage to data centres, or infrastructure failures, all of which can disrupt
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> Risk management
banking operations and impact service delivery. In Europe, evolving digital transformation regulations such as
DORA mandate strict requirements on IT resilience, requiring banks to ensure that their digital infrastructure
can withstand and recover quickly from operational disruptions. DORA also addresses concentration risk by
requiring rigorous oversight on third-party providers critical to IT operations. Additionally, new AI
developments can enhance the IT landscape, but incorrect usage can lead to serious issues beyond IT.
Model risk
Model risk arises from potential errors in the design, implementation, or use of models that inform critical
decision-making. Estimation errors, incorrect assumptions, and input inaccuracies can lead to unreliable
outputs, affecting risk assessments, financial forecasts, and regulatory compliance. The growing reliance on
AI models, machine learning, and advanced analytics has heightened the complexity of managing this risk,
as these tools require rigorous model validation to ensure accuracy.
Environmental risk
Environmental risk remains one of the most critical concerns the world is facing, impacting ING and the global
economy through regulatory pressures, and the increased frequency and intensity of climate-related events.
Regulatory bodies worldwide have imposed stricter guidelines to disclose and manage environmental impact.
Physical risks from climate change, such as extreme weather events and natural disasters, are intensifying
operational challenges and impacting asset values. Additionally, the world’s growing population and human
behaviour contribute to the loss of biodiversity, adding pressure on environmental stability. These risks also
affect our clients and customers, especially those in high-transition industries and in regions vulnerable to
physical risks. Transition risks, driven by policy, technological or market changes towards a low-carbon
economy, also pose challenges and could potentially lead to stranded assets.
For more details and mitigation actions, see Environmental, social and governance risk’ and ‘Credit risk’.
Risk governance
Effective risk management requires company-wide risk governance. ING’s risk and control structure is based
on the ‘three-lines-of-defence’ model. This model aims to provide a sound governance framework for risk
management by defining and implementing three lines. Each line has a specific role and defined
responsibilities, with the execution of tasks being distinct from the control of these same tasks. The three
lines work closely together to identify, assess, mitigate and monitor risks.
This governance framework is designed in such a way that risk is managed in line with the risk appetite
approved by the MBB, the EB and the SB, and this approach is cascaded throughout ING.
Three lines of defence

| First line of defence |  |  |  |  | Second line of defence |  |  |  |  | Third line of defence |
| Who |  |  | Who |  |  |  |  | Who |
| Heads or their delegates of: banking business, support functions*, geographies, countries Responsible for ▪ Running business with clients and accountable for assessing, controlling, mitigating and reporting all risks affecting their businesses, to ensure risks are within risk appetite, i.e. 1st LoD risk management activities ▪ Completeness and accuracy of the financial statements and risk reports with respect to their areas of responsibility * Although support functions are part of the first line of defence, they provide subject matter expertise to both the first and second line of defence Who COO Responsible for ▪ Setting, operating and maintaining effective and efficient processes and running operations for the bank, and managing risks arising from these activities Who CTO Responsible for ▪ Setting, operating and maintaining an effective and efficient IT architecture and IT services provision for the bank, and managing risks arising from these activities |  |  | Risk including Compliance Responsible for ▪ Overseeing, monitoring, advising and challenging the first line of defence on risk management (including compliance) and have escalation/veto power in relation to activities and decisions that are judged to present unacceptable risks to ING ▪ Setting minimum requirements in terms of quality and quantity of its resources (staff) at group and local level in ING's Risk (including Compliance) function ▪ Articulating and translating the risk appetite into methodologies, frameworks and policies and controlling execution of and adherence to their implementation/ embedding to support and monitor business management's control of risk ▪ Objectively challenging the first line of defence's risk management execution and control process including their reporting of risks and controls ▪ Coordinating the first line of defence's reporting of risks and controls |  |  |  |  | Internal audit function CAS Responsible for ▪ Independent assurance to the MB, the Audit Committee and the SB on the quality and effectiveness of ING's internal control, risk management, governance and implemented systems and processes in both the first and second lines of defence |

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> Risk management
Board-level risk oversight
Both the EB (for ING Group) and the MBB (for ING Bank) play an important role in managing and monitoring
our risk management framework. For more information on the SB and EB duties, powers and responsibilities
in relation to risk management, see ‘Corporate governance’.
Risk committees
The key risk committees described below act within the overall risk policy and delegated authorities granted
by the MBB:
• The Global Credit and Trading Policy Committee (GCTP) discusses and approves policies, methodologies,
and procedures related to credit, trading, country, and reputation (such as environmental and social risk
or ESR) risks. The GCTP meets monthly. After the MBB and the GCTP, the Credit Risk Policy Committee
(CRC) is the highest-level body authorised to discuss and approve models, policies, methodologies, and
procedures related to credit risk.
• The Global Credit Committee – Transaction Approval (GCC(TA)) discusses and approves transactions that
entail taking credit risk (including investment risk), country, legal, and environmental and social risk. The
GCC(TA) meets twice a week.
• The Asset and Liability Committee Bank (ALCO Bank), a finance and risk committee, translates the
strategy into a risk appetite and sets, monitors, and reviews the asset and liability objectives and risk
management framework. Adequate supervision and coordination of asset and liability management is
essential for good risk management and to serve customer and community needs by continued sound
banking business. The MBB has delegated this responsibility to the ALCO Bank. The ALCO Bank meets on a
monthly basis.
• The Bank Non-Financial Risk Committee (Bank NFRC) is accountable for the design and maintenance of
the non-financial risk management framework, including operational risk management, compliance and
legal policies, minimum standards, procedures and guidelines, development of tools, methods, and key
parameters (including major changes) for risk identification, assessment, measurement, mitigating and
monitoring/reporting. NFRC Bank meetings are held on a monthly basis.
• 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.
Further, several other committees are involved in various steps in the different risk management
frameworks, such as:
• The Credit Risk Model Committee (CRMC) can serve as a technical (content-related) adviser to the Credit
Risk Policy Committee (CRC). The CRMC has an approval authority, delegated by the CRC, to approve the
new and continued use for some IRB and IFRS9 models. Additionally, the CRMC has an approval authority,
for the approval, conditional approval and rejection of the new and continued use for some Non-IRB
models.
• The Non-Financial Risk Model Committee (NFR MC) is the dedicated authority for models owned by the
Group NFR function. This responsibility is delegated to the NFR MC partly by the Bank NFRC and partly by
the MoRMC.
• The Market Risk Model Committee (MRMC) is the dedicated authority for the approval of all funding and
liquidity risk, market risk (including banking and trading risk), counterparty credit risk, and business risk
models and parameters for ING Bank within its mandate delegated by ALCO Bank.
• The Valuation Model Committee approves pricing models for trading and banking books.
• 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 a desk level. The FMRC
has delegated authority from ALCO Bank for the management of market risk related to all trading and
banking book activities within Financial Markets (FM).
• The ICLAAP Committee is responsible for the internal capital and liquidity adequacy assessment process
(ICLAAP) and documents, as per the ICLAAP framework. It focuses on technical liquidity documents and
oversees business processes and deliverables concerning the internal liquidity adequacy assessment
process (ILAAP). The ALCO Bank has delegated this responsibility to the ICLAAP committee.
Regional and business unit level
ING’s regional and/or business unit management have primary responsibility for the management of risks
(credit, market, funding and liquidity, operational, IT, compliance and model) that arise in their daily
operations. They are accountable for the implementation and execution of appropriate risk frameworks
affecting their businesses in compliance with procedures and processes at the corporate level. Where
necessary, the implementation is adapted to local requirements.
Organisational structure
The CRO function is organised along the lines of a matrix structure integrating (i) the Global Risk functions, (ii)
the Regional/Country Risk functions at entity level, and (iii) the Risk Segments. Global Risk functions,
organised by risk types into risk domains (departments), are ultimately responsible and accountable for the
functional steering of the respective risk type globally. They ensure a uniform taxonomy and methodology
are used for the setting of the relevant risk appetite levels, further cascading risk appetite into detailed risk
strategies and for the effective monitoring and reporting of risks, on an individual and consolidated basis.
The following organisation chart illustrates the reporting lines in 2024 for the risk management organisation.
The departments in the grey background reflect hierarchical reporting lines, whereas the dotted lines are for
the functional reporting lines:
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> Risk management
Risk management framework
Risk policies, procedures and standards
ING has a system of risk management frameworks, policies, mandatory instructions, procedures and control
standards (hereinafter – internal control documents), which define requirements that are binding for all ING
locations. ING locations shall comply with both internal control documents and local requirements. Internal
control documents are regularly reviewed, updated, and approved in accordance with ING internal control
binding principles. Senior management is responsible for ensuring the implementation of, and staff
adherence to, internal control documents.
Internal control framework
The enterprise risk management (ERM) framework and its related internal control documents constitute the
internal control framework in ING. The ERM framework ensures an ING-wide governance model that aligns
strategy to risk appetite for all risk types. It applies to all business lines and ING locations on the global and
local level. The internal control framework is based on the following principles:
• The ING governance structure follows three lines of defence.
• ING risk appetite stipulates the risk levels ING is willing to accept across all risk types to achieve its
business objectives.
• The ING decision-making process is clear and documented. The decisions are taken in committees and
management bodies in accordance with the ING governance framework. The decision-making process
involves all relevant stakeholders, risk management and compliance.
• Global policies and internal control documents are linked to the ING risk taxonomy. Global policies and
internal control documents are leading. They are cascaded from the Global function to locations after
approval. Where local specific legislation is more stringent, local annexes to global policies are added.
• Processes and controls to mitigate critical and high inherent risks are linked to the relevant policies,
documented and tested.
• Local management are accountable for local implementation of the global policies and processes in line
with the local risk profile. Implementation is challenged by local 2nd LoD and any waivers/deviations from
the global policies and processes must be approved locally and globally.
Risk culture
At ING, we attach great importance to a sound risk culture, which is essential for keeping the bank safe and
secure. We determine our risk culture as the way in which employees identify, understand, discuss and act
on the many financial and non-financial risks we are confronted with every day.
Learning
In 2024, 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 topics covered in 2024 were
GenAI, Competition, Concern reporting, Cybersecurity and Fraud. We continue to update our learning
formats to increase engagement and drive practical application of the knowledge gained by staff. The
curriculum is tracked centrally to monitor timely completion.
In addition to all staff modules, we continue to expand our learning offering on a range of risk topics and for
risk staff. Working with risk experts, the Risk Academy has built role-based learning plans for risk colleagues
that provide a wide selection of learning to support their professional development, including their
knowledge, skills, and behaviours.
Dutch Banker’s Oath
In the Netherlands, all employees are required to take the Banker’s Oath. 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. Before taking the oath, an e-learning and a challenge (discussing dilemmas) are mandatory,
to stress the content and the importance of the oath. It also shows employees the dilemmas they may face
in their daily work, and how to carefully balance the interests of all our stakeholders in the decisions they
make.
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> Risk management
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, see the Capital
Requirements Regulation (CRR) remuneration disclosure published on ing.com.
Risk cycle process
ING identifies, measures and manages risks through five recurrent phases of the management cycle: risk
identification, risk assessment, risk mitigation, risk monitoring and risk reporting.
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
E ach 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 mitigation
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.
Procedure
The RAF procedure explains the setup of the overarching global risk appetite. Within the RAF, ING monitors a
range of financial and non-financial risk metrics, with the aim of keeping 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 metrics and assumptions, is reviewed at least annually so that it remains relevant. The
RAF combines various financial and non-financial risk appetite statements (RAS) into a single, coordinated
approach.
Process
The RAF 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 monthly review in the MBB and quarterly review in the EB and the SB. It is therefore a top-down
process, which bases itself on the ambition of the bank in terms of its risk profile, the regulatory environment
and the economic context. Limits that require SB approval are called boundaries, and the underlying
instruments supporting the boundaries require EB and MBB approval.
Step 1. Identify and assess ING’s key risks
The outcome of the risk-identification and risk-assessment process is used as the starting point for the
review of the RAF. Within this step, the risks ING faces when executing its strategy are identified in the
context of the current economic, political, social, regulatory and technological environment. The assessment
identifies whether the potential impact is material and if it is sufficiently controlled.
Step 2. Set risk appetite framework
Based on ING’s risk assessment and risk purpose, boundaries and instruments for the overarching risk
frameworks are set. Once the overarching risk appetite thresholds have been set and approved by the EB/
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> Risk management
MBB and subsequently by the SB, the statements are translated into risk-type-specific statements and
lower-level risk metrics, which are set and approved by senior risk committees, like ALCO Bank, GCTP, MoRM
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 at ensuring compliance with the overarching solvency, (credit)
concentration, and funding and liquidity RASs.
ING includes climate risk in its RAF by, among other things, introducing climate risk as one of the dimensions
to determine sector concentration as part of the credit risk appetite statements. In the coming years, ING
will extend the inclusion of climate risk impact on other risk types with the aim of ensuring that the potential
risks stemming from, for example, 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. The next graph is an illustrative and non-exhaustive overview of the RAF.
Step 4. Monitor and manage underlying risk limits
To verify that ING remains within the RAF, it reports the risk positions vis-à-vis their limits on a regular basis
to senior management committees. A monthly report is submitted to the MBB reflecting the exposure of ING
against the risk appetite. An extended report is submitted quarterly to the EB and the SB 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 political and geopolitical climate. In addition to assessing P&L, capital and
liquidity positions of ING for a range of different scenarios, idiosyncratic risks are also included. The outcomes
of these stress tests help management get insight into the potential impact, and define actions to mitigate
this potential impact.
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> Risk management
Types of stress tests
Within ING, we perform different types of stress tests. The most comprehensive type of stress tests are the
firm-wide scenario analyses, which involve setting scenario assumptions for all the relevant macroeconomic
and financial market variables in all countries relevant to ING. These assumptions usually follow a qualitative
narrative that provides a background to the scenario. In addition to firm-wide scenario analyses, ING
executes scenario analyses for specific countries or portfolios. Furthermore, sensitivity analyses are
performed, which focus on stressing one or more risk drivers – usually without an underlying scenario
narrative. Finally, ING performs reverse stress tests, which aim to determine scenarios that could lead to a
predefined severe adverse outcome.
Process
ING’s stress-testing process consists of several stages:
• Risk identification and risk assessment: it identifies and assesses the risks ING or the relevant entity is
facing when executing its strategy, based on the current and possible future economic, political,
regulatory and technological environment. It provides a description of the main risks and risk drivers
related to the nature of ING’s business, activities and vulnerabilities.
• Scenario definition and parameterisation: based on the outcome of the previous step, a set of scenarios is
determined with the relevant scope and set of risk drivers for each scenario, as well as its severity, the key
assumptions and input parameters. The output of this phase includes a quantitative description of the
stress scenarios to be analysed, the relevant output metrics and, when applicable, a narrative description.
• Impact calculation and aggregation: based on the quantitative description of the stress scenarios
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 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.
Solvency risk
Introduction
Solvency risk is the risk of lacking sufficient capital to fulfil business objectives, regulatory requirements or
market expectations. An insolvent bank is unable to pay its debts and will be forced into bankruptcy.
The level and quality of capital is crucial for the resilience of individual banks. Banks are expected to assess
the risks they face and, in a forward-looking manner, ensure they identify and manage all material risks.
They must also make sure these risks are sufficiently covered by loss-absorbing capital to provide continuity
if unexpected risks materialise in times of stress. Given the interdependencies with other financial and non-
financial risks, this balancing act of capital adequacy needs to be done within a sound and integrated
management approach. It must coherently link and align all the moving parts of the bank with its long-term
business strategy.
ICAAP framework
ING’s internal capital adequacy assessment process (ICAAP) framework aims to ensure that capital levels
remain adequate – both forward-looking and under adverse conditions, in terms of covering material risks-
to-capital from both a normative and an economic (internal) perspective. The assessment of ING’s capital
adequacy takes into account its business strategy and risk profile, market environment, and operating
macro environment. This implies that views of various stakeholders, such as regulators, shareholders,
investors, rating agencies, clients, and customers play an important role.
The continued strength of ING’s capital position, the adequacy of the financial position, and risk
management effectiveness are essential to achieving the strategy. ING’s capital and funding strategy
determines the underlying ICAAP elements, and thereby contributes to ING’s business continuity from
different perspectives.
Managing ING’s capital entails finding the right balance between supply and demand, while taking into
account market and macro circumstances. The process of balancing these strategic goals is captured in the
ICAAP framework. It is enabled by six building blocks and underlying elements facilitating the ICAAP. The
following building blocks have been defined in the ICAAP framework, which are applied for both the
‘normative’ and ‘economic’ perspective as defined in the ECB guide to ICAAP, published in November 2018:
• Risk identification and assessment;
• Risk appetite;
• Solvency stress testing;
• Planning and forecasting;
• Capital management; and
• Continuity .
ING Bank Annual Report 2024 53

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

> Solvency risk
Risk identification and assessment
ING’s capital management and solvency risk management starts with the risk-identification and risk-
assessment process, which is performed on an annual basis. In addition to this annual process, ING also
reassesses its risks as part of its capital adequacy statement, a quarterly process to assess ING’s capital
adequacy.
Risk appetite
ING has solvency risk appetite statements in place for the following metrics: CET1 ratio, total capital ratio,
leverage ratio, total loss-absorbing capacity (TLAC), and minimum requirement for own funds and eligible
liabilities (MREL) based on RWA/leverage ratio and economic capital adequacy.
Solvency stress testing
Solvency stress testing allows ING to examine the effect of plausible but severe stress scenarios on the
solvency position. It also provides insight into which entities or portfolios are vulnerable to certain types of
risks or scenarios. Solvency stress testing is an important tool in identifying, assessing, measuring, and
controlling risks to capital, providing a complementary and forward-looking perspective to other solvency
risk management tools. For solvency stress testing, ING follows the same steps described in the overall
section on stress testing.
The outcomes of solvency stress test analyses are taken into account in capital planning, but also for setting
risk appetite statements and the capital management buffer.
Planning and forecasting
The capital and funding plan is an integral part of the dynamic plan, ING’s financial and business planning
process. For more information, see section ‘Capital management’.
Capital management
Formulation of the CET1 target is a key element in solvency risk management. The target ratio, based on the
management buffer concept, enables ING’s senior management to steer, benchmark and assess the bank’s
current and future capital levels much more efficiently. The target level clearly supports trust-building
among ING’s key stakeholders (e.g. regulators, investors and customers).
The capital management buffer aims to protect the interests of key stakeholders and plays an important
role in the overall capital adequacy governance. The rationale behind the buffer is that it provides an
additional cushion on top of the (local) regulatory minimum requirements (e.g. supervisory review and
evaluation process (SREP) requirements) to withstand a certain level of stress and facilitate awareness and
preparedness to take management actions. ING reviews its capital management buffer on a regular basis to
determine its effectiveness and robustness, updating it as appropriate. See section ‘Capital management’.
Continuity
Risk events with high severity or significant deteriorations of economic and market conditions beyond ING’s
control could cause deviations from the business and capital plans, which may result in a potential capital
shortfall.
ING has 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
proactively 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 trigger further mitigating action and the
formation of the contingency crisis teams. Further drops in capital levels trigger the alert phase for recovery
monitoring and/or the activation of the recovery plan and corresponding crisis teams.
Assessing capital adequacy: Capital Adequacy Statement
The Capital Adequacy Statement is ING Group’s quarterly assessment of its capital adequacy and 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; and
• The ability to meet internal and external requirements in the case of stressed events or should a risk
materialise.
The Capital Adequacy Statement assesses the adequacy of ING’s capital position in relation to the above-
mentioned drivers and states the extent to which the capital position consequently is considered as
adequate. The Capital Adequacy Statement document is prepared on a quarterly basis. Additionally, each
year the EB/MBB signs and provides a comprehensive assessment of ING’s capital adequacy, supported by
the ICAAP outcomes, in the form of a capital adequacy statement.
ING Bank Annual Report 2024 54

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

Credit risk
Introduction
Credit risk is the risk of loss from the default and/or credit rating deterioration of clients. Credit risks arise in
ING’s lending, financial markets and investment activities. The credit risk section provides information on
how ING measures, monitors and manages credit risk and gives an insight into the portfolio from a credit risk
perspective.
Credit & counterparty risk categories (*)
In the following table the different types of credit and counterparty risk categories are described and a
reconciliation with the notes in the financial statements is also included:

Reconciliation between credit & counterparty risk categories and financial position (*)
Credit risk categories | Notes in the financial statements
Lending risk: The risk that the client (counterparty, corporate or individual) does not pay the principal interest or fees on a loan when they are due, or on demand for letters of credit (LCs) and guarantees provided by ING. | 2 | Cash and balances with central banks
3 | Loans and advances to banks
4 | Financial assets at fair value through profit or loss
5 | Financial assets at fair value through other comprehensive income
7 | Loans and advances to customers
38 | Contingent liabilities and commitments
Investment risk: The credit default and risk rating migration risk that is associated with ING’s investments in bonds, commercial paper, equities, securitisations and other similar publicly traded securities. This can be viewed as the potential loss that ING may incur from holding a position in underlying securities whose issuer's credit quality deteriorates or defaults. | 4 | Financial assets at fair value through profit or loss
5 | Financial assets at fair value through other comprehensive income
6 | Debt securities
Money market risk: This arises when ING places short-term deposits with a counterparty in order to manage excess liquidity. In the event of a counterparty default, ING may lose the deposit placed. | 2 | Cash and balances with central banks
3 | Loans and advances to banks
7 | Loans and advances to customers
Pre-settlement risk: This arises when a client defaults on a transaction before settlement and ING must replace the contract by a trade with another counterparty at the then prevailing (possibly unfavourable) market price. This credit risk category is associated with derivatives transactions (exchange-traded derivatives, over-the-counter (OTC) derivatives and securities financing transactions). | 4 | Financial assets at fair value through profit or loss
14 | Financial liabilities at fair value through profit or loss
37 | Offsetting financial assets and liabilities
Settlement risk: This arises when there is an exchange of value (funds or instruments) and receipt from its counterparty is not verified or expected until after ING has given irrevocable instructions to pay or has paid or delivered its side of the trade. The risk is that ING delivers but does not receive delivery from its counterparty. | 4 | Financial assets at fair value through profit or loss
11 | Other assets
14 | Financial liabilities at fair value through profit or loss
16 | Other liabilities

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

> Credit risk
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 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 and is expressed in quantitative and qualitative
measures.
The credit risk appetite is set at different levels and dimensions within ING. The credit risk appetite framework
specifies the scope and focus of the credit risk which ING takes and the composition of the credit portfolio,
including its concentration and diversification objectives in relation to business lines, locations, sectors and
products. The credit risk appetite framework has also been extended to embed climate risk elements. 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 concentration risk framework is composed of:
• Country risk concentration: Country risk is the risk that arises due to events in a specific country (or
group of countries). To manage the maximum country loss ING is willing to accept, boundaries are
approved by the SB. The estimated level is correlated to the risk rating assigned to a given country. Actual
country limits are set by means of country instruments, which are monitored monthly and updated,
when needed. For countries with elevated levels of geopolitical or severe economic cycle risk, monitoring
is performed on a more frequent basis with strict pipeline and exposure management.
• Single name and secondary risk concentration: ING has an established credit concentration risk
framework to identify, measure and monitor single name concentration including secondary risk. The
same concept of boundaries and instruments is applicable.
• Sector and product concentration risk are managed via the credit risk appetite framework.
Credit risk models (*)
Within ING, internal CRR-compliant models are used to determine probability of default (PD), exposure at
default (EAD) and loss given default (LGD) for regulatory and economic capital purposes. These models also
form the basis of ING’s IFRS 9 loan loss provisioning (see ‘IFRS 9 models’ below).
There are two main types of PD, EAD and LGD models used throughout the bank:
• Statistical models are created where a large set of default or detailed loss data is available. They are
characterised by sufficient data points to facilitate meaningful statistical estimation of the model
parameters. The model parameters are estimated with statistical techniques based on the data set
available.
• Hybrid models are statistical models supplemented with knowledge and experience of experts from risk
management and front-office staff, literature from rating agencies, supervisors and academics. These
models are only used for ‘low default portfolios’, where limited historical defaults exist.
Credit risk rating process (*)
The majority of risk ratings are based on a risk rating (PD) model that complies with the minimum
requirements detailed in CRR/CRD, ECB Supervisory Rules and European Banking Authority (EBA) guidelines.
This concerns all borrower types and segments.
ING’s PD rating models are based on a 1-22 internal risk rating scale (1 = 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 internal risk rating grades are composed of the following categories:
• Investment grade (risk rating 1-10);
• Non-investment grade (risk rating 11-17);
• Performing Restructuring (risk rating 18-19); and
• Non-performing (risk rating 20-22).
The first three categories (1-19) are risk ratings for performing loans. Ratings are calculated in IT systems
with internally developed models, based on manually or automatically fed data, or for part of the non-
performing loans set by the global or regional credit restructuring department. Under certain conditions, the
outcome of a manually fed model can be challenged through a rating appeal process. For securitisation
portfolios, the external ratings of the tranche in which ING has invested are leading indicators.
ING Bank Annual Report 2024 56

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> Credit risk
Risk ratings assigned to clients are reviewed at least annually, with the performance of the underlying
models monitored regularly. Some of these models are global in nature, such as those for large corporates,
commercial banks, insurance companies, central governments, funds, fund managers, project finance and
leveraged companies. Other models are more regional or country-specific: there are PD models for small and
medium enterprises (SMEs) in the Netherlands, Belgium, and Poland as well as residential mortgage and
consumer loan models in the various retail markets.
Rating models for Retail clients are predominantly statistically driven and automated, such that ratings can
be updated on a monthly basis. Rating models for large corporates, institutions and banks include both
statistical characteristics and expert input, with the ratings being manually updated at least annually. More
frequent reviews (e.g. quarterly) are performed where considered necessary.
In line with evolving regulatory expectations on models and emerging industry practices, ING has embarked
on a multi-year redevelopment process of its credit risk models. This is also in line with ING’s model
governance to ensure continuous improvement of models.
Credit risk tools and data standards
The acceptance, maintenance, measurement, management and reporting of credit risks at all levels of ING
are executed through single, common credit risk data standards using shared credit risk tools that support
standardised and transparent credit risk practices. ING has chosen to develop credit risk tools centrally with
the philosophy of using a single source of data in an integrated way.
Credit risk portfolio (*)
ING’s credit exposure is mainly related to lending to individuals (also referred to as consumer lending, all
Retail) and businesses (referred to as business lending, both in Retail and Wholesale), followed by
investments in bonds and securitised assets, and money market (Wholesale). Loans to individuals are mainly
mortgage loans secured by residential property. Loans (including guarantees issued) to businesses are often
collateralised, but may be unsecured based on the internal analysis of the borrower’s creditworthiness.
Bonds in the investment portfolio are generally unsecured, but predominantly consist of bonds issued by
central governments and EU and/or OECD-based financial institutions. Secured bonds, such as mortgage-
backed securities and asset-backed securities are secured by the underlying diversified pool of assets
(commercial or residential mortgages, car loans and/or other assets) held by the securities issuer. For money
market, exposure is mainly deposits to central banks. The last major credit risk source involves pre-
settlement exposures which arise from trading activities, including derivatives, repurchase transactions and
securities lending/borrowing transactions. This is also commonly referred to as counterparty credit risk.
Overall portfolio (*)
During 2024, ING’s portfolio size increased by €30.3 billion (3.2%) to €961.9 billion outstanding. Foreign
exchange rate changes had a positive impact on the portfolio growth, mainly in WB, increasing total
outstanding by €8.0 billion, driven by the appreciation of the US dollar against the euro. Retail banking
increased by €18.9 billion mainly due to underlying growth in residential mortgages.
Rating distribution (*)
Overall, the rating class distribution remained stable in 2024. The share of investment grade rating classes
increased from 76.8% to 78.1%, while the share of non-investment grade decreased from 21.2% to 19.9%.
Performing restructuring outstandings decreased from 0.7% to 0.6% of the total portfolio, whereas non-
performing loans increased from 1.3% to 1.4%.
With respect to the rating distribution within the business lines, in WB, investment grade increased to 83.7%
from 81.2%, while non-investment grade exposures decreased to 14.6% from 17.1% compared to 2023.
Performing restructuring assets decreased from 0.7% to 0.6% of total Wholesale Banking assets where non-
performing loans for WB increased from 1.0% to 1.2%. The non-performing loans (NPL) increase in
Wholesale Banking is mainly caused by Russian exposures as well as a few large NPLs that are unrelated in
terms of asset class, sector or geography.
For Retail Banking, investment grade increased to 73.3% from 73.0%, while non-investment grade exposures
decreased to 24.4% from 24.9% as compared to 2023. Performing restructuring increased to 0.7% from 0.6%
whereas NPL remained constant at 1.5% in 2024.
Industry (*)
The industry breakdown is presented in accordance with the NAICS definition. The increase of €30.3 billion in
total volume during 2024 was mainly due to the increase in Private Individuals (€18.4 billion), Non-Bank
Financial Institutions (€8.8 billion) and Commercial Banks (€5.2 billion). The share of Private Individuals
increased from 38.8% last year to 39.5%.
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Contents |  | Strategy |  | Our financial performance |  | Our leadership and corporate governance |  | Capital management |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information and appendices

> Credit risk
Portfolio analysis per business line (*)

Outstandings per line of business (*)1, 2, 3
in EUR million | Wholesale Banking | Retail Banking | Corporate line | Total
Rating class | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Investment grade | 1 (AAA) | 53,363 | 52,716 | 29,151 | 34,683 | 1,790 | 2,284 | 84,304 | 89,682
2-4 (AA) | 72,462 | 67,034 | 63,187 | 59,655 | 4 | 6 | 135,653 | 126,694
5-7 (A) | 101,831 | 95,320 | 140,479 | 132,076 | 157 | 147 | 242,467 | 227,543
8-10 (BBB) | 129,429 | 123,081 | 155,375 | 146,295 | 3,452 | 2,357 | 288,256 | 271,733
Non-investment grade | 11-13 (BB) | 53,757 | 57,348 | 94,753 | 94,408 |  |  | 148,510 | 151,756
14-16 (B) | 7,396 | 12,234 | 31,165 | 29,330 |  |  | 38,561 | 41,565
17 (CCC) | 1,037 | 1,122 | 3,345 | 3,113 | 170 | 196 | 4,552 | 4,431
Performing Restructuring loans | 18 (CC) | 1,792 | 2,523 | 2,001 | 1,957 |  |  | 3,794 | 4,481
19 (C) | 560 | 535 | 1,760 | 1,313 |  |  | 2,320 | 1,848
Non-performing loans | 20-22 (D) | 5,204 | 4,051 | 8,100 | 7,622 |  |  | 13,303 | 11,673
Total | 426,832 | 415,965 | 529,317 | 510,452 | 5,572 | 4,989 | 961,720 | 931,406
Industry |  |  |  |  |  |  |  |  |
Private Individuals |  | 2,116 | 2,330 | 377,712 | 359,057 |  |  | 379,827 | 361,387
Central Banks |  | 61,091 | 70,139 | 15,044 | 21,740 | 1,785 | 2,269 | 77,919 | 94,147
Natural Resources |  | 39,974 | 40,511 | 1,925 | 1,883 |  |  | 41,899 | 42,394
Real Estate |  | 24,643 | 24,904 | 28,738 | 26,611 |  |  | 53,381 | 51,515
Commercial Banks |  | 41,027 | 37,393 | 6,662 | 6,183 | 3,619 | 2,515 | 51,308 | 46,091
Non-Bank Financial Institutions |  | 64,217 | 55,313 | 2,212 | 2,290 | 79 | 89 | 66,509 | 57,692
Central Governments |  | 48,389 | 45,316 | 8,107 | 7,304 | 1 | 1 | 56,497 | 52,621
Transportation & Logistics |  | 27,499 | 27,106 | 6,037 | 5,784 |  |  | 33,536 | 32,890
Utilities |  | 25,517 | 23,324 | 2,196 | 2,184 |  |  | 27,713 | 25,509
Food, Beverages & Personal Care |  | 13,827 | 13,503 | 10,419 | 9,883 |  |  | 24,246 | 23,386
Services |  | 8,844 | 9,128 | 13,442 | 12,872 | 27 | 24 | 22,312 | 22,023
General Industries |  | 10,512 | 12,039 | 8,812 | 9,086 |  |  | 19,324 | 21,126
Lower Public Administration |  | 6,959 | 6,211 | 19,598 | 17,493 |  |  | 26,557 | 23,704
Other | 52,218 | 48,748 | 28,412 | 28,082 | 62 | 92 | 80,691 | 76,922
Total | 426,832 | 415,965 | 529,317 | 510,452 | 5,572 | 4,989 | 961,720 | 931,406

ING Bank Annual Report 2024 58

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> Credit risk

Outstandings per line of business (*) - continued 1, 2, 3
in EUR million | Wholesale Banking | Retail Banking | Corporate line | Total
Region | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Europe | Netherlands | 44,486 | 54,989 | 164,590 | 156,182 | 1,906 | 2,366 | 210,981 | 213,537
Belgium | 26,506 | 24,171 | 95,584 | 91,744 | 0 | 7 | 122,091 | 115,921
Germany | 27,443 | 26,152 | 128,598 | 128,885 | 30 | 31 | 156,071 | 155,067
Poland | 21,190 | 20,346 | 30,946 | 28,971 | 0 | 0 | 52,136 | 49,317
Spain | 11,990 | 11,047 | 28,507 | 27,158 | 36 | 35 | 40,533 | 38,240
United Kingdom | 28,257 | 28,587 | 265 | 275 | 91 | 112 | 28,613 | 28,974
Luxembourg | 26,176 | 23,805 | 5,139 | 5,557 | 0 | 0 | 31,314 | 29,363
France | 24,351 | 21,528 | 3,122 | 3,108 | 3 | 14 | 27,476 | 24,650
Rest of Europe | 72,860 | 65,157 | 23,203 | 20,368 | 14 | 32 | 96,076 | 85,558
America | 86,402 | 78,851 | 2,402 | 2,042 | 22 | 25 | 88,827 | 80,917
Asia | 44,136 | 49,851 | 215 | 159 | 3,464 | 2,365 | 47,815 | 52,374
Australia | 10,887 | 9,409 | 46,723 | 45,977 | 8 | 2 | 57,618 | 55,389
Africa | 2,148 | 2,071 | 22 | 26 | 0 | 0 | 2,170 | 2,098
Total | 426,832 | 415,965 | 529,317 | 510,452 | 5,572 | 4,989 | 961,720 | 931,406

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.
Portfolio analysis per geographical area (*)
The portfolio analysis per geographical area re-emphasises the international distribution of ING’s credit
portfolio. The Netherlands maintains the largest portfolio share in a single country with 21.9% (2023: 22.9%)
of the total amount, followed by Germany with 16.2% (2023: 16.6%) and Belgium with 12.7% (2023: 12.4%).
In terms of region, the majority of the portfolio balance remained in Europe with 80% (2023: 79%), followed
by Americas with 9.3% (2023: 8.7%) and Australia with 6.0% (2023: 5.9%). The top five countries within Rest
of Europe based on outstandings were Italy (€20.7 billion), Switzerland (€16.4 billion), Romania (€12.4 billion),
Türkiye (€8.6 billion) and Ireland (€4.8 billion).
The main contributors for the overall increase in outstanding are Americas (+€7.9 billion), Belgium
(+€6.2 billion), Poland (+€2.8 billion) and France (+€2.8 billion).
Private Individuals remained the largest composition of portfolio balances for the Netherlands at 58.3%
(2023: 54.6%), Belgium at 37.4% (2023: 38.5%), Germany at 68.8% (2023: 66.5%) and Australia at 66.1%
(2023: 65.6%). The decrease in Central Banks is mainly attributed to the Netherlands (€8.5 billion explaining
the decrease in WB Netherlands outstanding), Germany (€5.0 billion) and Asia (€4.1 billion).
In individual countries, the total share of investment grade/non-investment grade remains substantial for
the Netherlands at 98.5% (2023: 98.6%), Germany at 98.9% (2023: 99.1%) and in Belgium 96.6% (2023:
96.6%).
In Europe, the increase in investment grade was mainly witnessed in Poland (+€4.3 billion), France
(+€3.2 billion), Spain (+€3.2 billion), Belgium (+€3.2 billion) and Luxembourg (+€3.2 billion). Non-investment
grade decreased in the Netherlands (-€2.7 billion), Poland (-€1.8 billion), Luxembourg (-€1.2 billion) and Spain
(-€1.0 billion).
ING Bank Annual Report 2024 59

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> Credit risk

Outstandings by economic sectors and geographical area (*) 1
in EUR million | Region | Total
Industry | Netherlands | Belgium | Germany | Poland | Spain | United Kingdom | Luxembourg | France | Rest of Europe | America | Asia | Australia | Africa | 2024
Private Individuals | 122,914 | 45,611 | 107,415 | 16,525 | 27,083 | 122 | 3,058 | 2,260 | 16,391 | 198 | 129 | 38,106 | 16 | 379,827
Central Banks | 22,529 | 10,196 | 13,966 | 1,729 | 510 | 1,935 | 5,737 | 0 | 10,913 | 0 | 9,525 | 879 | 0 | 77,919
Natural Resources | 2,197 | 1,531 | 881 | 778 | 152 | 3,021 | 2,503 | 405 | 11,212 | 8,475 | 8,989 | 1,593 | 159 | 41,899
Real Estate | 16,749 | 13,387 | 1,218 | 2,085 | 1,595 | 552 | 3,446 | 2,713 | 3,707 | 3,220 | 1,066 | 3,642 | 0 | 53,381
Commercial Banks | 1,353 | 314 | 4,129 | 695 | 376 | 4,733 | 5,268 | 5,074 | 7,779 | 10,700 | 9,394 | 1,336 | 157 | 51,308
Non-Bank Financial Institutions | 2,872 | 1,766 | 5,147 | 2,874 | 249 | 8,479 | 6,031 | 5,932 | 5,174 | 23,157 | 3,518 | 1,255 | 55 | 66,509
Central Governments | 1,416 | 11,009 | 51 | 9,435 | 5,308 | 48 | 82 | 3,202 | 9,203 | 15,377 | 288 | 488 | 589 | 56,497
Transportation & Logistics | 4,290 | 2,076 | 1,426 | 1,623 | 679 | 2,262 | 828 | 765 | 7,407 | 3,983 | 6,912 | 504 | 781 | 33,536
Utilities | 1,805 | 1,843 | 3,920 | 814 | 1,971 | 2,826 | 395 | 712 | 3,951 | 5,886 | 1,187 | 2,253 | 152 | 27,713
Food, Beverages & Personal Care | 7,377 | 3,690 | 695 | 2,215 | 351 | 328 | 1,393 | 1,102 | 3,008 | 2,498 | 1,168 | 406 | 14 | 24,246
Services | 4,919 | 8,431 | 1,852 | 1,538 | 122 | 869 | 540 | 310 | 1,271 | 1,265 | 516 | 680 | 0 | 22,312
General Industries | 4,568 | 2,690 | 1,059 | 2,824 | 219 | 301 | 539 | 484 | 3,862 | 2,039 | 708 | 23 | 8 | 19,324
Lower Public Administration | 782 | 6,824 | 7,435 | 608 | 557 | 0 | 246 | 3,091 | 476 | 1,554 | 44 | 4,941 | 0 | 26,557
Other | 17,208 | 12,722 | 6,876 | 8,394 | 1,361 | 3,137 | 1,248 | 1,426 | 11,722 | 10,475 | 4,372 | 1,513 | 238 | 80,691
Total | 210,981 | 122,091 | 156,071 | 52,136 | 40,533 | 28,613 | 31,314 | 27,476 | 96,076 | 88,827 | 47,815 | 57,618 | 2,170 | 961,720
Rating class |  |  |  |  |  |  |  |  |  |  |  |  |  |
Investment grade | 170,161 | 74,882 | 136,096 | 36,029 | 32,741 | 23,844 | 27,235 | 21,886 | 67,110 | 72,476 | 41,203 | 46,959 | 59 | 750,680
Non-Investment grade | 37,689 | 43,059 | 18,238 | 13,948 | 7,126 | 4,388 | 3,858 | 5,229 | 25,679 | 14,763 | 5,859 | 9,889 | 1,898 | 191,623
Performing restructuring | 1,579 | 1,078 | 305 | 701 | 234 | 59 | 56 | 54 | 1,369 | 443 | 30 | 203 | 4 | 6,114
Non-performing loans | 1,552 | 3,071 | 1,432 | 1,458 | 432 | 322 | 166 | 307 | 1,918 | 1,145 | 723 | 568 | 210 | 13,303
Total | 210,981 | 122,091 | 156,071 | 52,136 | 40,533 | 28,613 | 31,314 | 27,476 | 96,076 | 88,827 | 47,815 | 57,618 | 2,170 | 961,720
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

Outstandings by economic sectors and geographical area (*) 1
in EUR million | Region | Total
Industry | Netherlands | Belgium | Germany | Poland | Spain | United Kingdom | Luxembourg | France | Rest of Europe | America | Asia | Australia | Africa | 2023
Private Individuals | 116,530 | 44,637 | 103,151 | 14,860 | 25,452 | 128 | 3,347 | 2,472 | 14,179 | 149 | 121 | 36,340 | 20 | 361,387
Central Banks | 31,017 | 9,756 | 18,945 | 2,530 | 489 | 4,335 | 4,853 |  | 6,166 |  | 13,668 | 2,379 | 9 | 94,147
Natural Resources | 2,623 | 1,346 | 1,017 | 685 | 129 | 3,789 | 2,511 | 429 | 10,608 | 8,237 | 9,785 | 941 | 295 | 42,394
Real Estate | 16,907 | 10,986 | 1,111 | 2,184 | 1,551 | 420 | 3,563 | 2,901 | 3,492 | 3,323 | 1,367 | 3,709 |  | 51,515
Commercial Banks | 1,268 | 404 | 4,050 | 601 | 353 | 4,488 | 5,070 | 4,155 | 6,757 | 9,833 | 8,182 | 719 | 210 | 46,091
Non-Bank Financial Institutions | 2,573 | 1,457 | 5,710 | 2,532 | 652 | 6,837 | 4,631 | 4,274 | 4,269 | 19,921 | 3,884 | 950 |  | 57,692
Central Governments | 1,620 | 9,046 | 699 | 8,614 | 5,491 | 41 | 79 | 2,255 | 9,384 | 13,752 | 520 | 526 | 593 | 52,621
Transportation & Logistics | 3,860 | 2,198 | 1,277 | 1,598 | 658 | 2,113 | 596 | 784 | 8,177 | 3,511 | 7,044 | 456 | 618 | 32,890
Utilities | 2,419 | 1,634 | 3,516 | 792 | 912 | 2,723 | 480 | 619 | 4,469 | 4,424 | 1,306 | 2,041 | 173 | 25,509
Food, Beverages & Personal Care | 7,138 | 3,127 | 550 | 2,242 | 490 | 540 | 1,505 | 1,250 | 2,455 | 2,652 | 1,140 | 281 | 18 | 23,386
Services | 5,073 | 8,463 | 1,725 | 1,325 | 71 | 745 | 502 | 380 | 1,052 | 1,576 | 469 | 642 |  | 22,023
General Industries | 5,746 | 2,604 | 1,193 | 2,827 | 333 | 199 | 649 | 287 | 3,661 | 2,848 | 761 | 18 |  | 21,126
Lower Public Administration | 253 | 6,607 | 5,349 | 669 | 350 | 0 | 249 | 3,488 | 356 | 1,550 | 7 | 4,826 |  | 23,704
Other | 16,510 | 13,657 | 6,774 | 7,858 | 1,309 | 2,615 | 1,326 | 1,356 | 10,532 | 9,141 | 4,120 | 1,562 | 163 | 76,922
Total | 213,537 | 115,921 | 155,067 | 49,317 | 38,240 | 28,974 | 29,363 | 24,650 | 85,558 | 80,917 | 52,374 | 55,389 | 2,098 | 931,406
Rating class |  |  |  |  |  |  |  |  |  |  |  |  |  |
Investment grade | 170,118 | 71,730 | 136,675 | 31,772 | 29,583 | 24,299 | 24,083 | 18,692 | 56,404 | 63,652 | 44,481 | 44,139 | 24 | 715,653
Non-Investment grade | 40,399 | 40,236 | 16,929 | 15,785 | 8,134 | 4,508 | 5,013 | 5,713 | 25,967 | 15,806 | 6,769 | 10,715 | 1,776 | 197,751
Performing restructuring | 1,433 | 799 | 349 | 830 | 230 | 2 | 105 | 122 | 1,983 | 245 | 72 | 132 | 26 | 6,328
Non-performing loans | 1,587 | 3,155 | 1,114 | 929 | 293 | 165 | 162 | 124 | 1,205 | 1,213 | 1,051 | 403 | 272 | 11,673
Total | 213,537 | 115,921 | 155,067 | 49,317 | 38,240 | 28,974 | 29,363 | 24,650 | 85,558 | 80,917 | 52,373 | 55,389 | 2,098 | 931,406

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
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 of ensuring consistent application
within ING. These also require that the value of the cover is monitored on a regular basis. Covers are revalued
periodically and whenever there is reason to believe that the market is subject to significant changes in
conditions. The frequency of monitoring and revaluation depends on the type of cover.
The valuation method also depends on the type of covers. For asset collateral, the valuation sources can be
the customer’s balance sheet (e.g. inventory, machinery and equipment), nominal value (e.g. cash and
receivables), market value (e.g. securities and commodities), independent valuations (e.g. commercial real
estate) and market indices (e.g. residential real estate). For third-party obligations, the valuation is based on
the value that is attributed to the contract between ING and that third party.
Where collateral values are used in the calculation of Stage 3 individual loan loss provisions, haircuts may be
applied to the valuation in specific circumstances, to sufficiently include all relevant factors impacting future
cash flows. ING applies haircuts to the collateral values of real estate, shipping and aviation assets that are
used in the calculation of the loss-given-default in recovery scenarios. The haircut reflects the risks of
adverse price developments between the moment of valuation of an asset and the actual settlement/cash
receipt.
Cover values (*)
This section provides insight into the types of cover and the extent to which exposures benefit from collateral
or guarantees. The disclosure differentiates between risk categories (lending, investment, money market
and pre-settlement). The most relevant types of cover include mortgages, financial collateral (cash and
securities), guarantees and other covers (mainly pledges). ING obtains covers that are eligible for credit risk
mitigation under CRR/CRDIV, as well as covers that are 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.
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> Credit risk

Cover values including guarantees received (*)
in EUR million |  | Cover type and value | Collateralisation
2024 | Outstandings | Mortgages | Financial Collateral | Guarantees | Other covers | No cover | Partially covered | Fully covered
Consumer lending | 378,832 | 865,466 | 6,257 | 25,428 | 55,115 | 6.5% | 2.0% | 91.5%
Business lending | 368,424 | 163,143 | 24,838 | 119,410 | 484,148 | 34.0% | 23.7% | 42.3%
Investment and money market | 153,495 | 0 | 0 | 1,115 | 95 | 99.3% | —% | 0.7%
Total lending, investment and money market | 900,752 | 1,028,609 | 31,095 | 145,953 | 539,357 | 33.6% | 10.5% | 55.9%
of which NPL | 13,295 | 10,427 | 194 | 3,093 | 11,109 | 27.6% | 27.7% | 44.7%
Pre-settlement | 60,968 |  |  |  |  |  |  |
Total Bank | 961,720 |  |  |  |  |  |  |

Cover values including guarantees received (*)
in EUR million |  | Cover type and value | Collateralisation
2023 | Outstandings | Mortgages | Financial Collateral | Guarantees | Other covers | No cover | Partially covered | Fully covered
Consumer lending | 360,124 | 804,994 | 22,401 | 25,269 | 29,070 | 6.2% | 2.0% | 91.8%
Business lending | 363,680 | 162,491 | 26,333 | 115,944 | 428,531 | 35.2% | 22.5% | 42.3%
Investment and money market | 158,506 |  | — | 1,040 | 549 | 99.0% | 0.6% | 0.4%
Total lending, investment and money market | 882,309 | 967,485 | 48,735 | 142,252 | 458,149 | 34.8% | 10.2% | 55.0%
of which NPL | 11,653 | 8,880 | 1,609 | 3,204 | 9,241 | 25.7% | 26.9% | 47.4%
Pre-settlement | 49,096 |  |  |  |  |  |  |
Total Bank | 931,406 |  |  |  |  |  |  |

The above tables gives an overview of the collateralisation of ING’s total portfolio. Excluding the pre-
settlement portfolio, 55.9% (2023: 55.0%) of ING’s outstandings were fully collateralised in 2024. Since
investments traditionally do not require covers, the ‘no covers’ percentage in this portfolio is over 99%.
Consumer lending portfolio (*)
The consumer lending portfolio accounts for 39.4% (2023: 38.7%) 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 (34.6%), Germany (27.5%), Belgium including Luxembourg (12.8%) and Australia (10.8%).
Note that the large increase in Other covers and decrease in Financial Collateral is related to a
reclassification of certain cover types.
Business lending portfolio (*)
Business lending accounts for 38.3% (2023: 39.1%) of ING’s total outstanding. Business lending presented in
this section does not include pre-settlement, investment and money market exposures.
ING Bank Annual Report 2024 63

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> Credit risk
Credit quality (*)
I NG uses three distinct statuses to categorise the management of clients with (perceived) deteriorating
credit risk profiles. ING usually classifies a client first with a “watch list” status 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. Furthermore, ING makes use of Early Warning
Indicators (EWIs) in daily credit risk management processes in non-Retail portfolios which relate to a change
in (internal and/or external) circumstances or outlook of the specific Obligor, the sector or portfolio. Some
clients with a watch list or EWI status may develop into a performing restructuring status (performing loans
that hold a reasonable probability that ING will end up with a loss, if no specific action is taken) or a non-
performing status.
When there is increasing doubt as to the performance and the collectability of the client’s contractual
obligations the loans are managed by Global Credit Restructuring (GCR) or by restructuring units in the
various regions and business units. The statuses and links with rating grades are illustrated in the table
below.

Credit risk ratings
Internal Rating Grade | 1-10 | 11-17 | 18-19 | 20-22
Category | Investment Grade | Non-Investment Grade | Performing Restructuring | Non-Performing
Credit risk management | Regular incl EWI/ Watchlist | Regular incl EWI/ Watchlist | Credit restructuring | Credit restructuring
ECL Stage | 1/2 1 | 1/2 1 | 2 | 3
1 Stage 2 in case one of the Stage 2 triggers is hit, where Watchlist files are always Stage 2

Credit quality outstandings (*)
in EUR million | 2024 | 2023
Performing not past due | 823,336 | 795,796
Business lending performing past due | 9,174 | 8,825
Consumer lending performing past due | 802 | 846
Non-performing | 13,295 | 11,653
Total lending and investment | 846,607 | 817,120
Money market | 54,145 | 65,189
Pre-settlement | 60,968 | 49,096
Total | 961,720 | 931,406

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> Credit risk
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 customers, ING aims to solve the (potential) financial difficulties by
offering a range of measures (e.g. payment arrangements, restructuring). If the issues cannot be resolved,
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.
The table below represents the breakdown of lending and investment credit risk outstandings that are
performing by age and geographic area.

Ageing analysis (past due but performing): Consumer lending portfolio by geographic area, outstandings (*)
in EUR million | 2024 | 2023
Region | Past due for 1–30 days | Past due for 31–60 days | Past due for 61–90 days | Total | Past due for 1–30 days | Past due for 31–60 days | Past due or 61–90 days | Total
Europe | Belgium | 185 | 49 | 29 | 263 | 223 | 43 | 29 | 295
Germany | 65 | 37 | 24 | 125 | 89 | 40 | 18 | 147
Poland | 61 | 9 | 4 | 74 | 76 | 8 | 5 | 89
Netherlands | 62 | 35 | 4 | 101 | 67 | 24 | 6 | 97
Luxembourg | 22 | 6 | 3 | 32 | 21 | 2 | 2 | 25
Spain | 12 | 16 | 8 | 36 | 19 | 13 | 6 | 38
Rest of Europe | 93 | 15 | 4 | 112 | 64 | 19 | 11 | 94
America | 0 | 0 | 0 | 1 | 1 | 0 | 0 | 1
Asia | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 1
Australia | 38 | 19 | 2 | 59 | 43 | 15 | 1 | 59
Africa | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0
Total | 538 | 186 | 78 | 802 | 602 | 164 | 79 | 846

The past due but performing consumer lending outstanding decreased by €44 million, due to a decrease in
1-30 days (-€64 million) which was partially offset by an increase in 31-60 (+€22 million). The largest
decrease was observed in Belgium (-€32 million) and Germany (-€22 million), mainly in the 1-30 days
bucket. The largest increase was seen in Rest of Europe (+€18 million).
ING Bank Annual Report 2024 65

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> Credit risk

Ageing analysis (past due but performing): Business lending portfolio by geographic area, outstandings (*)
in EUR million | 2024 | 2023
Region | Past due for 1–30 days | Past due for 31–60 days | Past due for 61–90 days | Total | Past due for 1–30 days | Past due for 31–60 days | Past due for 61–90 days | Total
Europe | Belgium | 1,187 | 17 | 13 | 1,217 | 929 | 98 | 11 | 1,037
United Kingdom | 830 | 8 |  | 838 | 623 | 659 | 128 | 1,410
Luxembourg | 367 | 51 | 5 | 423 | 577 | 8 | 11 | 596
Netherlands | 929 | 14 |  | 943 | 509 | 10 | 12 | 531
Poland | 173 | 17 | 19 | 209 | 346 | 26 | 10 | 383
Spain | 26 |  |  | 26 |  |  |  |
France | 194 |  |  | 194 | 58 | 132 |  | 190
Germany | 215 | 3 | 2 | 220 | 131 | 110 | 1 | 242
Rest of Europe | 630 | 4 | 46 | 681 | 972 | 2 | 2 | 977
America | 3,504 | 95 |  | 3,599 | 2,508 | 101 | 41 | 2,650
Asia | 310 |  |  | 310 | 284 |  | 22 | 306
Australia | 469 | 6 |  | 475 | 501 | 1 |  | 502
Africa | 39 |  |  | 39 |  |  |  |
Total | 8,873 | 215 | 86 | 9,174 | 7,437 | 1,148 | 240 | 8,825

Total past due but performing outstanding of business lending increased by €0.3 billion. Increase was
witnessed in the 1–30 days past due bucket (€1.4 billion) which was offset by the decrease observed in the
31-60 days (-€0.9 billion) and 61-90 days (-€0.2 billion) past due buckets. The largest increase was in the
Americas (€0.9 billion) while the largest decrease was in the United Kingdom (-€0.6 billion).
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. The aim is to maximise the client’s repayment
ability, thereby avoiding a default situation, or help the client to return to a performing situation.
For ING Retail units, clear criteria have been established to determine whether a client is eligible for the
forbearance process. Specific approval mandates are in place to approve the measures, as well as
procedures to manage, monitor and report the forbearance activities.
ING reviews the performance of forborne exposures at least quarterly, either on a case-by-case (Business) or
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.
ING Bank Annual Report 2024 66

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> Credit risk

Summary Forborne portfolio (*)
in EUR million | 2024 | 2023
Business line | Outstandings | Of which: performing | Of which: non- performing | % of total portfolio | Outstandings | Of which: performing | Of which: non- performing | % of total portfolio
Wholesale Banking | 5,934 | 3,191 | 2,743 | 1.9% | 6,063 | 3,919 | 2,144 | 1.9%
Retail Banking | 6,883 | 3,987 | 2,897 | 1.3% | 7,026 | 4,128 | 2,898 | 1.4%
Total | 12,817 | 7,178 | 5,640 | 1.5% | 13,089 | 8,047 | 5,042 | 1.6%

Summary Forborne portfolio by forbearance type (*)
in EUR million | 2024 | 2023
Forbearance type | Outstandings | Of which: performing | Of which: non- performing | % of total portfolio | Outstandings | Of which: performing | Of which: non- performing | % of total portfolio
Loan modification | 11,726 | 6,734 | 4,993 | 1.4% | 11,881 | 7,550 | 4,331 | 1.4%
Refinancing | 1,091 | 444 | 647 | 0.1% | 1,208 | 497 | 711 | 0.1%
Total | 12,817 | 7,178 | 5,640 | 1.5% | 13,089 | 8,047 | 5,042 | 1.5%

As of 31 December 2024, ING’s total forborne assets decreased by €272 million compared to 31 December
2023. WB decreased by €129 million and Retail decreased by €143 million.
Wholesale Banking (*)
As of December 2024, WB forborne assets amounted to €5.9 billion (2023: €6.1 billion), which represented
1.9% (2023: 1.8%) of the total WB portfolio.

Wholesale Banking: Forborne portfolio by geographical area (*)
in EUR million | 2024 | 2023
Region | Outstandings | Of which: performing | Of which: non- | Outstandings | Of which: performing | Of which: non-
performing | performing
Europe | Netherlands | 217 | 69 | 148 | 361 | 301 | 60
Belgium | 172 | 165 | 7 | 454 | 446 | 8
Germany | 372 | 62 | 310 | 288 | 148 | 139
United Kingdom | 444 | 266 | 178 | 583 | 425 | 158
Italy | 389 | 353 | 36 | 54 | 19 | 34
Norway | 0 | 0 | 0 | 6 | 0 | 6
Poland | 630 | 284 | 346 | 520 | 519 | 0
Rest of Europe | 1,339 | 940 | 399 | 1,421 | 1,142 | 279
America | 1,586 | 867 | 719 | 1,025 | 532 | 493
Asia | 652 | 111 | 541 | 1,198 | 277 | 921
Australia | 79 | 34 | 44 | 87 | 87 | —
Africa | 54 | 40 | 15 | 68 | 23 | 45
Total | 5,934 | 3,191 | 2,743 | 6,063 | 3,919 | 2,144

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> Credit risk

Wholesale Banking: Forborne portfolio by economic sector (*)
in € million | 2024 | 2023
Industry | Outstandings | Of which: performing | Of which: non- | Outstandings | Of which: performing | Of which: non-
performing | performing
Natural Resources | 781 | 424 | 356 | 788 | 321 | 467
Real Estate | 1,115 | 703 | 412 | 1,320 | 1,254 | 66
Transportation & Logistics | 214 | 83 | 131 | 315 | 175 | 139
Food, Beverages & Personal Care | 810 | 415 | 395 | 866 | 465 | 401
Services | 211 | 176 | 34 | 284 | 254 | 30
Automotive | 332 | 183 | 149 | 138 | 98 | 40
Utilities | 677 | 301 | 376 | 510 | 255 | 255
General Industries | 127 | 70 | 58 | 145 | 74 | 71
Retail | 149 | 21 | 128 | 282 | 104 | 178
Chemicals, Health & Pharmaceuticals | 668 | 136 | 532 | 571 | 559 | 11
Builders & Contractors | 122 | 118 | 5 | 133 | 72 | 61
Other | 729 | 561 | 168 | 712 | 287 | 425
Total | 5,934 | 3,191 | 2,743 | 6,063 | 3,919 | 2,144

Net decrease in WB is driven by the performing forborne exposures -€728 million. Non-performing forborne
assets increased by €599 million, mainly in Chemicals, Health & Pharmaceuticals and in Real Estate in line
with earlier mentioned NPL increases.
WB's forborne assets are mainly concentrated in real estate; food, beverages & personal care; natural
resources; chemicals, health & pharmaceuticals; and utilities. These five sectors accounted for 68.3% of the
total WB forborne outstandings.
Retail Banking (*)
As of 31 December 2024, Retail Banking forborne assets amounted to €6.9 billion (2023: €7.0 billion), which
represented 1.3% (2023: 1.4%) of the total RB portfolio. 26.7% f the forborne exposures were in Private
Individuals.

Retail Banking: Forborne portfolio by geographical area (*)
in € million | 2024 | 2023
Region | Outstandings | Of which: performing | Of which: non- | Outstandings | Of which: performing | Of which: non-
performing | performing
Europe | Netherlands | 1,548 | 1,134 | 414 | 1,483 | 981 | 502
Belgium | 1,942 | 800 | 1,142 | 2,153 | 838 | 1,315
Germany | 1,379 | 1,052 | 327 | 1,309 | 1,064 | 246
Poland | 777 | 403 | 374 | 852 | 522 | 330
Türkiye | 13 | 9 | 4 | 25 | 15 | 10
Italy | 122 | 43 | 79 | 123 | 51 | 71
Romania | 173 | 72 | 101 | 135 | 49 | 86
Spain | 159 | 127 | 31 | 138 | 118 | 21
Rest of Europe | 102 | 50 | 52 | 88 | 58 | 30
America | 22 | 17 | 6 | 21 | 20 |
Asia | 1 |  | 1 | 2 | 1 | 1
Australia | 646 | 279 | 367 | 697 | 411 | 286
Africa |  |  |  |  |  |
Total | 6,883 | 3,987 | 2,897 | 7,026 | 4,128 | 2,898

The main concentration of forborne assets in a single country was in Belgium with 28.2% (2023: 30.6%) of
total Retail Banking forborne assets and 39.4% (2023: 45.4%) of the non-performing forborne assets,
followed by the Netherlands with 22.5% (2023: 21.1%) and Germany having 20.0% (2023: 18.6%) of the total
Retail forborne assets.
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> Credit risk
Non-performing loans (*)
ING has aligned the regulatory concept of non-performing with that of the definition of default. Hence,
borrowers are classified as non-performing when a default trigger occurs:
• 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; and
• 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 warning indicators to signal possible future issues
in debt service.
The table below represents the breakdown of credit risk outstandings that have been classified as non-
performing by sector and business line.

Non-performing Loans: outstandings by economic sector and business lines (*)1
in EUR million | Wholesale Banking | Retail Banking | Total
Industry | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Private Individuals | 4 | 4 | 4,766 | 4,416 | 4,769 | 4,419
Natural Resources | 965 | 669 | 99 | 85 | 1,064 | 754
Food, Beverages & Personal Care | 452 | 565 | 357 | 520 | 809 | 1,085
Transportation & Logistics | 347 | 437 | 157 | 134 | 504 | 572
Services | 102 | 101 | 394 | 481 | 495 | 582
Real Estate | 831 | 592 | 603 | 462 | 1,434 | 1,053
General Industries | 236 | 111 | 451 | 385 | 687 | 497
Builders & Contractors | 51 | 124 | 445 | 453 | 496 | 577
Retail | 157 | 207 | 224 | 188 | 381 | 395
Utilities | 582 | 331 | 19 | 18 | 600 | 348
Chemicals, Health & Pharmaceuticals | 654 | 101 | 185 | 132 | 839 | 233
Telecom | 151 | 378 | 12 | 12 | 163 | 390
Other | 666 | 412 | 387 | 336 | 1,052 | 748
Total | 5,196 | 4,034 | 8,099 | 7,619 | 13,295 | 11,653

1 Based on lending and investment outstandings.
ING Bank Annual Report 2024 69

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> Credit risk

Non-performing Loans: outstandings by economic sectors and geographical area (*)
in EUR million | Region | Total
Industry | Netherlands | Belgium | Germany | Poland | Spain | United Kingdom | France | Luxembourg | Rest of Europe | America | Asia | Australia | Africa | 2024
Private Individuals | 646 | 1,461 | 1,066 | 210 | 304 | 10 | 8 | 44 | 545 | 2 | 2 | 469 |  | 4,769
Natural Resources | 13 | 54 |  | 33 |  |  |  |  | 569 | 31 | 343 | 21 |  | 1,064
Food, Beverages & Personal Care | 196 | 154 | 1 | 93 |  | 23 | 5 |  | 158 | 51 | 127 |  |  | 809
Transportation & Logistics | 93 | 40 | 3 | 124 | 47 |  |  | 1 | 136 |  |  | 1 | 59 | 504
Services | 57 | 293 | 5 | 87 | 2 | 1 | 3 | 5 | 10 | 34 |  |  |  | 495
Real Estate | 12 | 374 | 63 | 114 | 59 |  | 59 | 90 | 6 | 606 |  | 52 |  | 1,434
General Industries | 153 | 123 | 24 | 147 | 20 |  | 2 | 1 | 170 | 17 | 30 |  |  | 687
Builders & Contractors | 68 | 175 | 5 | 162 |  |  |  | 7 | 78 |  |  |  |  | 496
Retail | 53 | 97 | 39 | 62 |  |  | 3 |  | 14 | 97 | 15 | 1 |  | 381
Utilities | 13 | 8 | 25 | 21 |  | 285 |  |  | 12 | 128 | 109 |  |  | 600
Chemicals, Health & Pharmaceuticals | 37 | 94 | 84 | 340 |  | 1 | 110 |  | 113 | 36 |  | 24 |  | 839
Telecom | 7 | 1 |  | 3 |  |  | 44 |  | 14 | 90 | 4 |  |  | 163
Other | 202 | 198 | 117 | 60 |  | 2 | 72 | 17 | 90 | 54 | 92 |  | 150 | 1,052
Total | 1,549 | 3,071 | 1,432 | 1,457 | 432 | 322 | 307 | 166 | 1,916 | 1,145 | 723 | 567 | 210 | 13,295

Non-performing Loans: outstandings by economic sectors and geographical area (*)
in EUR million | Region | Total
Industry | Netherlands | Belgium | Germany | Poland | Spain | United Kingdom | France | Luxembourg | Rest of Europe | America | Asia | Australia | Africa | 2023
Private Individuals | 609 | 1,535 | 885 | 225 | 235 | 3 | 8 | 45 | 489 | 2 | 2 | 380 | 1 | 4,419
Natural Resources | 30 | 60 | 1 | 23 |  |  |  | 55 | 164 | 31 | 369 |  | 20 | 754
Food, Beverages & Personal Care | 281 | 157 | 1 | 131 |  | 139 | 7 |  | 158 | 82 | 128 |  |  | 1,085
Transportation & Logistics | 110 | 50 | 2 | 51 | 47 | 20 |  | 1 | 168 | 49 | 1 | 2 | 72 | 572
Services | 121 | 342 | 2 | 55 | 2 |  | 3 | 8 | 13 | 37 |  |  |  | 582
Real Estate | 40 | 297 | 53 | 55 | 9 |  | 36 | 16 | 7 | 519 |  | 21 |  | 1,053
General Industries | 145 | 127 | 49 | 99 |  |  | 2 | 7 | 24 | 42 |  |  |  | 496
Builders & Contractors | 113 | 181 | 2 | 135 |  |  |  | 22 | 91 | 32 |  |  |  | 577
Retail | 51 | 82 | 36 | 52 |  |  | 2 |  | 14 | 149 | 7 |  |  | 395
Utilities | 14 | 5 |  | 21 |  |  |  |  | 18 | 153 | 138 |  |  | 348
Chemicals, Health & Pharmaceuticals | 31 | 77 | 13 | 25 |  |  | 64 |  | 11 | 12 |  |  |  | 233
Telecom | 12 | 1 | 28 | 3 |  |  |  |  | 13 | 56 | 277 |  |  | 390
Other | 28 | 239 | 42 | 55 |  | 2 | 1 | 6 | 23 | 46 | 128 |  | 179 | 748
Total | 1,586 | 3,153 | 1,114 | 929 | 293 | 165 | 124 | 162 | 1,193 | 1,210 | 1,050 | 403 | 272 | 11,653

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> Credit risk
In 2024, the NPL portfolio increased to €13.3 billion. n increase in Wholesale Banking (+€1.2 billion) together
with an increase in Retail Banking (+€0.5 billion). The increase in Wholesale Banking was mainly witnessed in
real estate; chemicals, health & pharmaceuticals; and in natural resources, partially offset by telecom. In
Retail Banking, the increase was concentrated in Private Individuals. The top three countries by NPL
outstanding are Belgium, the Netherlands and Poland.
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,
financial- and non-financial guarantees issued.
ING distinguishes between two types of calculation methods for credit loss allowances:
• Collective 12-month ECL (Stage 1) and collective lifetime ECL (Stage 2) for portfolios of financial
instruments, as well as collective lifetime ECL for credit-impaired exposures (Stage 3) below €1 million;
• Individual lifetime ECL for credit-impaired (Stage 3) financial instruments with exposures above €1 million.
IFRS 9 models (*)
ING's IFRS 9 models leverage on the internal rating-based (IRB) models (PD, LGD, EAD), which include certain
required conservatism. To include IFRS 9 requirements, such regulatory conservatism is removed from the
ECL parameters (PD, LGD and EAD). The IFRS 9 models apply two other types of adjustments to the IRB ECL
parameters: (i) to the economic outlook and (ii) for Stage 2 and Stage 3 assets only, to the lifetime horizon.
The IFRS 9 model parameters are estimated based on statistical techniques and supported by expert
judgement.
ING has aligned the definition of default for regulatory purposes with the definition of ‘credit-impaired’
financial assets under IFRS 9 (Stage 3). ING has also aligned its definition of default between IFRS 9 and the
regulatory technical standards (RTS) and EBA guidelines. More information can be found in section 1.5.6 of
the consolidated financial statements.
Climate and environmental risks in IFRS 9 models (*)
Climate risk drivers (physical and transition risks) can reduce the ability of businesses and households to fulfil
their obligations due on existing lending contracts. These may also lead to the depreciation/erosion of
collateral values, which would translate into higher credit losses and loan-to-value ratios in the lending
portfolio of ING.
Currently, it is not yet possible to fully incorporate climate risk separately into IFRS 9 ECL models given the
lack of sufficient empirical historical data and data limitations in the risk assessments on client level.
However, ING has taken next steps in 2024 to more explicitly cover for climate-risk drivers in loan loss
provisioning. A management adjustment to ECL models for business clients was introduced to specifically
cover for the medium- to long-term transition risk on high greenhouse gas-emitting sectors. For households,
particularly the mortgage book, next step in the development will be to apply differentiation in collateral
valuation based on EPC labels.
Additionally, where climate and environmental factors have impacted the economy in the recent past or
present, these impacts are implicitly embedded in ING’s IFRS 9 ECL models through the projected
macroeconomic indicators (e.g. indirectly via GDP growth and unemployment rates). We note, however, 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 specific climate-related matters, particularly physical risk events that have
already occurred (e.g. floods, stranded assets etc.), the impact of such events is individually assessed in the
calculation of Stage 3 individual provisions, collective SICR or management adjustments to ECL models. For
example, we consider whether affected assets have suffered from a significant increase in credit risk (or are
credit impaired) and whether the ECL is appropriate. Furthermore as at 31 December 2024 we have reported
a management adjustment for the increased expected credit risk in the Mortgage and Consumer Lending
portfolio in Spain due to payment holidays provided for customers with collateral or activities in the Valencia
area impacted by the severe floods in the fourth quarter of 2024. For more, see ‘Management adjustments
applied this reporting period’.
Going forward, ING aims to continue to improve on climate risk data, which will enable us to further embed
climate risks into the IFRS 9 ECL models. For further details on ESG risk management, see ‘ESG risk’
ING Bank Annual Report 2024 71

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> Credit risk

Reconciliation gross carrying amount (IFRS 9 eligible) and statement of financial position |  |  |  |  |  |  |
in EUR million | 2024 | 2023
| Gross carrying amount | Loan Loss Provisions | Cash and on- demand bank positions | Reverse repurchase transactions | Cash collateral | Other | Statement of financial position | Gross carrying amount | Loan Loss Provisions | Cash and on- demand bank positions | Reverse repurchase transactions | Cash collateral | Other | Statement of financial position
Amounts held at central banks | 71,280 | -14 | -1,550 |  |  | 637 | 70,353 | 90,602 | -5 | -794 |  |  |  | 90,214
Loans and advances to banks | 4,684 | -22 | 3,195 | 10,777 | 2,362 | 773 | 21,769 | 5,835 | -30 | 2,381 | 5,251 | 3,063 | 208 | 16,708
Financial instruments FVOCI loans | 1,671 | -7 |  |  |  | -56 | 1,608 | 983 | -8 |  |  |  | -24 | 951
Financial Instruments FVOCI debt securities | 42,185 | -12 |  |  |  | 46 | 42,219 | 38,323 | -13 |  |  |  | -30 | 38,281
Securities at amortised cost | 50,701 | -15 |  |  |  | -413 | 50,273 | 48,770 | -22 |  |  |  | -435 | 48,313
Loans and advances to customers | 679,488 | -5,833 |  | 3,471 | 4,956 | -1,783 | 680,299 | 647,925 | -5,621 |  | 499 | 3,914 | -4,265 | 642,453
Total on-balance (IFRS 9 eligible) | 850,009 | -5,902 | 1,645 | 14,248 | 7,318 | -796 | 866,521 | 832,439 | -5,697 | 1,587 | 5,750 | 6,978 | -4,137 | 836,919
Guarantees and irrevocable facilities (IFRS 9 eligible) | 198,420 | -146 |  |  |  |  |  | 192,458 | -142 |  |  |  |  |
Total gross carrying amount (IFRS 9 eligible) | 1,048,429 | -6,048 |  |  |  |  |  | 1,024,897 | -5,839 |  |  |  |  |

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.
Portfolio quality (*)
The table below describes the portfolio composition over the different IFRS 9 stages and rating classes. The
Stage 1 portfolio represents 91.1% (2023: 91.5%) of the total gross carrying amounts, mainly composed of
investment grade, while Stage 2 makes up 7.6% (2023: 7.3%) and Stage 3 makes up 1.3% (2023: 1.2%) of the
total gross carrying amounts, respectively.
ING Bank Annual Report 2024 72

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> Credit risk

Gross carrying amount per IFRS 9 stage and rating class (*)1,2, 3
in EUR million | 12-month ECL (Stage 1) | Lifetime ECL not credit impaired (Stage 2) | Lifetime ECL credit impaired (Stage 3) | Total
Rating class | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions
|  | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Investment grade | 1 (AAA) | 79,076 | 87,122 | 1 | 1 | 281 | 439 |  |  |  |  |  |  | 79,357 | 87,561 | 1 | 1
2-4 (AA) | 140,671 | 132,159 | 10 | 8 | 1,579 | 2,553 | 1 | 2 |  |  |  |  | 142,250 | 134,711 | 11 | 9
5-7 (A) | 244,306 | 231,018 | 22 | 24 | 6,908 | 6,188 | 8 | 6 |  |  |  |  | 251,214 | 237,206 | 29 | 30
8-10 (BBB) | 310,114 | 302,967 | 55 | 85 | 24,683 | 17,004 | 55 | 24 |  |  |  |  | 334,797 | 319,971 | 110 | 108
Non-Investment grade | 11-13 (BB) | 154,348 | 157,387 | 190 | 226 | 18,479 | 19,273 | 91 | 93 |  |  |  |  | 172,827 | 176,661 | 281 | 319
14-16 (B) | 25,377 | 26,414 | 124 | 164 | 17,433 | 19,336 | 366 | 455 |  |  |  |  | 42,811 | 45,750 | 490 | 618
17 (CCC) | 905 | 617 | 8 | 10 | 3,992 | 3,928 | 173 | 233 |  |  |  |  | 4,897 | 4,545 | 181 | 242
Performing Restructuring | 18 (CC) |  |  |  |  | 4,059 | 4,617 | 233 | 402 |  |  |  |  | 4,060 | 4,617 | 233 | 402
19 (C) |  |  |  |  | 2,474 | 1,919 | 203 | 221 |  |  |  |  | 2,474 | 1,919 | 203 | 221
Non-performing loans | 20-22 (D) |  |  |  |  |  |  |  |  | 13,742 | 11,956 | 4,509 | 3,887 | 13,742 | 11,956 | 4,509 | 3,887
Total | 954,798 | 937,684 | 409 | 517 | 79,888 | 75,257 | 1,130 | 1,435 | 13,742 | 11,956 | 4,509 | 3,887 | 1,048,429 | 1,024,897 | 6,049 | 5,839

1 Compared to the credit risk portfolio, the differences are mainly undrawn committed amounts (€155 billion; 2023: €151 billion) and other positions (€6 billion; 2023: €9 billion) not included in credit outstandings and non-IFRS 9 eligible assets (€75 billion; 2023: €67 billion), mainly
pre-settlement exposures) included in credit outstandings but not in the gross carrying amounts.
2 Stage 3 lifetime credit impaired provision includes €21 million (2023: €11 million) on purchased or originated credit impaired.
Changes in gross carrying amounts and loan loss provisions (*)
The table below provides a reconciliation by stage of the gross carrying amount and allowances for loans
and advances to banks and customers, including loan commitments and financial guarantees. The transfers
of financial instruments represent the impact of stage transfers upon the gross carrying/nominal amount
and associated allowance for ECL. This includes the net-remeasurement of ECL arising from stage transfers,
for example, moving from a 12-month (Stage 1) to a lifetime (Stage 2) ECL measurement basis.
The net-remeasurement line represents the changes in provisions for facilities that remain in the same
stage.
Please note the following comments with respect to the movements observed in the table below:
• Stage 3 gross carrying amount increased by €1.7 billion from €12.0 billion as at 31 December 2023 to
€13.7 billion as at 31 December 2024, mainly as a result of €4.8 billion net inflow into NPL (credit
impaired) in 2024 which is offset by €1.8 billion derecognitions and repayments and €1.3 billion write-offs
and disposals. Following the increase in carrying amount, Stage 3 provisions increased by €0.6 billion.
• Stage 2 gross carrying amounts increased by €4.6 billion from €75.3 billion as at 31 December 2023 to
€79.9 billion as at 31 December 2024, largely driven by €23.7 billion net transfers from Stage 1 into Stage
2, including the impact of changes in risk drivers (including updated macro-economic forecasts), model
redevelopments mainly for Wholesale Banking models and new Stage 2 overlays. This was offset by a
decrease of exposure by €16.2 billion due to derecognised financial assets (including sales), repayments
and €2.9 billion exposure moving to Stage 3. Stage 2 provisions decreased by €0.3 billion to €1.1 billion as
of 31 December 2024.
ING Bank Annual Report 2024 73

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> Credit risk

Changes in gross carrying amounts and loan loss provisions (*)1, 2
in EUR million | 12-month ECL (Stage 1) | Lifetime ECL not credit impaired (Stage 2) | Lifetime ECL credit impaired (Stage 3) | Total | 12-month ECL (Stage 1) | Lifetime ECL not credit impaired (Stage 2) | Lifetime ECL credit impaired (Stage 3) | Total
| Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions | Gross carrying amount | Provisions
| 2024 | 2023
Opening balance | 937,684 | 517 | 75,258 | 1,435 | 11,956 | 3,887 | 1,024,897 | 5,839 | 884,886 | 580 | 70,725 | 1,679 | 11,708 | 3,841 | 967,319 | 6,100
Impact of changes in accounting policies |  |  |  |  |  |  |  |  | 37,079 | 9 | 4,704 | 13 | 158 | 73 | 41,941 | 95
Adjusted opening balance |  |  |  |  |  |  |  |  | 921,965 | 589 | 75,429 | 1,692 | 11,866 | 3,914 | 1,009,260 | 6,195
Transfer into 12-month ECL (Stage 1) | 20,276 | 22 | -20,026 | -195 | -249 | -34 |  | -207 | 11,832 | 28 | -11,583 | -239 | -249 | -36 | 0 | -247
Transfer into lifetime ECL not credit impaired (Stage 2) | -43,155 | -49 | 43,900 | 429 | -745 | -96 |  | 285 | -29,134 | -67 | 29,849 | 449 | -716 | -105 | 0 | 276
Transfer into lifetime ECL credit impaired (Stage 3) | -2,980 | -18 | -2,856 | -235 | 5,836 | 1,802 |  | 1,548 | -2,053 | -10 | -1,775 | -114 | 3,828 | 978 | 0 | 853
Net remeasurement of loan loss provisions |  | -180 |  | -137 |  | 185 |  | -133 | 0 | -149 | 0 | -94 | 0 | 59 | 0 | -183
New financial assets originated or purchased | 212,529 | 192 |  |  |  |  | 212,529 | 192 | 195,826 | 204 | 0 | 0 | 0 | 0 | 195,826 | 204
Financial assets that have been derecognised | -126,858 | -76 | -11,840 | -153 | -1,450 | -257 | -140,148 | -485 | -121,991 | -72 | -14,239 | -215 | -1,475 | -266 | -137,705 | -552
Net drawdowns and repayments | -41,763 |  | -4,406 |  | -309 |  | -46,478 |  | -38,758 | 0 | -2,386 | 0 | -229 | 0 | -41,372 | 0
Changes in models/risk parameters |  | 8 |  | -6 |  | -22 |  | -20 | 0 | 7 | 0 | 11 | 0 | 84 | 0 | 102
Increase in loan loss provisions |  | -101 |  | -297 |  | 1,578 |  | 1,179 |  | -58 |  | -203 |  | 714 |  | 452
Write-offs 3 |  |  |  |  | -1,017 | -1,017 | -1,017 | -1,017 | -3 | -3 |  |  | -787 | -787 | -790 | -790
Disposals 3 | -935 | -1 | -141 | -8 | -279 | -215 | -1,355 | -225 |  |  | -38 | -38 | -283 | -283 | -321 | -321
Recoveries of amounts previously written off |  |  |  |  |  | 69 |  | 69 | 0 | 0 | 0 | 0 | 0 | 71 | 0 | 71
Foreign exchange and other movements |  | -5 |  |  |  | 208 |  | 203 | 0 | -12 | 0 | -15 | 0 | 257 | 0 | 231
Closing balance | 954,798 | 409 | 79,888 | 1,130 | 13,742 | 4,509 | 1,048,429 | 6,048 | 937,684 | 517 | 75,258 | 1,435 | 11,956 | 3,887 | 1,024,897 | 5,839

1 Stage 3 lifetime credit impaired provision includes €21 million (2023: €11 million) on purchased or originated credit impaired.
2 The addition to the loan provision (in the consolidated statement of profit or loss) amounts to €1,194 million (2023: €520 million) of which €1,170 million (2023: €483 million)related to IFRS 9 eligible financial assets, €9 million (2023: €-31 million) related to non-credit
replacement guarantees and €15 million(2023: €67 million) to modification gains and losses on restructured financial assets.
3 T able was updated for presentation purposes to disaggregate utilisation of the provision between write-offs and disposals. Comparatives have been updated accordingly.
ING Bank Annual Report 2024 74

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> Credit risk

Exposure per stage, coverage ratio and stage ratio’s 2
in EUR million | 2024 | 2023
Balance sheet | Gross carrying amount | Loan loss provisions | Stage Ratio | Gross carrying amount | Loan loss provisions | Stage Ratio
Loans and advances to banks (including central banks) | 75,964 | 35 |  | 96,436 | 34 |
Stage 1 | 74,631 | 4 | 98% | 95,935 | 4 | 99%
Stage 2 | 1,258 | 15 | 2% | 494 | 17 | 1%
Stage 3 | 75 | 16 | 0.10% | 6 | 13 | %
Loans and advances to customers | 679,488 | 5,833 |  | 647,927 | 5,621 |
of which: Residential mortgages | 348,432 | 814 |  | 331,467 | 821 |
Stage 1 | 315,774 | 49 | 91% | 306,192 | 97 | 92%
Stage 2 | 29,341 | 307 | 8% | 22,167 | 252 | 7%
Stage 3 | 3,317 | 458 | 1% | 3,108 | 472 | 1%
Of which: Consumer lending (excl. Residential mortgages) | 28,514 | 957 |  | 25,954 | 1,004 |
Stage 1 | 24,134 | 112 | 85% | 22,081 | 177 | 85%
Stage 2 | 3,090 | 191 | 11% | 2,743 | 198 | 11%
Stage 3 | 1,290 | 654 | 5% | 1,131 | 629 | 4%
Of which: loans to public authorities | 23,930 | 17 |  | 19,068 | 11 |
Stage 1 | 23,214 | 6 | 97% | 18,083 | 4 | 95%
Stage 2 | 464 | 3 | 2% | 691 | 2 | 4%
Stage 3 | 252 | 8 | 1% | 294 | 5 | 2%
Of which: Corporate lending | 278,612 | 4,045 |  | 271,438 | 3,785 |
Stage 1 | 237,305 | 196 | 85% | 232,452 | 185 | 86%
Stage 2 | 33,427 | 575 | 12% | 32,178 | 921 | 12%
Stage 3 | 7,880 | 3,274 | 3% | 6,808 | 2,679 | 3%
Other IFRS 9 eligible financial Instruments 1 | 292,977 | 180 |  | 280,534 | 184 |
Stage 1 | 279,951 | 43 | 96% | 262,941 | 49 | 94%
Stage 2 | 12,308 | 39 | 4% | 16,984 | 46 | 6%
Stage 3 | 718 | 98 | 0.2% | 609 | 88 | 0.2%
Total gross carrying amount (IFRS 9 eligible) | 1,048,429 | 6,048 |  | 1,024,897 | 5,839 |

1 Includes off-balance sheet IFRS 9 eligible guarantees and irrevocable facilities. Reference is made to Note 1 'Basis of preparation and material accounting policy information'.
2 The exposure classification to residential mortgages, consumer lending and corporate lending is aligned to the regulatory definition
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> Credit risk
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 EUR million | 2024 | 2023
Financial assets modified during the period |  |
Amortised cost before modification | 1,888 | 1,565
Net modification results | -107 | -75
Financial assets modified since initial recognition |  |
Gross carrying amount at 31 December of financial assets for which loss allowance has changed to 12-month measurement during the period | 1,506 | 2,599

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). Input
from a leading third-party service provider is used to complement the consensus with consistent projections
for variables for which there are no consensus estimates available (most notably house prices and – for
some countries – unemployment), to generate alternative scenarios, to convert annual consensus
information to a quarterly frequency and to ensure general consistency of the scenarios. As the baseline
scenario is consistent with the consensus view, it can be considered as free from any bias.
The relevance and selection of macroeconomic variables is defined by the ECL models under credit risk
model governance. The scenarios are reviewed and challenged by two panels of ING experts. The first panel
consists of (economic) experts from Global Markets Research, risk and modelling, while the second panel
consists of relevant senior managers in ING.
Alternative scenarios and probability weights (*)
Two alternative scenarios are taken into account: an upside and a downside scenario. The alternative
scenarios have statistical characteristics as they are based on the forecast deviations of the leading third-
party service provider.
To understand the baseline level of uncertainty around any forecast, the leading third-party service provider
keeps track of all its deviations (so-called forecast errors) of the past 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, the leading third-party service provider runs a survey with respondents from around the
world and across a broad range of industries. In this survey, respondents put forward their views of key risks.
Following the survey results, the distribution of forecast errors (that is being used for determining the
scenarios) may be skewed.
For the downside scenario, ING has chosen the 90th percentile of that distribution because this corresponds
with the way risk management earnings-at-risk is defined within the Group. The upside scenario is
represented by the 10th percentile of the distribution. The applicable percentiles of the distribution imply a
20 percent probability for each alternative scenario. Consequently, the baseline scenario has a 60 percent
probability weighting. Please note that, given their technical nature, the downside and upside scenarios are
not based on an explicit specific narrative.
Macroeconomic scenarios applied (*)
The macroeconomic scenarios applied in the calculation of loan loss provisions are based on the consensus
forecasts.
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> Credit risk
Baseline assumptions (*)
The general picture that the consensus conveys is that global economic growth is diverging between major
blocs. US growth is expected to continue to outpace European markets, while China is expected to continue
on a declining growth trend, but still at higher rates than seen in advanced markets. Inflation is expected to
remain near target for most advanced economies, although it is set to remain above target for the United
States. With interest rates moderating, although some uncertainty about this path for the US exists at this
point, monetary conditions should turn more favourable for growth. For the housing market, continued price
growth is expected for almost all main markets.
The December 2024 consensus expects global output (as measured by the weighted average GDP growth
rate of ING’s 25 main markets) to slow from 2.5 percent in 2024 to 2.4 percent in 2025. For 2026-2027,
economic growth is expected to come in at 2.4 percent and 2.3 percent respectively.
The American economy continues to perform very well despite signs of a slowing labour market around the
summer of 2024. Inflation has come down to more benign levels, which has prompted the Federal Reserve to
lower interest rates. Still, inflation remains above the 2% target and the outlook for inflation has become
more uncertain. The US administration’s economic plans are set to stimulate the economy for 2025, as
reflected in the increased expectations for 2025 GDP of consensus forecasters. The consensus expects the
growth rate of the US economy to slow from 2.7 percent in 2024 to 2.0 percent for both 2025 and 2026.The
eurozone economy has seen some growth return in 2024 after a long period of stagnation that started
during the energy crisis. Still, expectations for 2025 remain modest. The export environment continues to be
plagued by weak global demand and investments are stymied by high interest rates and weak
manufacturing performance. Expectations of a pickup in growth over the course of the year hang on
domestic drivers like a pickup in real wage growth and continued rate cuts from the ECB at the start of the
year. Consensus expects the eurozone to have grown by only 0.8 percent in 2024, before recovering slightly
to 1.0 percent and 1.2 percent in 2025 and 2026 respectively.Elsewhere in Europe, the outlook is more
upbeat. In Poland, domestic demand appears to remain the key growth driver over the near-term forecast.
Foremost, consumers remain willing to spend, encouraged by elevated wage growth and a resilient labour
market. The economy is expected to grow by 2.7 percent in 2024, picking up to 3.5 percent in 2025 and 3.8
percent in 2026. The consensus expectation for Türkiye is to see growth slow, which is being confirmed by
weak incoming data. Consensus expects growth to slow from 3.1 percent in 2024 to 2.6 percent in 2025, in
part due to soft demand from export orders. For 2026, a recovery to 3.5 percent is expected. The Russian
economy is expected to slow substantially in 2025 after a strong 2024. Growth is expected to drop from 3.7
percent in 2024 to 1.6 percent in 2025 and 1.3 percent in 2026.
For China, economic underperformance continues as it still struggles with the impact of the real estate
correction and weak domestic demand. Large scale stimulus plans and a possible bottoming out of the real
estate market do help economic forecasts for the short-run, although medium term consensus continues to
be downbeat for the moment. For 2024, consensus expects 4.8 percent growth, down to 4.4 percent in 2025
and 4.1 percent in 2026.
Economic momentum in Australia is expected to be soft. The economy is lacking a clear growth engine, with
the private sector clearly struggling against restrictive policy settings and consumers facing a tough outlook.
Growth is expected to have come in at 1.2 percent in 2024, with just moderate pick-up expected for 2025 to
2.0 percent and 2.4 percent for 2026.
When compared to the June 2024 consensus forecast, the December 2024 forecast is relatively stable.
Global GDP is expected to increase by 2.5 percent in 2024 (compared to 2.4 percent assumed before) and is
expected to grow by 2.4 percent in 2025 (2.3 percent assumed before). With the energy crisis and pandemic
now further behind us, the consensus for economic activity in major markets is showing smaller deviations
over time despite economic and geopolitical uncertainty still being very prevalent.
Alternative scenarios and risks (*)
The baseline scenario assumes continued steady economic growth. However, a longer period of weakness,
due to even more concerning geopolitical tensions, persistent elevated inflation and trade tensions 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 downside scenario – though technical in nature – sees a recession in 2025 and 2026 for most countries.
Unemployment increases strongly in this scenario and house prices in most countries show outright falls.
The downside scenario captures the possible impact from escalating geopolitical tensions, increased trade
tensions and persistent elevated inflation.
The upside scenario – while equally technical in nature – reflects the possibility of a better economic out-turn
because of a substantial loosening of monetary policy, and policy stimulus in China.
Management adjustments applied this reporting period (*)
In times of volatility and uncertainty where portfolio quality and the economic environment are changing
rapidly, models alone may not be able to accurately predict losses. In these cases, management
adjustments can be applied to appropriately reflect ECL. Management adjustments can also be applied
where the impact of the updated macroeconomic scenarios is over- or under-estimated by the IFRS 9
models, as well as to reflect the impact of model redevelopment or recalibration and periodic model
assessment procedures that have not been incorporated in the IFRS 9 models yet.
ING has internal governance frameworks and controls in place to assess the appropriateness of all
management adjustments.
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> Credit risk

Management adjustments to ECL models (*)
in EUR million | 2024 | 2023
Commercial Real Estate/ Inflation and interest rate increases | 50 | 351
Economic sector / portfolio based adjustments | 38 | 36
Mortgage portfolio adjustments | 112 | 126
Climate transition risk | 29 |
Other Post Model Adjustments | -27 | 64
Total management adjustments | 203 | 577

As the ING credit risk models generally assume that inflation and interest rate increase risks materialise via
other risk drivers, such as GDP and unemployment rates with a delay, an overlay approach was determined
in previous financial years to timely estimate the expected credit losses (ECL) related to reduced repayment
capacity and affordability for private individuals and business clients in the Retail Banking segment.
As inflationary stress has decreased since origination of the overlay approach and the limited observed
impact in both the Retail and the Wholesale Banking segment, no management adjustment is reported as at
31 December 2024, with exception of a management adjustment of €50 million for the Commercial Real
Estate portfolio (31 December 2023: €351 million in total). The €50 million management adjustment related
to the Commercial Real Estate portfolio is reported in Wholesale Banking (€33.5 million) and in Business
Banking in the Netherlands (€16.5 million) because the prevailing risks from increased levels of interest rates
and inflation still exist for this sector in these portfolios. This management adjustment is reflected in Stage 1
and Stage 2.Furthermore, in specific parts in the Retail Banking segment, that were previously included in the
inflation and interest rate increases overlay and where increased risked not yet captured in the credit risk
models are still observed, specific portfolio-based adjustments have been recognised.
As at 31 December 2024, the economic sector / portfolio based adjustments in Stage 2 of €38 million in total
included a management adjustment of €14 million for the increased expected credit risk in the Mortgage
and Consumer Lending portfolio in Spain due to payment holidays provided for customers with collateral or
activities in the areas impacted by the severe floods in the Valencia area in the fourth quarter of 2024.
Furthermore, adjustments have been taken in the Business Banking portfolio in Germany (€10 million) to
cover for the increased uncertainty in the German economy and to the Mortgage portfolio in Australia (€15
million) to cover for affordability risk from inflation and interest rate increases.
The economic sector adjustments as at 31 December 2023 of €36 million, fully related to Business Banking
clients that have benefited from government support programs in the Netherlands during the Covid-19
pandemic. This adjustment was released in full in 2024 as the risk was considered to be no longer present in
the portfolio. The overall mortgage portfolio adjustment as at 31 December 2024 decreased to €112 million
(31 December 2023: €126 million). The management adjustment in Stage 2 for the risk segmentation model
that captures affordability, repayment and refinancing risk on performing mortgage customers with a bullet
loan in the Netherlands was decreased to €112 million (31 December 2023: €115 million). The mortgage
portfolio adjustment that related to the overvaluation of house prices was released in full in 2024 (31
December 2023: €11 million).
As of 31 December 2024, an adjustment of €29 million was introduced to cover for the impact of climate
transition risk in Wholesale Banking (€17 million) and in Business Banking (€12 million). Climate transition risk
is expected to lead to a structural change in credit risk, which means specific business activities will become
structurally riskier due to environmental policies, technological progress or changes in market sentiment and
preferences. The current IFRS 9 models do not capture this (novel) risk. The management adjustment to ECL
models for business clients was made to specifically cover for the medium- to long-term transition risk on
high greenhouse gas-emitting sectors and is reported in Stage 2.
Other post-model adjustments mainly relate to the impact of model redevelopment or recalibration and
periodic model assessment procedures that have not been incorporated in the ECL models yet. The impact
on total ECL can be positive or negative. These result from both regular model maintenance and ING’s
multiyear programme to update ECL models. These adjustments will be removed once updates to the
specific models have been implemented. The change in balance compared to previous reporting date is due
to i) released PMAs because of model updates that have been implemented and ii) new PMAs recognised for
new redevelopments and recalibrations.
Analysis on sensitivity (*)
The table below presents the analysis on the sensitivity of key forward-looking macroeconomic inputs used
in the ECL collective-assessment modelling process and the probability weights applied to each of the three
scenarios. The countries included in the analysis are the most significant geographic regions in ING, and for
Wholesale Banking the US is the most significant in terms of both gross contribution to reportable ECL and
sensitivity of ECL to forward-looking macroeconomics. Accordingly, ING considers these portfolios to present
the most significant risk of resulting in a material adjustment to the carrying amount of financial assets
within the next financial year. 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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> Credit risk

Sensitivity analysis as at December 2024 (*)
|  | 2025 | 2026 | 2027 | Un-weighted ECL (€ mln) | Probability- weighting | Reportable ECL (€ mln)1
Netherlands Upside scenario | Real GDP | 2.6 | 3.0 | 2.5 | 193 | 20% | 270
Unemployment | 3.5 | 3.3 | 3.3
HPI | 18.9 | 11.7 | 2.5
Baseline scenario | Real GDP | 1.5 | 1.4 | 1.5 | 249 | 60%
Unemployment | 4.0 | 4.1 | 4.3
HPI | 9.1 | 3.5 | 2.4
Downside scenario | Real GDP | -0.4 | -1.4 | -0.2 | 411 | 20%
Unemployment | 5.7 | 7.2 | 8.1
HPI | -3.7 | -7.2 | 2.2
Germany Upside scenario | Real GDP | 2.0 | 2.8 | 1.6 | 510 | 20% | 548
Unemployment | 2.9 | 2.4 | 2.0
HPI | 5.4 | 8.9 | 9.9
Baseline scenario | Real GDP | 0.5 | 1.1 | 1.2 | 540 | 60%
Unemployment | 3.4 | 3.3 | 3.2
HPI | 2.6 | 5.6 | 6.3
Downside scenario | Real GDP | -1.7 | -1.7 | 0.3 | 609 | 20%
Unemployment | 4.7 | 5.6 | 5.9
HPI | -1.7 | 1.3 | 2.2
Belgium Upside scenario | Real GDP | 2.2 | 2.6 | 2.1 | 534 | 20% | 579
Unemployment | 5.1 | 5.0 | 4.9
HPI | 4.8 | 4.5 | 4.4
Baseline scenario | Real GDP | 1.1 | 1.5 | 1.6 | 569 | 60%
Unemployment | 5.7 | 5.7 | 5.6
HPI | 3.2 | 4.1 | 3.8
Downside scenario | Real GDP | -0.6 | -0.2 | 1.1 | 654 | 20%
Unemployment | 7.0 | 8.0 | 8.0
HPI | 1.2 | 2.9 | 2.5
United States Upside scenario | Real GDP | 3.1 | 3.5 | 3.2 | 74 | 20% | 113
Unemployment | 3.4 | 2.4 | 2.3
HPI | 4.3 | 8.4 | 9.4
Baseline scenario | Real GDP | 2.0 | 2.0 | 2.0 | 101 | 60%
Unemployment | 4.2 | 4.1 | 4.0
HPI | 3.3 | 3.7 | 3.9
Downside scenario | Real GDP | -0.1 | -1.1 | -0.4 | 187 | 20%
Unemployment | 5.9 | 7.3 | 8.0
HPI | -0.7 | -3.0 | -2.5

1 Excluding management adjustments.

Sensitivity analysis as at December 2023 (*)
|  | 2024 | 2025 | 2026 | Un-weighted ECL (€ mln) | Probability- weighting | Reportable ECL (€ mln)1
Netherlands Upside scenario | Real GDP | 1.3 | 3.3 | 2.8 | 214 | 20% | 310
Unemployment | 3.7 | 3.3 | 3.3
HPI | 10.4 | 11.2 | 4.0
Baseline scenario | Real GDP | 0.8 | 1.6 | 1.5 | 282 | 60%
Unemployment | 4.1 | 4.3 | 4.5
HPI | 0.9 | 3.0 | 3.9
Downside scenario | Real GDP | -1.7 | -1.2 | 0.1 | 487 | 20%
Unemployment | 5.9 | 7.2 | 8.1
HPI | -10.9 | -7.4 | 3.7
Germany Upside scenario | Real GDP | 1.4 | 3.1 | 1.6 | 472 | 20% | 525
Unemployment | 2.6 | 2.0 | 1.7
HPI | 0.9 | 6.6 | 8.0
Baseline scenario | Real GDP | 0.5 | 1.3 | 1.2 | 513 | 60%
Unemployment | 3.0 | 3.0 | 3.0
HPI | -1.4 | 3.4 | 4.5
Downside scenario | Real GDP | -2.4 | -1.4 | 0.3 | 615 | 20%
Unemployment | 4.5 | 5.2 | 5.5
HPI | -6.0 | -0.8 | 0.4
Belgium Upside scenario | Real GDP | 1.5 | 2.7 | 2.3 | 568 | 20% | 619
Unemployment | 5.3 | 5.0 | 4.9
HPI | 1.3 | 5.6 | 4.5
Baseline scenario | Real GDP | 0.9 | 1.5 | 1.8 | 604 | 60%
Unemployment | 5.6 | 5.5 | 5.4
HPI | 0.4 | 5.2 | 3.9
Downside scenario | Real GDP | -1.3 | -0.2 | 1.2 | 713 | 20%
Unemployment | 7.3 | 8.0 | 7.9
HPI | -2.2 | 3.9 | 2.6
United States Upside scenario | Real GDP | 1.8 | 3.2 | 3.4 | 102 | 20% | 165
Unemployment | 4.1 | 3.3 | 3.1
HPI | 0.6 | 8.7 | 8.7
Baseline scenario | Real GDP | 0.9 | 1.9 | 2.1 | 144 | 60%
Unemployment | 4.5 | 4.5 | 4.4
HPI | -0.7 | 3.5 | 3.3
Downside scenario | Real GDP | -1.3 | -1.4 | -0.1 | 292 | 20%
Unemployment | 6.6 | 8.2 | 8.8
HPI | -4.2 | -2.7 | -3.0

1 Excluding management adjustments.
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> Credit risk
When compared to the sensitivity analysis of 2023, the macroeconomic inputs are overall more favourable.
This is driven by an improved macroeconomic outlook, mainly because economies prove to be rather
resilient to increased interest rates, particularly in the US, as well as recovery in house prices in, among
others, the Netherlands.
On a total ING level, the unweighted ECL for all collective provisioned clients in the upside scenario was
€2,721 million, in the baseline scenario €2,949 million and in the downside scenario €3,533 million compared
to €3,020 million reportable collective provisions as at 31 December 2024 (excluding all management
adjustments). To perform the sensitivity analysis, a point in time reportable ECL is used as input, which
slightly deviates from the total Model ECL as reported below:

Reconciliation of reportable collective ECL to total ECL (*)
in EUR million | 2024 | 2023
Total reportable collective provisions | 2,975 | 2,856
ECL from individually assessed impairments | 2,871 | 2,406
ECL from management adjustments | 203 | 577
Total ECL | 6,049 | 5,839

Criteria for identifying a significant increase in credit risk (SICR) (*)
All assets and off-balance-sheet items that are in scope of IFRS 9 impairment and which are subject to
collective ECL assessment are allocated a 12-month ECL if deemed to belong in Stage 1, or a lifetime ECL if
deemed to belong in Stages 2 or 3. An asset belongs in Stage 2 if it is considered to have experienced a
significant increase in credit risk (SICR) since initial origination or purchase.
The main determinant of SICR is a quantitative test, whereby the lifetime 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 either a threshold for absolute change in lifetime PD or a threshold for relative change in lifetime PD is
reached, the item is considered to have experienced a SICR (for more details on absolute and relative
thresholds, see the following sections). Furthermore, any facility which shows an increase of 200 percent
between the PD at the date of initial recognition and the lifetime PD at the reporting date (i.e. threefold
increase in PD) must be classified as Stage 2. This is considered a backstop within the quantitative
assessment of SICR.
In Wholesale Banking, significant increase in lifetime PD is not considered plausible for assets of obligors with
a credit rating at the reporting date in the top range of investment grade. As of 2024, the assets of these
Wholesale Banking obligors are excluded from the assessment of significant increase in credit risk triggers.
For these obligors the qualitative significant increases in credit risk triggers remain applicable (see the
section below on Qualitative SICR triggers). These are for example the Watchlist and/ or forbearance triggers.
Finally, the 30 days past due backstop also remains applicable for the top range of investment grade
exposures to ensure significant increase in credit risk recognition.
Absolute lifetime PD threshold
The absolute threshold is a fixed value calibrated per portfolio/segment and provides a fixed threshold that, if
exceeded by the difference between lifetime PD at reporting date and lifetime PD at origination, triggers
Stage 2 classification. The absolute threshold is calibrated during model development.
Relative lifetime PD threshold
The relative threshold defines a relative increase of the lifetime PD beyond which a given facility is classified
in Stage 2 because of a significant increase in credit risk. The relative threshold is dependent on the individual
PD assigned to each facility at the moment of origination, and a scaling factor calibrated in the model
development phase.
Ultimately, the relative threshold provides a criterion to assess whether the ratio (i.e. increase) between
lifetime PD at reporting date and lifetime PD at origination date is deemed a significant increase in credit risk.
If the threshold is breached, SICR is identified and Stage 2 is assigned to the given facility.
The threshold for the relative change in lifetime PD is inversely correlated with the PD at origination; the
higher the PD at origination, the lower the threshold. The logic behind this is to allow facilities originated in
very favourable ratings to downgrade for longer without the need of a Stage 2 classification. In fact, it is
likely that such facilities will still be in favourable ratings even after a downgrade of a few notches. On the
contrary, facilities originated in already unfavourable ratings grades are riskier and even a single-notch
downgrade might represent a significant increase in credit risk and thus a tighter threshold will be in place.
Still, the relative threshold is relatively sensitive for investment-grade assets while the absolute threshold
primarily affects non-investment grade assets.
Average threshold ratio
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 2023 and year-end 2024.
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.
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> Credit risk

Quantitative SICR thresholds (*)
| 2024 | 2023
Average threshold ratio | Investment grade (rating grade 1-10) | Non-investment grade (rating grade 11-17) | Investment grade (rating grade 1-10) | Non-investment grade (rating grade 11-17)
Asset class category |  |  |  |
Mortgages | 2.9 | 2.4 | 2.5 | 2.3
Consumer lending | 2.8 | 2.1 | 2.9 | 2.1
Business lending | 2.7 | 2.1 | 2.7 | 2.1
Governments and financial institutions | 2.9 | 1.9 | 3.0 | 1.9
Other Wholesale Banking | 2.7 | 1.9 | 2.8 | 1.8

As it is apparent from the disclosures above, as per ING’s methodology, the threshold is tighter the higher
the riskiness at origination of the assets, illustrated by the difference between the average threshold applied
to investment grade facilities and non-investment grade facilities.
Sensitivity of ECL to PD lifetime PD thresholds
The setting of PD threshold bands requires management judgement and is a key source of estimation
uncertainty. On Group level, the total model ECL on performing assets, which is the ECL collective-
assessment without taking management adjustments into account, was €1,328 million as at 31 December
2024 (31 December 2023: €1,412 million). To demonstrate the sensitivity of the ECL to these PD threshold
bands, hypothetically solely applying the upside scenario would result in total model ECL on performing
assets of €1,066 million and a decrease in the Stage 2 ratio by 0.5%-point, while solely applying the
downside scenario would result in total model ECL on performing assets of €1,911 million and an increase in
the Stage 2 ratio by 1.9%-point.
Qualitative SICR thresholds
It should be noted that the lifetime PD thresholds are not the only drivers of stage allocation as ING Bank
also relies on a number of qualitative indicators to identify and assess SICR. An asset can also change stages
as a result of other triggers, such as having over 30 days arrears (used as a backstop), collective SICR
assessment, being on a watch list, being under intensive care management, having a substandard internal
rating or being forborne.
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Market risk
Introduction (*)
Market risk is the risk that movements in market variables, such as interest rates, equity prices, foreign
exchange rates, credit spreads and real-estate prices negatively impact the bank’s earnings, capital, market
value or liquidity position. Market risk either arises through positions in banking books or trading books.
The banking book positions are intended to be held for the long term (or until maturity) or for the purpose of
hedging other banking book positions. The trading book positions are typically held with the intention of
short-term trading or to hedge other positions in the trading book. Policies and processes are in place to
monitor the inclusion of positions in either the trading or banking book as well as to monitor the transfer of
risk between the trading and banking books.
The following sections elaborate on the various elements of the risk management framework for:
• Market risk in banking books;
• Market risk in trading books; and
• Market risk capital.
Market risk in banking books (*)
ING 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 they are centrally managed. The scheme below presents the transfer
and management process of market risks in the banking books.
Risk measurement (*)
The main concepts and metrics used for measuring market risk in the banking book are described below per
risk type.
Interest rate risk in banking book (*)
Interest rate risk in the banking book is defined as the exposure of a bank’s earnings, capital, and market
value to adverse movements in interest rates originated from positions in the banking book.
ING centralises interest rate risk management from commercial books (that capture the products sold to
clients) to globally managed interest rate risk books. This enables a clear demarcation between commercial
business results and results based on unhedged interest rate positions.
ING distinguishes between three types of activities that generate interest rate risk in the banking book:
• Investment of own funds.
• Commercial business.
• 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 due to different re-pricing properties of assets and
liabilities. Also, interest rate risk can arise from customer behaviour and/or convexity risk, depending on the
nature of the underlying product characteristics.
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> Market risk
To determine the interest rate risk in particular products (like savings, mortgages) specific assumptions may
need to be made. Customer behaviour risk is defined as the potential future (value) loss due to deviations in
the actual behaviour of clients versus the modelled behaviour with respect to 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 the following main
product types: savings and current accounts (funds entrusted), demand deposits, mortgages and loans.
Savings and demand deposits are generally invested in such a way that both the value is hedged and the
sensitivity of the margin to market interest rates is minimised. This is achieved by creating the investment
profile distributed from short term to long term, which dampens the immediate impact from changes in the
market rates as well as stabilises margin in the longer horizon. Interest rate risk is modelled based on the
stability of deposits and the pass-through rate. This takes account of different elements, such as pricing
strategies, volume developments and the level and shape of the yield curve.
Interest rate risk for mortgages arises due to prepayment or other embedded optionalities. 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 analysis of historical data. However, the substantial change in the interest rate environment in
recent years makes the analysis 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, and are closely monitored on a monthly basis.
Linear risk transfers take place from commercial business books to the treasury book (Group Treasury), if
necessary, by using estimations of customer behaviour. The originating commercial business is ultimately
responsible for estimating this customer behaviour, leaving convexity risk and (unexpected) customer
behaviour risk with the commercial business. Risk measurement and the risk transfer process take place at
least monthly. If deemed necessary, additional risk transfers can take place.
The commercial business manages the convexity risk that is the result of products that contain embedded
options, like mortgages. Here the convexity risk is defined as the optionality effects in the value due to
interest rate changes, excluding the first-order effects. In some cases, convexity risk is transferred from the
commercial books to treasury books using cap/floor contracts and swaptions.
In the following sections, the interest rate risk exposures in the banking books are presented. ING quantifies
risk measures from both earnings and value perspectives. 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 NPV-at-Risk is measured under a direct interest rate shock. Hence no additional,
corrective hedges are included in the measure. The NII-at-Risk measure is measured for interest rate
movements over a period, whereby (assumed) corrective hedges are included in the risk metric.
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 (dynamic plan) are included in this risk metric. NII-at-
Risk provides insight into the sensitivity of ING’s NII under shocked interest rate scenarios against what is
projected in a base case scenario.
In its risk management, ING monitors the NII-at-Risk under a three-year time frame. Interest rates are
shocked during the first year of analysis through the gradual application of shock. The rate changes
considered encompass both upward and downward scenarios, as well as both parallel (equal movements
across the yield curve) and non-parallel scenarios.
The impact of changing interest rates on ING’s NII is predominantly caused by the following factors:
• Change in returns of (re)investments of client deposits;
• Change in client deposit rates (mainly savings), (partially) tracking changes in market interest rates;
• Change in the amortisation profile of mortgages, due to an increase or decrease in expected
prepayments;
• Higher/lower returns of (re-)investments of capital investment;
• Open interest rate positions, leading to changes in return because of different market rates; and
• Assumed volume development of the balance sheet in line with ING’s dynamic plan.
For projecting the change in client deposit rates, ING uses a client rate model that describes the relation
between market interest rates and client deposit rates. The model is calibrated under a range of interest
rate scenarios. Per scenario, the actual change in client deposit rates may deviate from this calibrated
model. The actual NII development of customer deposits may, indeed, differ from the provided scenarios,
depending on, among other things, actual interest rate and savings client rate evolution, as well as changes
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> Market risk
to ING’s balance sheet composition, such as net deposit growth and relative share of savings deposits and
non-remunerated current accounts.
The NII-at-Risk figures in the table below reflect a parallel, linear interest rate movement during a year
('ramped') under the assumption of balance sheet developments in line with ING’s dynamic plan with a time
horizon of one year. The majority of the risk comes from fixed-rate positions, most notably non-
remunerated current accounts and variable-rate savings accounts .
The NII-at-Risk is mainly influenced by the difference in the sensitivity between client liabilities and client
assets and investments to rate changes. The primary factor of NII-at-Risk are the investments of current
accounts, while the investments of own funds have a marginal effect, as only a relatively small portion
needs to be (re)invested within a one-year period.

NII-at-Risk banking book per currency - year one (*)
in EUR million | 2024 | 2023
| Ramped, floored | Ramped, floored
parallel ▼ | parallel ▲ | parallel ▼ | parallel ▲
By currency |  |  |  |
Euro | -144 | 158 | -165 | 155
US dollar | -4 | 5 | -12 | 12
Other | -2 | 21 | -62 | 69
Total | -151 | 184 | -239 | 236
EUR ramped (floored at -100bps) is at +/- 120bps in 1 year (2023: +/-110bps)
USD ramped (floored at -100bps) is at +/- 120bps in 1 year (2023: +/-110bps)

The change in NII under declining and upward interest rate scenarios may not be equal. This is due to
different expected reactions in prepayment behaviour of mortgages and different pricing developments of
commercial loans and deposits products (mainly savings). This is caused by embedded options, explicit or
implicit pricing floors and other (assumed) pricing factors.
The metrics mentioned above are internal metrics, which therefore deviate from the regulatory NII SOT
metrics.
Year-on-year variance analysis (*)
In 2024, in response to falling inflation, most central banks (including ECB and FED) began to ease their
monetary policy, executing series of rates cuts. 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. The
impact of explicit and implicit floors on both rates of client assets and savings remains limited. Pre-existing
hedges, as executed by Group Treasury, were also adjusted continuously throughout the year to hedge any
interest rate risk coming from lower interest rates. Most of the year-on-year change in NII sensitivity is due
to enhancements in risk management framework in one of non-EUR locations. These enhancements are
aimed at mitigating sensitivity in a volatile rate environment and include increasing the granularity of risk
transferred positions and implementing limits to trigger an intra-month recalibration of the hedges.
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. 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. The majority of the risk comes from the investments of own funds and from positions
exhibiting negative convexity due to embedded optionality (most notably variable rate savings and fixed
rate mortgages).
The metrics mentioned above are internal metrics, which therefore deviate from the regulatory EVE SOT
metrics.
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> Market risk

NPV-at-Risk banking books per currency (*)
in EUR million | 2024 | 2023
| floored | floored
parallel ▼ | parallel ▲ | parallel ▼ | parallel ▲
By currency |  |  |  |
Euro | 7 | -1,473 | -291 | -645
US dollar | 274 | -266 | 186 | -178
Other | 321 | -329 | 131 | -146
Total | 602 | -2,068 | 27 | -969
EUR (floored at -100bps) is at +/- 120bps (2023: +/-110bps)
USD (floored at -100bps) is at +/- 120bps (2023: +/-110bps)

Year-on-year variance analysis (*)
The overall NPV sensitivity increased considerably over last year. The worst-case scenario remains the
parallel up, while the shock used in calculation for main currencies (EUR and USD) increased from 110bps to
120bps on the back of increased volatility observed in the market during 2023. This increase partially
explains the observed higher sensitivity. The other important factor impacting end of 2024 utilisation is
convexity: with lower interest rates, the increase in convexity on mortgages and savings accounts was
observed, especially for EUR positions. Lastly, Group Treasury actively managed the position and executed
investments for capital in the anticipation of possible further rates decreases.
The impact of the benchmark rate reform (*)
In line with the recommendations of the Financial Stability Board, a fundamental review of important
interest rates benchmarks has been undertaken. Some interest rate benchmarks have been reformed, while
others have or will be replaced by risk-free rates and discontinued. USD LIBOR in its current form ceased on
30 June 2023, whereas the cessation of GBP, CHF, JPY, and EUR LIBOR rates occurred on 31 December 2021.
To support these changes, the financial sector has issued several guidance papers and other initiatives to
help phase the transition. In 2024, the benchmark rate reform of only one reference rate, to which the Group
has significant exposures as at 31 December 2024, was continuing (i.e. WIBOR). The WIBOR rate is expected
to be ceased and replaced by a risk-free rate (RFR) by 31 December 2027.
The Steering Committee of the National Working Group (NWG SC) appointed in connection with the WIBOR
benchmark reform the decision (published on 10 December 2024) on the selection of the proposed index
with the technical name 'WIRF –' as the ultimate interest rate benchmark in Poland to replace the WIBOR
benchmark. On 24 January 2025, the Steering Committee of the National Working Group has selected target
name POLSTR (Polish Short Term Rate) for this index.The chosen index is calculated based on unsecured
deposits of Credit and Financial Institutions. Thus, the NWG SC has reviewed and modified its previous
decision to select WIRON as alternative RFR in Poland. The WIBOR rate is still expected to be ceased and
replaced by a new RFR ("WIRF -") by 31 December 2027.
Due to the discontinuation of WIBOR, ING, its customers, and in general those market participants with
exposure to such benchmark rates will be faced with a number of risks. These risks include legal, financial,
operational, reputational and conduct risk. The WIBOR rates are used in several of our lending and derivative
products, and hence a project team has been established to manage the transition. WIBOR transition is
especially important for our Polish subsidiary (ING Bank Śląski S.A.) with a significant amount of Polish zloty-
denominated assets and liabilities including derivatives that are continuously rebalanced to hedge the risk
exposures.
The tables below summarise the approximate gross exposures of ING that have yet to transition related to
USD LIBOR and WIBOR, excluding exposures expiring before the transition date 31 December 2027 for
WIBOR.

Non-derivative financial instruments to transition to alternative benchmarks (*)
| Financial assets non- derivative | Financial liabilities non-derivative | Off balance sheet commitments
in EUR million at 31 December 2024 | Carrying value | Carrying value | Nominal value
By benchmark rate |  |  |
USD LIBOR |  |  |
WIBOR | 19,202 | 134 | 1,544
Total | 19,202 | 134 | 1,544
in EUR million at 31 December 2023 |  |  |
By benchmark rate |  |  |
USD LIBOR | 915 | 16 | 9
WIBOR | 18,064 |  | 1,021
Total | 18,979 | 16 | 1,030

Derivative financial instruments to transition to alternative benchmarks (*)
| 31 December 2024 | 31 December 2023
in EUR million | Nominal value | Nominal value
By benchmark rate |  |
USD LIBOR |  | 151
WIBOR | 110,189 | 77,238
Total | 110,189 | 77,388

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> Market risk
sections 1.5.4 and 1.5.7 of Note 1 ‘Basis of preparation and material accounting policy information’ for
information on the Phase 1 and Phase 2 amendments.
As at 31 December 2024, Phase 1 reliefs are applicable to WIBOR indexed fair value and cash flow hedge
accounting relationships as there is uncertainty arising from the WIBOR reform with respect to the timing
and the amount of the underlying cash flows that the Group is exposed to. Therefore, for WIBOR financial
instruments designated in hedge accounting the applicable Phase 1 reliefs will continue to apply until the
relevant contract is modified. At that point in time, Phase 2 reliefs will become applicable. For these affected
fair value and cash flow hedge relationships, ING assumes that the 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 WIBOR
reform still meet the highly probable requirement, assuming the 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 that are used in the ING’s hedge accounting
relationships for which the Phase 1 amendments to IAS 39 were applied are:

Notional amounts of hedging instruments (*)
| 31 December 2024 | 31 December 2023
in EUR million | Nominal value | Nominal value
By benchmark rate |  |
WIBOR | 99,663 | 89,338

As at 31 December 2024, 32% (31 December 2023: 29%) of the notional amounts for WIBOR have a
maturity date beyond 31 December 2027. The notional amounts of the derivative hedging instruments
provide a close approximation of the extent of the risk exposure ING manages through these hedging
relationships.
Credit spread risk in banking books (CSRBB) (*)
Credit spread risk is defined as risk driven by the changes of the market price for credit risk, for liquidity and
potentially other characteristics of credit-risky instruments, which is not captured by another existing
prudential framework such as IRRBB or by expected credit/(jump-to-) default risk. CSRBB framework is
implemented based on EBA Guidelines. Metrics used are NPV-at-Risk, NII-at-Risk and Market Value Changes-
at Risk and view the positions across different accounting treatments.
Credit spread risk is not part of the internal risk transfer towards Group Treasury and therefore remains in
the business unit it originated in. Group Treasury itself is also an important driver of credit spread risk via its
HQLA investment portfolio and issuance activities.
Risk appetite limits are set on a combination of metrics and accounting scopes and are cascaded to local
ALCOs depending on the type of limit and materiality. Metrics and limits are monitored and reported
monthly to ALCO Bank, local ALCOs and various stakeholders.
Foreign exchange (FX) risk in banking books (*)
FX exposures in banking books result from core banking business activities (business units doing business in
currencies other than their base currency), foreign currency investments in subsidiaries (including realised
net profit and loss), and strategic equity stakes in foreign currencies. The policy regarding these exposures is
briefly explained below.
Core banking business (*)
Every business unit hedges the FX risk resulting from core banking business activities into its base currency
to prevent volatility in profit and loss. Consequently, assets and liabilities are matched in terms of currency,
within certain friction limits.
FX translation (*)
ING’s strategy is to protect the CET1 ratio against adverse impact from FX rate fluctuations, while limiting
the volatility in the profit and loss account due to this CET1 hedging and limiting the RWA impact under the
regulatory framework. Hedge accounting is applied to the largest extent possible. Taking this into account,
the CET1 ratio hedge can be achieved by deliberately taking foreign currency positions equal to certain
target positions, such that the CET1 capital and risk-weighted assets are equally sensitive in relative terms to
changing FX rates.
Risk profile – FX translation (*)
The following table presents the currency exposures in the banking books for the most important currencies
for the FX translation result. Positive figures indicate long positions in the respective currency. As a result of
the strategy to hedge the CET1 ratio an open structural FX exposure exists.
To measure the volatility of the CET1 ratio from FX rate fluctuations, different metrics are used, including the
CET1 Ratio-at-Risk. The impact is controlled via the Solvency and Financial Risk RAS.
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EBA Structural FX guidelines
In line with the EBA guidelines on Structural FX, upon permission from the competent authorities, certain
currency positions are being excluded from the calculation of net open currency positions under CRR article
352(2). The resulting impact is presented in the Pillar 3 disclosure.

Foreign currency exposures banking books (*)
in EUR million | Foreign Investments | Hedges | Net exposures
| 2024 | 2023 | 2024 | 2023 | 2024 | 2023
US dollar 1 | 11,251 | 10,337 | -4,823 | -3,416 | 6,429 | 6,921
Pound Sterling | 1,674 | 1,659 | -484 | -156 | 1,190 | 1,503
Polish Zloty | 4,395 | 3,976 | -1,616 | -1,254 | 2,779 | 2,722
Australian Dollar | 3,373 | 3,620 | -2,161 | -2,273 | 1,212 | 1,346
Turkish Lira | 557 | 517 |  |  | 557 | 517
Chinese Yuan | 2,439 | 1,815 | -830 | -348 | 1,609 | 1,466
Russian Rouble | 396 | 375 |  |  | 396 | 375
Romanian Leu | 913 | 895 | -176 | -134 | 736 | 761
Thai Baht | 1,266 | 1,128 | -838 | -697 | 428 | 431
Other currency | 3,346 | 3,704 | -2,748 | -2,897 | 599 | 806
Total | 29,612 | 28,024 | -13,675 | -11,175 | 15,936 | 16,849

*The FX sensitivity is expressed as the FX spot equivalent position.
Equity price risk in banking books (*)
ING maintains a portfolio with substantial equity exposure in its banking books.
Risk profile (*)
Equity price risk arises from the possibility that an equity security’s price will fluctuate, affecting the values
of the equity security itself as well as other instruments whose values react similarly to the particular
security, a defined basket of securities, or a securities index. ING’s equity exposure mainly consists of the
investments in associates and joint ventures of €1,679 million (2023: €1,509 million) and equity securities
held at fair value through other comprehensive income (FVOCI) of €2,562 million (2023: €1,885 million). The
value of equity securities held at FVOCI is directly linked to equity security prices with increases/decreases
being recognised in the revaluation reserve. Investments in associates and joint ventures are measured in
accordance with the equity method of accounting, and the balance sheet value is therefore not directly
linked to equity security prices. The equity sensitivity is expressed as the equity position.
Year-on-year variance analysis (*)
In 2024, the revaluation reserve equity securities increased by €664 million from €1,152 million to €1,816
million mainly due to revaluation of the shares in Bank of Beijing with € 652 million. In 2024, the equity
securities at fair value through OCI increased by €678 million.

Revaluation reserve equity securities at fair value through other comprehensive income (*)
in EUR million | 2024 | 2023
Positive re-measurement | 1,820 | 1,158
Negative re-measurement | -4 | -6
Total | 1,816 | 1,152

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 2024, ING
continued its strategy of undertaking trading activities to develop its client-driven franchise and deliver a
differentiating experience by offering multiple market and trading products.
With respect to the trading portfolios, Trading Risk Management (TRM) focuses on the management of
market risks of Wholesale Banking (mainly Financial Markets) as this is the only business line within ING
where trading activities take place. Trading activities include facilitation of client business and market
making. TRM is responsible for the development and implementation of trading risk policies and risk
measurement methodologies, and for reporting and monitoring risk exposures against approved trading
limits. TRM also reviews trading mandates and global limits, and performs the gatekeeper role in the product
review process (PARP).
Risk measurement (*)
ING uses a comprehensive set of methodologies and techniques to measure market risk in trading books:
Value at Risk (VaR) and Stressed Value at Risk (SVaR), Incremental Risk Charge (IRC), and stress testing.
Systematic validation processes are in place to validate the accuracy and internal consistency of data and
parameters used for the internal models and modelling processes.
Value at Risk (*)
TRM uses the historical simulation VaR methodology (HVaR) as its primary risk measure. The HVaR for
market risk quantifies, with a one-sided confidence level of 99 percent, the maximum overnight loss that
could occur in the trading portfolio of ING due to changes in risk factors (e.g. interest rates, equity prices,
foreign exchange rates, credit spreads, implied volatilities) considering the positions remain unchanged for a
time period of one day.
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> Market risk
Next to general market movements in these risk factors, HVaR also takes into account market data
movements for specific moves in, for example, the underlying issuer or securities. A single model which
diversifies general and specific risk is used. In general, a full revaluation approach is applied, while for a
limited number of linear trading positions and risk factors in commodity and equity risk classes a sensitivity-
based approach is applied. The potential impact of historical market movements on today’s portfolio is
estimated, based on equally weighted observed market movements of the previous year (260 business
days). When simulating potential movements in risk factors, depending on the risk factor type, either an
absolute or a relative shift is used.
The data used in the computations is updated daily. ING uses HVaR with a one-day horizon for internal risk
measurement, management control, and backtesting, and HVaR with a 10-day horizon for determining
regulatory capital. To compute HVaR with a 10-day horizon, the one-day risk factor shifts are scaled by the
square root of 10 and then used as an input for the revaluation. The same model is used for all legal entities
within ING with market risk exposure in the trading portfolio.
Limitations (*)
HVaR has some limitations: it uses historical data to forecast future price behaviour, but future price
behaviour could differ substantially from past behaviour. Moreover, the use of a one-day holding period (or
10 days for regulatory capital calculations) assumes that all positions in the portfolio can be liquidated or
hedged in one day. In periods of illiquidity or market events, this assumption may not hold. Also, the use of a
99 percent confidence level means that HVaR does not take into account any losses that occur beyond this
confidence level.
Backtesting (*)
Backtesting is a technique for the ongoing monitoring of the plausibility of the HVaR model in use. Although
HVaR models estimate potential future trading results, estimates are based on historical market data. In a
backtest, the actual daily trading result (excluding fees and commissions) is compared with the one-day
HVaR.
In addition to using actual results for backtesting, ING also uses hypothetical results, which exclude the
effects of intraday trading, fees, and commissions. When an actual or a hypothetical loss exceeds the HVaR,
an ‘outlier’ occurs. Based on ING’s one-sided confidence level of 99 percent, an outlier is expected once in
every 100 business days.
On an overall level in 2024, there was one outlier for hypothetical P&L and zero outliers for actual P&L. The
hypothetical outlier occurred in the third quarter of 2024, mainly due to higher interest rate and FX market
movements.
Stressed HVaR (*)
The stressed HVaR (SVaR) is intended to replicate the HVaR calculation that would be generated on the
bank’s current portfolio with inputs calibrated to the historical data from a continuous 12-month period of
significant financial stress relevant to the bank’s portfolio.
To calculate SVaR, ING uses the same model that is used for 1DHVaR, with a 10-day horizon. The data for the
historical stress period used currently includes the height of the credit crisis around the fall of Lehman
Brothers (2008-2009), and this 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 percent
confidence level. Trading positions (excluding securitisations) of ING, which are subject to specific interest
rate risk included in the internal model approach for market risk regulatory capital, are in scope of the IRC
model. By model choice, equity is excluded from the model. For the calculation of IRC, ING performs a Monte
Carlo simulation based on a multi-factor t-copula. In the multi-factor IRC model the supervisory asset
correlations are no longer applicable and the calibration of the correlations is based on historical market
data. The rating change is simulated for all issuers over the different liquidity horizons (i.e. time required to
liquidate the position or hedge all significant risks) within one year. Movements across different rating
categories and probabilities of default are governed by a credit-rating transition matrix. An internal
transition matrix along with internal LGDs is used, to comply with the consistency requirement. The financial
impact is then determined for the simulated migration to default, or for the simulated migration to a
different rating category, based on LGD or credit spread changes, respectively.
The liquidity horizon has been set to the regulatory minimum of three months for all positions in scope. ING
reviews the liquidity horizons on a yearly basis, based on a structured assessment of the time it takes to
liquidate the positions in the trading portfolio.
Stress testing and event risk (*)
Stress testing is a valuable risk management tool. In addition to the bank-wide stress-test framework as
described in the stress-testing section, Trading Risk Management performs stress tests specific to the trading
book with various frequencies. The trading book stress tests evaluate the impact on the bank’s trading book
under severe but plausible stress scenarios, using a full revaluation approach. The framework is based on
historical as well as hypothetical scenarios. The stress result is an estimate of the profit and loss caused by a
potential event and its worldwide impact for ING. The results of the stress tests are used for decision-making,
aimed at maintaining a financially healthy going-concern institution after a severe event occurs.
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> Market risk
In stress scenarios, shocks are applied to prices (credit spreads, interest rates, equity, commodities, and FX
rates) and volatilities. Depending on the type of the stress test, additional scenario assumptions can be
made, for example on correlations, dividends, or recovery rates. The structural scenarios are defined to cover
market moves in various directions and capture different asset class correlations. Scenarios are calculated
using full revaluation approach. The worst scenarios are determined for each product line, business line and
super business line, and compared against limits
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, and ING uses a variety of other controls to supplement these limits. Position
and sensitivity limits are used to prevent large concentrations in specific issuers, sectors, or countries.
Moreover, other risk limits are set with respect to the activities in complex derivatives trading. The market
risk of these products is controlled by product-specific limits and constraints.
Risk profile
The following chart shows the development of the overnight HVaR under a 99 percent confidence level and a
one-day horizon versus actual and hypothetical daily trading profits and losses. In calculation of the
hypothetica l daily profit and loss, the trading position is kept constant and only the market movement is
taken into account. The overnight HVaR is presented for the ING trading portfolio for 2024.
The risk figures in the above backtesting graph and in the table below relate to all trading books for which
the internal model approach is applied.

1d VaR for internal model approach trading portfolios
in EUR million | Minimum | Maximum | Average | Year end
| 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Interest rate 1 | 6 | 6 | 17 | 23 | 12 | 15 | 11 | 8
Equity and commodity | 2 | 2 | 7 | 4 | 4 | 3 | 6 | 2
Foreign exchange | 1 | 1 | 14 | 8 | 3 | 3 | 2 | 2
Credit spread | 2 | 2 | 12 | 10 | 4 | 5 | 3 | 5
Diversification 2 |  |  |  |  | -7 | -8 | -6 | -8
Total VaR 2 | 7 | 9 | 21 | 29 | 15 | 18 | 16 | 9

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.
Average 1D/10D HVaR and IRC over 2024 has decreased compared to 2023, while average 10D SVaR went
up. The overall average has decreased in 2024, for all trading portfolios. The first half of 2024 was
characterised by less elevated levels of volatility compared to 2023. In the second half of 2024, the volatility
increased due to the geopolitical risks stemming from the ongoing Russia-Ukraine and Middle East conflicts
and the impending US elections as well as risks of economic slowdown.The year-end 1D HVaR has increased
at period end of 2024, due to higher volatility in interest rates, equity and commodity markets.
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> Market risk
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 EUR million | 2024 | 2023
VaR (10 day 99%) |  |
1 Maximum value | 73 | 84
2 Average value | 48 | 53
3 Minimum value | 29 | 25
4 Period end | 47 | 25
Stressed VaR (10 day 99%) |  |
5 Maximum value | 175 | 116
6 Average value | 109 | 82
7 Minimum value | 56 | 57
8 Period end | 98 | 69
Incremental risk charge (99.9%) |  |
9 Maximum value | 232 | 304
10 Average value | 125 | 151
11 Minimum value | 64 | 48
12 Period end | 100 | 108
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

Standardised approach

EU MR1: market risk under standardised approach
in EUR million | 2024 | 2023
| RWA | RWA
Outright products |  |
1 Interest rate risk (general and specific) | 31 | 40
2 Equity risk (general and specific) |  |
3 Foreign exchange risk | 4,374 | 4,811
4 Commodity risk |  |
Options |  |
5 Simplified approach |  |
6 Delta-plus method |  |
7 Scenario approach |  |
8 Securitisation (specific risk) |  |
9 Total | 4,405 | 4,851

The MRWA under standardised approach have decreased compared to 2024.
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> Market risk
Internal model approach
Market risk regulatory capital has decreased during 2024 compared to 2023. This mainly reflects lower
interest rate positions during 2024, as well as the reduced regulatory-driven capital multiplier.

EU MR2-A: Market risk under Internal Model Approach
in EUR million | 2024 | 2023
|  | RWA | Total own funds requirements | RWA | Total own funds requirements
1 | VaR (higher of values a and b) | 1,964 | 157 | 2,508 | 201
(a) | Previous day’s VaR (VaRt-1) |  | 49 |  | 26
(b) | Multiplication factor (mc) x average of previous 60 working days (VaRavg) |  | 157 |  | 201
2 | SVaR (higher of values a and b) | 4,915 | 393 | 4,385 | 351
(a) | Latest available SVaR (SVaRt-1)) |  | 116 |  | 75
(b) | Multiplication factor (ms) x average of previous 60 working days (sVaRavg) |  | 393 |  | 351
3 | IRC (higher of values a and b) | 1,457 | 117 | 1,746 | 140
(a) | Most recent IRC measure |  | 116 |  | 108
(b) | 12 weeks average IRC measure |  | 117 |  | 140
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 | 340 | 27 | 810 | 65
6 | Total | 8,676 | 694 | 9,449 | 756

Sensitivities (*)
As part of the risk monitoring framework, TRM actively monitors the sensitivities of the trading portfolios.
Sensitivities measure the impact of movements in individual market risk factors (foreign exchange rates,
interest rates, credit spreads, equity and commodity prices) on profit and loss results of the trading positions
and portfolios.
The following tables show the five largest trading positions in terms of sensitivities to foreign exchange,
interest rate and credit spread risk factor movements. These largest exposures also reflect concentrations of
risk in FX risk per currency, interest rate risk per currency, and credit spread risk per country, rating and
sector. Due to the nature of the trading portfolios, positions in the portfolios can change significantly from
day to day, and sensitivities of the portfolios can change daily accordingly.

Most important foreign exchange year-end trading positions (*)
in EUR million | 2024 |  | 2023
Foreign exchange |  | Foreign exchange |
US Dollar | -93 | Japanese Yen | 61
Turkish Lira | 84 | Taiwan Dollar | -58
Korean Won | 62 | Romanian Leu | 58
Japanese Yen | 61 | Chinese Yuan | 49
Chinese Yuan | -37 | Hong Kong Dollar | -38

Most important interest rate and credit spread sensitivities at year-end (*)
in EUR thousand | 2024 |  | 2023
Interest rate (BPV) 1 |  | Interest rate (BPV) 1 |
Euro | -799 | Euro | -309
US Dollar | -198 | Czech Koruna | 71
British Pound | -189 | Korean Won | -41
Korean Won | -54 | US Dollar | -40
Philippine Peso | -54 | British Pound | -35
Credit spread (CSO1) 2 |  | Credit spread (CSO1) 2 |
United States | 193 | Germany | 405
Netherlands | -165 | Netherlands | 120
France | -113 | Korea | -111
Poland | 69 | Japan | 106
Germany | 49 | United Kingdom | 101

1 Basis point value (BPV) measures the impact on value of a one basis point increase in interest rates.
2 Credit spread sensitivity (CS01) measures the impact on value of a one basis point increase in credit spreads. Exposures to supranational institutions are not assigned to a specific country.

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> Market risk

Credit spread sensitivities per risk class and sector at year-end (*)
| 2024 | 2023
in EUR thousand | Corporate | Financial institutions | Corporate | Financial institutions
Credit Spread (CSO1) 1 |  |  |  |
Risk classes |  |  |  |
1 (AAA) | -2 | -118 |  |
2–4 (AA) | -44 | -27 | 12 | 50
5–7 (A) | 49 | -246 | 57 | 50
8–10 (BBB) | 93 | -76 | 106 | 13
11–13 (BB) | 38 | -13 | 25 | -25
14–16 (B) | 23 | -12 | 17 | -4
17–22 (CCC and NPL) | 4 | 2 | -8 | -20
Total | 162 | -489 | 208 | 65

1 Credit Spread Sensitivity (CS01) measures the impact on value of a 1 basis point increase in credit spreads.
Market risk capital
Economic capital
Market risk economic capital (MREC) measures the capital ING must hold to protect itself against losses due
to market risks. MREC covers the entire balance sheet of ING Bank, and includes market risk sub-types such
as: interest rate and basis risk, credit spread risk, customer behaviour risk, FX risk, equity risk and commodity
risk.
MREC is calculated as the 99.9 percent worst value loss that can be incurred from one-year shocks to the
underlying risk drivers. While aggregating the different economic capital market risk figures for the different
portfolios, diversification benefits are taken into account as it is not expected that all extreme market
movements will appear at the same moment.
Regulatory capital
Market risk regulatory capital is the amount of capital that ING has to hold to protect itself against losses
due to market risks, as required by the financial regulator. From a regulatory capital perspective, market risk
stems from all the positions included in a bank’s trading book, as well as from commodity and foreign
exchange risk positions in the whole balance sheet of ING Bank. According to the Capital Requirements
Regulation (CRR/CRD IV), regulatory capital (own funds requirements) for market risk can be calculated using
the standardised approach or an internal model approach.
FX risk in banking book
Regulatory Capital requirements for FX risk in banking book is set out in Part 3, Title IV, Chapter 3 of the
Capital Requirements Regulation (CRR). This is further supplemented by EBA guidelines on Structural FX for
the calculation of the net open currency positions (CRR Art 352(2)). ING uses the standardised approach
where the capital requirement is 8 percent of this total net currency and gold position.
Equity risk in banking book
Equity regulatory capital is included as part of Credit RWA as prescribed by regulations. ING uses the simple
risk weight approach (SRWA) under the IRB (internal ratings-based) approach for the calculation of
Regulatory Capital as described in Capital Requirements Regulation (CRR) Art 155. Under SRWA, the RWA
amount is calculated by multiplying the risk weight with the exposure value (not tailored to a specific
internal model). The capital requirement is 8 percent of the RWA value.
Trading book
ING has regulatory approval to use an internal model to determine the regulatory capital for the market risk
in all trading books of ING. Market risk capital of trading books is calculated according to the CRR, using
internal HVaR, SVaR and IRC models, where diversification is taken into account. Collective investment
undertakings (CIUs) 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.
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Funding and liquidity risk (*)
Introduction (*)
Funding and liquidity (F&L) risk is the risk that ING or one of its subsidiaries cannot meet their financial
obligations upon their maturity date at a reasonable cost and in a timely manner. ING incorporates funding
and liquidity risk management in its business strategy and has established a funding and liquidity risk
framework to manage these risks within pre-defined boundaries.
The following sections elaborate on the various elements of funding and liquidity risk:
• Funding and liquidity risk framework;
• Funding and liquidity risk management strategy and objectives;
• Funding and liquidity adequacy and risk appetite;
• Funding and liquidity risk indicators;
• Liquidity stress testing; and
• Contingency funding planning.
Funding and liquidity risk framework (*)
Macroeconomic and market environment are important considerations in ING’s F&L framework. The
macroeconomic environment is comprised of various exogenous factors over which ING has no control, but
which may have a material impact on ING’s F&L position. The main macroeconomic factors analysed on a
regular basis include:
• performance of global and local macroeconomic indicators, e.g. shifts in GDP, inflation rates,
unemployment rates, and public deficit/surplus;
• developments and risks arising from geopolitical tensions and trends;
• monetary policy with a focus on the alternative monetary measures employed by central banks in recent
years as a result of the global energy crisis and the recent period of high inflation; and
• regulatory requirements, e.g. understanding the changing regulatory landscape as well as the impact of
ING’s actions on existing regulatory boundaries.
The strategic ambitions of ING, together with the design and execution of the funding plan, are assessed
under both current and projected market conditions. An emphasis is placed on understanding overall market
trends and developments, credit rating changes and peer comparisons.
The EB, MBB and staff departments from the CRO and CFO domains, as well as Group Treasury, have
oversight of, and are responsible for, managing funding and liquidity risks.
Funding and liquidity management strategy and objectives (*)
The main objective of ING’s funding and liquidity risk management is to maintain sufficient liquidity to fund
the commercial activities of ING both under normal and stressed market circumstances across various
locations, currencies and tenors.
ING’s funding consists mainly of retail and corporate deposits contributing 53 percent and 22 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
| 2024 | 2023
Funding type |  |
Customer deposits (retail) | 52% | 52%
Customer deposits (corporate) | 23% | 27%
Lending/repurchase agreements | 5% | 7%
Interbank | 2% | 2%
CD/CP | 5% | 5%
Long-term senior debt | 6% | 5%
Subordinated debt | 7% | 2%
Total | 100% | 100%
1 Liabilities excluding trading securities and IFRS equity |  |

Funding and liquidity adequacy and risk appetite (*)
ING identifies key drivers of short-term and future liquidity and funding needs on an ongoing basis through
the periodic risk-identification process. Taking into consideration the identified risk drivers, ING regularly
assesses its current and future liquidity adequacy and, if deemed necessary, takes action to further improve
ING’s liquidity position and maintain sufficient counterbalancing capacity. A Liquidity Adequacy Statement is
formulated on a regular basis to substantiate and reflect the management view on the current funding and
liquidity position as well as the potential future challenges. The Liquidity Adequacy Statement is an
important part of ING’s ILAAP process. Additionally, ING completes ad hoc funding and liquidity assessments
if deemed necessary. In 2024, ING focused on the implementation of activities which steered the LCR higher
and diversified the funding mix in order to ensure funding stability for the bank into the F&L risk appetite.
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> Funding and liquidity risk
ING assesses its F&L adequacy through three lenses – stress, economic and normative:
• Through the stress lens, ING evaluates its ability to withstand periods of prolonged F&L stress for both
normative and economic requirements or limits under idiosyncratic, market-related, combined
idiosyncratic and market-related, and climate risk scenarios, which lead to customer deposit outflows,
deterioration of access to funding markets, and lower liquidity value of counterbalancing capacity.
• Through the economic lens, ING assesses the extent to which its customers, professional counterparties
and investors are comfortable to provide deposits and funding in the tenors, currencies and instruments
necessary to sustainably fund the business (intraday, short-term and long-term) in a going-concern
situation.
• Through the normative lens, ING ascertains that the bank is in the position to meet current and future
home and host regulatory requirements.
For each lens, ING has established a related set of risk appetite statements, which define ING’s risk appetite,
commensurate with the principles of liquidity adequacy.
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, combined (idiosyncratic and market-
wide) and climate-stress scenarios. The design of the framework is based on empirical evidence
supplemented by expert judgment. The framework can be extended to additional ad-hoc scenarios. For
example, it can be used as input for firm-wide stress testing and reverse stress testing.
Outcomes of the stress tests are considered in the key aspects of ING’s F&L risk framework and F&L risk
management, including:
• Risk Appetite Framework (through risk appetite statements);
• Risk identification and assessment;
• Monitoring of the liquidity and funding position;
• Business actions (if needed);
• Contingency funding plan; and
• Early-warning indicators.
The funding and liquidity stress-testing framework is also subject to regular internal validation by model
validation.
In line with supervisory expectations, ING’s liquidity position is stress tested on (at minimum) a monthly basis
using scenarios that form part of the F&L risk appetite statement. The results of all internal stress scenarios
are monitored and assessed on a monthly basis. In addition, ad hoc scenarios based on current economic
and market developments are run to determine their potential impacts on the funding and liquidity position
of ING. In 2024, this included stress-test scenarios assessing the impact of a shutdown of US short- and long-
term funding markets and FX markets. The internal stress scenarios and their corresponding results serve as
input in the decision on holding additional contingency measures.
Contingency funding planning (*)
ING’s contingent F&L risks are addressed in its Contingency Capital and Funding Plan (CCFP).The objectives of
the CCFP include the following:
• Establishment of a monitoring framework to detect approaching contingent events as well as their
impact on ING’s F&L position;
• Provision of a plan for responding to various and increasing levels of a bank’s liquidity and capital shortfall
under adverse and stressed conditions;
• Designation of management responsibilities, crisis communication methods and channels, and reporting
requirements;
• Identification of contingent capital and liquidity sources that can be used under various and increasing
adverse as well as stressed circumstances; and
• Description of steps which should be taken to ensure that the bank’s sources of capital and liquidity are
sufficient to fund scheduled operating requirements and meet the institution’s commitments with
minimal costs and disruption.
The contingency funding measures are developed in conjunction with the ING Recovery Plan and are
reviewed and tested on a regular basis.
1 In line with the European Central Bank (ECB) guide on Climate-related and Environmental risks
2 As per the ING Bank Risk Identification and Risk Assessment Procedure for ICLAAP purposes
3 The double materiality assessment is performed in line with CSRD requirements
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Environmental, social and governance risk
Introduction
ESG risk is defined as any negative financial and/or non-financial impact on ING due to the present or future
impact to/dependencies from factors on and stemming from ING’s full value chain.
ESG risk is not an independent risk category/risk type but rather a set of drivers 1 affecting the likelihood and
severity of existing risk categories/risk types. ESG risk is an overarching set of risk drivers affecting:
• financial risks: credit risk, market risk, funding and liquidity risk;
• non-financial risks and compliance risk; and
• other overarching risks: model risk and business and strategy risk.
The risk drivers 2 are defined as risk events that lead to an impact on ING’s financial solvency or liquidity &
funding position via the above-mentioned risk types. Our comprehensive approach ensures we integrate ESG
considerations into our risk management practices, aligning with our commitment to sustainable growth
and resilience.

Definitions
ESG Factors ESG factors are defined as environmental, social or governance matters that may have a positive or negative impact on the non-financial/financial performance or solvency of an entity, sovereign, or individual. ING's ESG taxonomy of ESG factors are defined through the consideration of the CSRD and EUT. | Value chain Value chain is a concept derived from CSRD Annex II as 'the full range of activities, resources and relationships related to the business model(s) of the undertaking and the external environment in which it operates'. For ING, the concept of the value chain defines the scope of the ESG risk management lifecycle. | Double Materiality 3 ING must identify both actual and potential: ▪ impacts on people and environment (impact materiality, inside-out), as well as; ▪ The sustainability matters that impact ING's financial positions (financial materiality, outside- in). Impact materiality and financial materiality assessments are interrelated, as financial materiality may stem from negative impact, dependency on resources and context analysis. ING defines material ESG factor per value chain for both impact and financial materiality.
Environment
| ▪ Climate-change adaptation ▪ Climate-change mitigation ▪ Pollution ▪ Water & marine resources ▪ Circular economy ▪ Biodiversity and ecosystems
Supply chain
Own operations
Social | Wholesale banking
| ▪ Own workforce and workers in the value chain ▪ Customers ▪ Communities | Business banking
Retail banking |
Governance | Treasury & other investments |
| ▪ Business Conduct |  |

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> Environmental, social and governance risk
The ESG risk framework
The environmental, social and governance (ESG) risk framework provides a definition of ESG risk, the
governance structure supporting the management of ESG risk, and an overview of the various roles and
responsibilities related to ESG risk. The framework assists in managing ESG risk effectively through the
application of the risk management process at various levels of the organisation.
Governance
ING has a governance structure with well-defined, transparent, and consistent lines of responsibility in
managing ESG risk in line with the three lines of defence. For more information, see ‘Three lines of defence’.
ESG risk bodies
The ESG committees and bodies at ING are responsible for overseeing and integrating ESG matters into ING’s
strategy and daily operations in line with our sustainability governance. The following committees, bodies,
and their associated charters are relevant with regard to the framework:
• Supervisory Board ESG Committee (SB-ESG) : The ESG Committee assists the SB by generally monitoring
and advising on relevant ESG developments.
• The key risk committees : A cting within delegated authorities granted by the MBB support on
implementation and execution of the controls mitigating material ESG risks.
• Executive Board (EB) and Management Board Banking (MBB ): ING’s EB/MBB has overall responsibility for
the ESG risk framework and is accountable for having it implemented and embedded.
• ESG Risk Committee (ERC) : A standing committee that receives its mandate from the MBB, and is
responsible for the approval of ESG risk procedures and mandatory instructions as well as its rollout in the
different impacted functions. In addition, it advises MBB and MBB-delegated committees on the
implementation and execution of the controls mitigating material ESG risk.
Organisational bodies
Management of ESG risk is embedded within all material risk types across the three lines of defence, with E
fully integrated and S&G in the integration phase during 2025. Within the CRO domain, ESG risk governance
is integrated and aligned with the existing governance structure around global risk functions responsible for
the functional steering of the respective risk categories/risk types globally. The goal of the ESG Risk
department is to ensures the adaptation of the various risk functions to account for ESG risk. The
operationalisation of ESG risk between the global and local functions and across the three lines of defence is
depicted below.

|  |  |  |  |  |  |  |  |  |  |  |  | Global |  | Local |  |  |  |  |  |  |  |  |  |  |  |
ESG Risk Department |  | Develops and oversees the implementation of the ESG risk framework, policy and instructions |  |  |  |  |  |  |  |  |  |  |
Global 1 st line |  | Implements the framework, policies and instructions |  | Implements the framework, policies and instructions |  | Local 2 nd line
Global 2 nd line |  | Reviews and provides oversight of 1 st line implementation |  | Implements the framework, policies and instructions |  | Local 1 st line
|  |  |  |  |  |  | Reviews and provides oversight of 1 st line implementation |  | Local 2 nd line
| Corporate Audit Services (CAS) | Provides independent assurance |  |

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> Environmental, social and governance risk
Managing ESG risk
The ESG risk framework assists in managing ESG risk effectively through the application of the risk
management process at varying levels of the organisation. The risk cycle describes the processes by which
ING can identify, assess, mitigate, monitor, and report ESG risk integrated within the existing risk types.
Risk identification

E1: Climate Change; E4: Biodiversity and Ecosystems
S1: Own workforce; S4: Consumers and end-users
G1: Business Conduct

Transmission channels
Business ▪ Property damage & Business disruption ▪ Stranded assets & New capital expenditure Households ▪ Loss of income ▪ Property damage Macro economy ▪ Shift in prices ▪ Productivity changes ▪ Labour market frictions
Social and Governance ▪ Negative customer and investor preference ▪ Legal liability for damages caused and loss of customer preference ▪ Negative impact on workforce ▪ Exposure to controversies

Material: Financial & Non-financial risks
Risk category | Time horizon
Very short-term | Short-term | Medium - Long term
Credit Risk |  | E1 / E4
Compliance Risk | S4 / G1 | E1 / S4 / G1
Market Risk | In scope of the assessment, no material risks identified
Liquidity Risk
Non-financial Risk | S1
Business Risk | E1 |

It is our policy to formalise and maintain an up-to-date ESG impact and risk inventory. This inventory
includes descriptions of the drivers of ESG negative impacts and ESG risks. Regarding the risk drivers, the
inventory further details their transmission channels and maps them to the risk categories where ESG risk
drivers can materialise. Additionally, the inventory briefly outlines the drivers of positive impact and
opportunities.
Risk assessment
ESG metrics are defined and assessed against predetermined thresholds to determine materiality. The
outcome of the double materiality assessment (DMA) defines the way ESG risk is adopted in the business
strategy and the risk management of each risk category/risk type to be mitigated. In addition to the results
of the DMA, ING considers some ESG factors to be important 4 (such as the negative impact of some sectors
on affected communities) and the risk assessment and due diligence processes that follow would consider
these factors as well.
T he below visualisation and paragraphs illustrate the mapping of ESG risk drivers to financial and non-
financial risks across different time horizons.
4 Important ESG factors are determined on a case by case basis and consider international standards such as the OECD Guidelines for
Multinational Enterprises on responsible business conduct and the UNGPs on Business and Human Rights.
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> Environmental, social and governance risk
Credit risk
• Climate transition risk
ING has credit exposure to clients whose business models might not be aligned with the transition to an
environmentally sustainable economy. As a result, these clients might face a higher risk of business
disruption and reduced earnings, which may impair their ability to repay loans or meet other financial
obligations. Collateral depreciation is also possible in adverse climate conditions.
Impact on PD: Entities may be affected by increased operating costs and reduced revenue due to fines,
taxes and adaptation costs which, in turn, might decrease clients' affordability and ability to repay, thus
increasing PDs.
Impact on LGD: The transition to environmentally sustainable economies might make carbon intensive
assets in ING’s lending portfolio more vulnerable to disinvestment and demand – leading to potential
write-offs, stranded assets, early retirement of assets (based on carbon profiling/intensity) and a
decrease in the collateral value for brown assets. This in turn might result in higher loan to values (LTVs)
and LGDs.
• Climate physical risk
Climate-related physical impacts can lead to significant losses, unexpected expenses, and reduced
income and profits for borrowers. This may impair their ability to repay loans, thereby increasing credit
risk for ING. Additionally, the frequency and intensity of extreme events can affect the value of real estate
or other collateral, altering the relationship between the loan and the asset's value.
Impact on PD: Acute and chronic risks can negatively impact cash flows of affected entities: 1) as
damaged physical capital might generate less income, 2) operational disruptions might lead to decreased
productivity and increased operational costs and 3) increased insurance premiums. This might decrease
clients' affordability and ability to repay debt and therefore increase PDs. For sovereign and municipal
exposures, the income effects from physical risk events may primarily arise through lower tax revenues
and higher spending channels to compensate for negative impacts and adaptation costs.
Impact on LGD: Write-offs, asset devaluation and early retirement of existing assets due to acute events
decrease the value of collateral and have a negative impact on LTVs, and therefore LGDs.
• Biodiversity and ecosystems (impact on species)
The negative impact on biodiversity, which can result in a demise in natural resources, can disrupt clients’
operations, leading to financial losses.
Financial losses can also occur due to reputational damage and litigation risks. This may leave them unable
to repay loans or meet their obligations on other financial transactions at the same time as reducing the
value of the business.
Compliance risk
Assuming that attention to greenwashing by society and stakeholders will increase over the upcoming years
and decades, the inherent risk may rise accordingly. Additionally, compliance risk may increase in the long
term if ING does not meet its externally communicated commitments.
Non-financial risk
Financial materiality of our own workforce can stem from two risks. Firstly, from a reputational risk whereby
employees are not happy and, for example, file a lawsuit or raise an issue in the media, which can
potentially affect ING’s financial position, financial performance and cash flow. This risk is particularly
relevant when ING publicly discloses on targets. Secondly, from a turnover risk whereby the risk of
employees leaving the bank results in a position that needs to be filled within the bank that can negatively
affect ING’s financial position.
Business and strategy risk
High impact from transition risk may arise in the event that ING fails to meet its sustainability strategy. For
instance, negative perceptions can lead to a loss of trust among ING’s customers and stakeholders, which
can result in customers choosing to take their business elsewhere. ING may therefore face increased costs
related to customer acquisition and retention efforts. Rebuilding a damaged reputation may require
significant investment in marketing and public relations. This can increase operational costs and divert
resources away from core business activities, ultimately affecting profitability.
Measurement methodologies and tools
ING measures its exposure to ESG risks by assessing risks through risk quantification methodologies and
tools. The methodologies take into account qualitative and quantitative criteria, different time horizons as
well as scenario analysis and stress testing. Quantification leverages on top-down and bottom-up
approaches, when applicable. During 2024, ING continued working on multiple initiatives to support our risk
assessment process, focusing on, though not limited to, the initiatives below:
• Physical risk tool : ING has developed a tool to measure and assign a level of physical risk for four chronic
and nine acute physical risks across the short, medium and long term for portfolios and geographies in
which ING operates. This range of hazards is recognised under EU Taxonomy. The thorough selection of
hazards means this tool caters for broad, continent-spanning risks as well as local and nuanced ones. The
tool has been developed using physical risk maps obtained and recognised by academically reputable
sources.
• Transition risk scorecard is used by ING to quantify transition risk with a scorecard approach at client
level. Methodology helps to identify the pool of high-risk clients within specific sectors, in order to
subsequently manage these high-risk subsegments, taking into account ING’s public commitments and
sector-specific climate strategies (Terra approach). This pool of high-risk clients is subsequently managed
via the climate risk appetite setting.
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> Environmental, social and governance risk
• ESG risk-assessment tool: For WB, ING has developed a new ESG risk-assessment approach which
considers the (climate and) environmental, social and governance risk factors, negative impacts and
dependencies of our WB customers, and fully integrates the previous ESR framework. Tooling was
developed to support the implementation of the assessment approach in the credit granting process. The
new approach was gradually rolled out in 2024, and enhancements and refinements will continue during
2025. Depending on the ESG risk-assessment outcome, mitigation actions and escalation to the ESR team
for additional due diligence and (binding) advice might be required. In 2024 , we began a comprehensive
ESR framework review. The implementation efforts of the ESR framework will continue in 2025 and will be
rebranded as ING’s new ESG risk framework. For more information about ESR at ING, see our corporate
website.
• Stress testing : ING continues enhancing its climate stress-testing methodology to assess the impact of
climate risks on corporate and mortgage exposures from a credit risk perspective. This methodology
builds on existing stress tests (e.g., ICAAP, EBA) and adds overlays for the impact of transition and
physical risks. For transition risk, a data-driven approach reflects increased carbon prices and energy
costs, focusing on energy performance certificates (EPC) level for mortgages and NACE sectors for
corporates. For physical risk, a dedicated approach assesses flood risk impacts on the mortgages
portfolio. The climate stress-test outcome shows a manageable short-term financial impact for ING, as
sufficient contingency measures are in place. A dedicated long-term methodology has been developed to
assess the impact on provisions under various scenarios and portfolio assumptions. Additionally,
methodologies are available to evaluate the impact of climate risk on market risk (banking and trading
book) and other risks, including non-financial, issuance, business, and model risks.
Risk mitigation
The mitigation of the identified risks in line with the risk appetite can be performed through several risk
mitigating strategies, such as reducing risk level, avoiding risk, accepting risk or transferring the risk. The
measures are embedded as part of the updates of the existing policies and procedures in the different risk
categories/risk types in order to mitigate material ESG risk. Mitigation activities can be performed at a
process, product, portfolio, client or transaction level and include, but are not limited to:
• engaging with high ESG risk counterparties to understand and support their mitigation plans;
• setting RAS to limit the level of acceptable risks with consequence management attached;
• incorporating ESG risks in the collateral valuation process; and
• ensuring appropriate business continuity plans and insurance are in place to reduce the impact of more
frequent and severe ESG events for ING’s value chain, thus reducing the residual risk.
Risk monitoring, reporting and disclosures
ING aims to provide regular and transparent reports and regulatory disclosures related to ESG so that the
management body and all relevant units in ING receive ESG risk information in a timely, accurate, concise,
clear and meaningful manner, containing relevant information on the identification, assessment,
measurement, monitoring, and management of ESG risk.
The ESG risk dashboard consists of comprehensive and integrated ESG risk-related, financial and non-
financial information on business activities and own operations, summarising the following:
• Results of the double materiality assessment, detailing negative impacts, financial and non-financial
materiality for each value chain segment;
• ING key climate risk indicators for material ESG risks across value chain segments. The depth of reporting
is informed by the materiality assessments performed; and
• Outcome of the latest climate stress-testing assessment.
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Non-financial risk
Introduction
Non-financial risk (NFR) is defined as the risk of financial loss, legal or regulatory sanctions, or reputational
damage due to inadequate or failing internal processes, people and systems, a failure to comply with laws,
regulations and standards, or external events.
Non-financial risk management
Risk categories
ING categorises non-financial risks in the following 10 areas:
• Continuity risk is the risk of financial loss, regulatory fines, litigation, business disruption and/or
reputational damage due to events (e.g. natural disasters, power outages, terrorism) leading to a
situation that threatens business continuity.
• Information (technology) risk (including cyber risk) is the risk of financial loss, regulatory fines, litigation,
business disruption and/or reputational damage due to breaches of confidentiality, integrity or
availability within business processes, the supporting IT systems, of information or lack of information
quality, and business disruptions (loss of people, processes, systems, data, premises).
• Fraud is the deliberate abuse of procedures, systems, assets, data, products and/or services of ING by
those who intend to benefit themselves deceitfully or unlawfully and/or others. This definition of fraud is
specified in the following two categories of fraud:
• Internal fraud: acts of fraud that involve 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.
• Control risk is the risk of financial loss, regulatory fines, litigation, business disruption, reputational
damage due to not complying with controls set through governance procedures and/or project
management methods caused by improper or insufficient monitoring (testing) of entities or activities.
• Processing risk is the risk of financial loss, regulatory fines, litigation, business disruption and/or
reputational damage due to unintentional human error during (transaction) processing.
• Unauthorised activity risk is the risk of financial loss, regulatory fines, litigation, reputational damage due
to unauthorised employee activities, approvals or overstepping of authority (based on intentional human
behaviour, not intended to deceitfully or unlawfully benefit themselves or others).
• Personal and physical security risk is the risk of personal harm, financial loss, regulatory fines, litigation
loss, business disruption, reputational damage due to personal or physical security risk.
• Employment practice risk is the risk of financial loss, regulatory fines, litigation loss, business disruption,
reputational damage due to ineffective employee relations or inadequate psychosocial safety caused by
breaches of employment or discrimination or health and/or safety legislation, regulations or agreements,
or collective labour action.
• Compliance risk is the risk of financial loss, regulatory fines, litigation, business disruption and/or
reputational damage due to the impairment of ING Group’s integrity, leading to damage to ING’s
reputation, legal or regulatory sanctions, or financial loss, as a result of a failure (or perceived failure) to
comply with applicable laws, regulations, and standards.
In line with ING’s strategy on sustainability and regulatory requirements relating to ESG risk management,
the NFR Framework has been updated to ensure ESG risk is properly embedded in our risk management
cycle and material risk types in line with the overarching ESG risk management framework.
Measurement approach
ING uses an internal model in line with the advanced measurement approach (AMA) to determine the
minimum regulatory and economic capital amounts that are necessary to cover potential losses resulting
from non-financial risks. This model calculates the non-financial risk exposure by combining a forward-looking
and a backward-looking view on non-financial risk events. ING reports the outcome of its AMA model quarterly.
As of 1 January 2025, following CRR3 regulations, the AMA is replaced by the standardised measurement
approach, a non-model-based formula to calculate regulatory operational risk capital. The internal model has
been redesigned and will be used for economic capital and stress testing purposes (Pillar II).
Main developments in 2024
Continuity risk
Providing safe, secure, and seamless services for our customers is at the heart of ING’s strategy. Operational
and IT resilience measures are key in preventing disruptions and ensuring a quick recovery in the event of a
disruption. In 2024, ING analysed, updated and mapped most critical business services and the related
processes and systems, including the facilities, people, third parties and intragroup parties and data therein.
These value chains continue to be tested against severe but plausible scenarios in order to continuously
improve and enhance our operational and IT resilience. Furthermore, ING continued with the implementation
of the Digital Operational Resilience Act (DORA), which aims to further strengthen the digital operational
resilience of financial institutions.
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> Non-financial risk
Information (technology) risk
The mission of information (technology) risk is to support ING in staying safe and secure, by preventing and
mitigating the risk of unauthorised access to IT systems and processes and protecting the confidentiality,
integrity and availability of the data processed and stored therein. To support this mission, IT Risk operates a
framework that adapts to emerging or changing risks as a result of, among other things:
• the ongoing release of new regulations and (local) laws, such as the EU AI Act, DORA, PSD3, which require
more reporting on how IT systems process data and how customer principles are safeguarded and
remain resilient;
• rapidly evolving threats, including increasingly sophisticated cyber attacks, as a result of new modus
operandi in combination with the availability of digital capabilities (such as artificial intelligence, QR code
phishing or quantum computing);
• further digitalisation of value chains and the use of emerging technologies and digital products therein,
such as artificial intelligence and digital currencies; and
• geopolitical risk.
Identity & access management (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
confidentiality, integrity and availability of 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 global IAM team in the Chief
Information Security Office (CISO), which aims to ensure that emerging threats and improvements inside and
outside ING are identified and responded to. In 2024, ING continued with the standardisation and
harmonisation of processes, workflows, and automation of IAM controls as well as the further roll-out of
supporting global tooling.
External fraud
The continuous evolution of threats against financial services including developing technologies such as
generative AI and deep fake continues to present fraud-management challenges both in the short and
medium-term. Criminals are increasingly targeting our customers. In 2024, we saw more AI-enabled social
engineering fraud, scams and authorised push payments, often through social media, online marketplaces
and third-party communication platforms.
There has been a noticeable rise in the incidence of fraud affecting credit facilities, frequently involving the
use of forged documentation, with or without customer consent. An increase in impact on fraud on credit
facilities is observed, often caused by using forged documentation, with or without customer consent. ING
has mobilised its experts to further strengthen this area of concern on prevention and detection.
Furthermore, the rise in scams is a major concern for financial institutions and their customers in general,
who suffer severe consequences when targeted. Although financial institutions have limited means to
prevent authorised transactions, they prioritise fraud prevention through new processes, technology and
ongoing customer education and awareness. To protect customers and society, ING is enhancing its fraud
resilience by collaborating with financial industry peers, law enforcement, government and other industries.
This collaborative approach is essential for effectively combating the societal challenge of fraud.
ING’s newly created Global Fraud Target Operating Model is aimed at ensuring a globally aligned approach
and brings together skilled fraud management experts from across domains, ensures continuous evolution
of fraud capabilities and ensures that ING’s business and fraud strategy remains aligned on fraud threats,
market best practices, applicable law and legislation, risk appetite and operational targets.
Data risk management
Data risk management, as part of control risk management, focuses on maintaining high-quality data that is
readily available for business or regulatory purposes, in a secure and compliant way.
As reliance on data and data volumes is continuing to rise at a fast pace, one of our top priorities remains to
address any societal concerns, data-related regulatory requirements, and risks in the use of data-driven
technology like AI. ING has set up governance and initiatives to structurally address the ethical handling of
data and implement AI acts in its policies and way of working.
ING’s data strategy is to deliver on ING’s promise and to improve governance around data, data quality and
data risk management in general. Data governance has improved from senior management level to that of
data owners and data users. The ING data strategy is also starting to deliver on business value, for example
through a master system for customer onboarding and customer administration, which aims to create a
single and complete view on ING customers.
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Compliance risk
Introduction
ING aims to be compliant with applicable internal rules and external laws and regulations at all times, while
also taking societal expectations into consideration. A robust compliance risk management framework
supports ING in conducting its business activities in line with these objectives. Compliance risk is defined as
the risk of ING’s integrity being impaired, which can result in reputational damage, legal, or regulatory
sanctions or financial loss, due to failure (or perceived failure) to comply with applicable laws, regulations
and standards.
Within ING we apply the following compliance risk categories:
• Financial crime risk refers to the risks of the bank’s products and services being abused for illicit purposes,
generating, facilitating or disguising financial and/or economic crimes (FEC).
• Conduct risk refers to compliance risks arising from (the perception of) breaching our obligations towards
customers and/or other parties, including inappropriate market conduct.
• Data protection (personal data protection, data retention) risk refers to the personal data protection risk
of financial loss (regulatory fines, reputational damage) due to not protecting the personal data rights of
individuals as required, and as to data retention risk, to having the records being destroyed too soon or
retained too long.
The Compliance organisation has the mission to drive compliance risk management by desire and design
throughout the organisation. Compliance's primary role is advising, challenging, and overseeing the first line
of defence in how they manage the compliance risks, as well as raising awareness and stimulating a sound
compliance risk culture.
Training and awareness
At ING we believe all our people play a role in protecting our customers, the bank and, through that, society
too. A sound risk culture is promoted by empowering our employees with the skills and knowledge they
need to manage compliance risks. In 2024, we continued to train our people with mandatory trainings on
financial crime, fraud, conduct and data protection. Senior Management (MBB and SB) are trained on various
compliance risk topics based on a multi-year training plan.
Financial crime and fraud prevention
Financial crime and fraud prevention in the first line of defence and financial crime compliance continue to
play a major role in our aim to make sure we only engage and do business with people and entities that
meet regulatory requirements. Knowing who we do business with is vital to keeping ING safe, secure, and
compliant. As part of our ongoing anti-money laundering efforts, we continuously assess (proposed)
relationships with customers, monitor and screen transaction s to fulfill our regulatory and reporting
obligations and review potentially unusual transactions and/or suspicious transactions and, where
applicable, report these to the relevant authorities.
Financial crime risk management
The day-to-day responsibility for the oversight of ING’s compliance with our legal and regulatory obligations,
in relation to financial crime risks, sits with the global head of Financial Crime Compliance, who reports to
ING’s CCO, with oversight by the CRO. As a global financial institution combatting financial crime, we comply
with anti-money laundering and counter-terrorism financing (AML/CTF) laws and regulations, have
established a reasonable and risk-based control framework to mitigate continuously evolving financial crime
risk, and seek to provide useful information to relevant government agencies.
Operational effectiveness (OE)
ING’s global KYC policy and related control standards set the minimum requirements and control objectives
for all ING entities to guard against involvement in financial crime activity, while reflecting relevant national
and international laws, regulations, guidance documents, and guidelines from national, European and
international authorities, (supra)national risk assessments, and industry standards. In 2024, our focus was
on maintaining a sustainable level of OE through oversight and challenge as the second line of defence, as
the bank's KYC activities have matured. Being safe, secure and operationally effective in managing KYC
continues to be an important part of our strategy.
Bribery and corruption
Bribery and corruption undermine business confidence and corporate integrity, hinder fair business
competition, and harm international trade. Bribery and corruption risks are considered as part of our client
and third-party due diligence, and financial crime risk monitoring measures. This supports our zero-tolerance
approach to bribery and corruption, which is also part of the governance elements of our sustainability
objectives.
Customer tax compliance
Compliance with customer tax-related regulations and reporting obligations, under the Foreign Account Tax
Compliance Act (FATCA), the Common Reporting Standard (CRS), and Mandatory Disclosure Rules, aims to
ensure that ING is not involved in facilitating tax-related financial crime, such as harmful aggressive tax-
avoidance schemes, on behalf of its customers.
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> Compliance risk
Sanctions
It is ING’s policy to take into consideration the applicable sanctions regimes as imposed by international
authorities and by local mandatory sanctions law (as applicable). ING’s policy generally prohibits
relationships or transactions involving sanctioned persons and entities or comprehensively sanctioned
countries, territories and their governments. This sometimes also means that ING’s risk appetite may be
stricter than legal obligations, and we may choose not to support certain customer relationships, business
activities and transactions even if permitted by law.
ING continuously monitors external developments to remain proactive to new sanctions packages or
updates to existing sanctions packages. Through 2024, geopolitical risk has grown (e.g. through the conflict
in the Middle East and the continuation of Russia's invasion in Ukraine), and global sanctions regimes
remained increasingly active, creating a complex regulatory and legislative environment. There has been an
increasing focus on the potential circumvention of sanctions against Russia, and the roles of third countries
and companies in facilitating any circumvention or undermining the sanctions’ measures. This has prompted
a concerted effort by governments to impose pressure on companies operating in these jurisdictions, and to
prevent sanctions measures being sidestepped by targeted Russian parties. ING’s sanctions programme is
designed to comply with sanctions across the multiple jurisdictions in which ING has business operations.
As a result of Russia’s continued occupation of Ukraine and the associated conflict, there has been a
continued focus from the EU, US, and other governments to impose additional sanctions and combat the
potential circumvention of sanctions against Russia. In addition to several new sanctions packages, there has
been an increased focus on the roles of third countries and companies in facilitating the circumvention or
undermining of such sanctions' measures. The EU has increased efforts to ensure that EU operators are
adhering to the sanctions by implementing new reporting requirements and by implementing new rules to
harmonise criminal offences and penalties for the violation and circumvention of EU sanctions. The EU also
introduced the 'best efforts' requirements, which seek to hamper sanctions circumvention through a new
requirement for EU parent companies to do their 'best efforts' to make their non-EU subsidiaries align with
EU sanctions. The extent to which this aimed alignment can in fact be realised as an end-result depends on
the applicable factual and legal context. Practical impossibilities or limitations, conflicting applicable laws
(potentially including personal liability risks), and/or conflicting regulatory expectations could be
complicating factors triggering challenges. An example of such challenges concerns the topic of information
sharing by Russian subsidiaries with their EU parent companies, particularly where it relates to their local
Russian client data. Under new Russian regulatory restrictions, Russian subsidiaries are locally prohibited
from sharing such data, whereas EU parent companies are typically still expected to obtain such data as part
of their group-level oversight.
Since February 2022, ING has taken measures to not engage in new Russian business and ING follows an
active de-risking approach, aimed to reduce ING’s overall exposure towards Russia, including measures to
reduce operational risks and to further ringfence activities of ING (Bank) Eurasia JSC. ING expects the agreed
sale of ING (Bank) Eurasia JSC to close in the third quarter of 2025.
As a result of frequent evaluation of the business from economic, strategic and risk-based perspectives, ING,
with limited exception, does not engage in business involving certain countries, including Cuba, Iran, North
Korea, Sudan, Syria and the Crimea region. ING has a policy not to enter into new relationships with clients
from these countries and processes are in place to discontinue existing relationships involving these
countries.
Evolving financial crime landscape
Financial crime continues to evolve, whether through technology, new and sophisticated techniques used by
criminals, or the results of geopolitical events. This widespread digitalisation of the economy and use of AI
has led to a reshaping of the methods used to launder and finance terrorism. Criminal groups have adopted
and are misusing new technologies, AI, and anonymity-enhancing technologies, such as virtual currencies
and mixers, to commit criminal activities.
ING is continuing to invest in new and innovative technological capabilities, enhance our cooperation with
law-enforcement agencies, industry bodies and regulators, and develop intelligence and data-led
collaborative solutions to detect and disrupt financial crime. In this context, this may at times include sharing
information within ING to manage our financial crime risk exposure, in line with General Data Protection
Regulation requirements and local privacy laws and regulations.
EU AML/CFT legislative package
European legislation continues to evolve with the aim of strengthening and standardising anti-money
laundering (AML) and counter-terrorism financing (CTF) regulation. ING welcomes this harmonisation, which
removes a degree of regulatory complexity. ING has actively participated through banking associations in
assessing the potential impact of the AML legislative package on banks. The regulation (AMLR) and the EU
agency (AMLA) that will coordinate national authorities to ensure the correct and consistent application of
EU rules, will be fully in force by Q3 2027.
The earlier published report from the Dutch Central Bank (DNB) ‘From Recovery to Balance’ on the use of risk-
based approaches and the related ‘Industry Baselines’ on KYC topics that were created with ING being
involved, create a necessary step towards fighting financial crime through the enhanced application of a
risk-based approach (RBA): focusing efforts on higher risks, while remaining within the boundaries of the
applicable laws and regulations.
Public-private partnerships
We continue to work with our peers, regulators and law enforcement in public-private partnerships (PPPs) in
our major markets, and on international level – through our Group-level participation in networks such as
Europol’s Financial Intelligence Public Private Partnership. We recognise that our risk management
frameworks and controls benefit from having a direct dialogue with public partners as well as
complementing our understanding of relevant and evolving financial crime threats and risks. Sharing and
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> Compliance risk
applying these insights across the organisation helps us move beyond technical compliance and enhances
our ability to meet regulatory obligations and protect our customers.
Conduct compliance and ethics
ING’s product governance and conduct compliance risk management amplify that we aim to act in the
interest of our customers. Focus areas include customer protection and transparency (referred to as
customer centricity), market conduct (including market manipulation and abuse), anti-competitive conduct,
and conflicts of interest. ESG- and ethics-related compliance risks, being risk drivers, are different by nature
as they potentially have an overarching impact on other compliance risks.
Customer centricity
Customers are our reason for being and customer centricity is therefore key for ING. ING wants to ensure
that its customers, particularly those that are vulnerable, are able to make well-informed decisions on the
products and services used. In our effort to ensure ING’s approach to customer centricity is carried out
consistently throughout the organisation, local standards were complemented by an overarching global
Customer Centricity Policy implemented in 2024. In this policy, we set central norms for retail and wholesale
banking products (e.g. investments, mortgages and insurance) to meet customer needs on a continuous
basis, from the creation of a product and throughout the full product lifecycle. By implementing a policy that
manages the way in which we consider and address our customers, we have further enshrined the Orange
Code and the Global Code of Conduct.
We aim to build on the Customer Centricity Policy in 2025 by enhancing our approach to social inclusion. We
will support the business in the implementation of the EU Accessibility Act by setting minimum norms for
the accessibility of products and services. Through an expanded customer centricity module in the product
approval and review process, we reinforce that issues such as financial distress and accessibility will be taken
into account structurally whenever we launch or review a product, ensuring ING aims to address customer
needs.
ESG
We have integrated sustainability into the compliance risk management framework as a continuous
reflection of ING’s strategy to put sustainability at the heart of what we do. In 2024, we created the ESG &
Ethics team in Group Compliance to ensure a structural approach to ESG-related compliance risks. While
material environmental-related compliance risks are now an integral part of the bank's compliance
processes, we continue with the translation of the social and governance-related topics. The role of
Compliance in the fast-changing and evolving area of sustainability is expected to continue to develop
further, alongside the other risk domains within ESG risk management.
Greenwashing has proven to be an important risk with various (legal) actions noted in the market. In 2024,
we reviewed our portfolio of sustainable products to identify any potential greenwashing risks, and
Compliance Quality Assurance reviews on this topic were performed in multiple ING entities. With the
implementation of a Greenwashing Prevention Mandatory Instruction, we further enhance the management
of greenwashing risks. Although we observe that the regulatory framework on ESG is maturing, we do expect
substantial regulatory developments, setting further requirements for the prevention of greenwashing. Any
such developments will be included in the compliance risk management framework.
Speak up and ethics
ING wants to create, facilitate and maintain an environment in which employees feel encouraged and
supported to speak up at all times. Conduct ethics is about supporting and protecting our employees by
means of (i) dealing with dilemmas; (ii) setting the right environment for ethical decisions and behaviours;
and (iii) providing for an escalation/reporting process in case of concerns, and ensuring fair consequence
management. For this we rely on our Orange Code, with the values and behaviours that guide us, the Global
Code of Conduct – revised in 2024 – that prevents and protects employees from behaving unethically, and
the whistleblowing framework in case of concerns.
In 2024, ING further enhanced the whistleblower process with explicit focus on anti-retaliation, fair
consequence management, and deliberate after-care. A global cross-channel Speak up programme is in
place to harmonise the different Speak up channels for undesirable behaviour.
Market conduct
Market conduct risk stems from behaviour that can negatively impact market integrity. ING has a global
market abuse policy and control framework, as well as supplementary procedures that include personal
account dealing, management of inside information and information barriers. In 2024, further steps were
taken towards automating, standardising, and centralising our approach to personal account dealing, deal
conflict clearance, and insider list management across the group.
Conflicts of interest
ING, being a large financial institution, is prone to multiple conflicts of interest, due to overlapping interests of
different stakeholders as businesses, employees, customers, shareholders and society. In 2024, we updated
the global conflicts of interest policy, including the related framework document, coming into effect in May
2025.
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> Compliance risk
Anti-competitive conduct
Competition law impacts all areas of ING’s business. It is ING’s policy to adhere to competition laws and
regulations that promote effective and fair competition, and which benefits and protects society, our clients
and business partners, and our own business.
Data protection
At ING, data protection is at the core of our strategy and business operations. Our approach can be
summarised as 'the right people use the right data for the right purpose'. We are bound by European and
local data protection laws, which can differ from country to country. A group-wide, global, personal data
protection policy is in place to enable a consistent approach to our way of processing personal data. In
addition, we have implemented binding corporate rules within ING Bank with the aim of ensuring appropriate
safeguards for our internal data transfers.
Regulatory developments which potentially lead to emerging data protection risks are monitored and
managed on an ongoing basis. In 2024, following early developments in the application of GenAI and based
on the EU AI Act, ING launched a programme to assess potential impact on our way of working – especially
with regard to future obligations and requirements to be embedded in our policies and frameworks.
Personal data
In line with the EU’s General Data Protection Regulation (GDPR) and other applicable data protection
requirements, we aim to process personal data for a specified business purpose in a fair and lawful manner,
observing the rights and liberties of data subjects in scope of our activities. We aim to perform data
protection impact assessments (DPIAs) and regular internal audits on the personal data processing that we
do for clients and employees, including ING’s technologies.
We strive to be transparent about our use of personal data from customers, employees, suppliers and
business partners, who we share personal data with and why. It is our policy that our business entities,
support functions, as well as third parties that we engage with, ensure that the data subject is granted a level
of protection equivalent to that guaranteed by the GDPR, especially if personal data is transferred outside of
the European economic area (EEA). Part of the data protection scope is that personal data is managed in a
safe and secure manner, in line with applicable information security standards. More information can be
found in the privacy statement on our corporate website.
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Model risk
Introduction
Model risk is the risk of financial loss, regulatory fines, reputational damage, legal or regulatory sanctions
resulting from decisions that are principally based in the output 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.
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.
• 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 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 function.
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 monthly.
Model risk management (MoRM)
The ING MoRM policy framework comprises the total set of measures and tools put in place to manage
model risk. ING classifies models based on their criticality, financial materiality and complexity. The model
classification determines the depth and extent of the applied model risk management activities, including
model validation. Model validation is the independent confirmation that a model is valid for its intended use.
Models are validated according to procedures applicable to key model types. These procedures are
continuously being enhanced to keep up to date with regulatory, technical developments and industry
trends.
ING models are developed using a variety of technologies, including AI. As such, ING MoRM has been
assessing the requirements of the EU AI Act, designing an AI risk framework and consequently adapting the
MoRM approach for AI models. Given the relevance of deploying such new technologies in a safe and secure
way, ING has set up a Centre of Excellence for AI Risk Management that will reside within MoRM. Its purpose
is to drive the AI risk strategy, centrally coordinate AI risk management activities across ING risk domains,
advise on responsible AI use, and facilitate its scalable and responsible adoption.
On an aggregated level, model risk is monitored via analysis of data from the global model inventory,
collected across the bank to manage ING model's landscape. Insights are reported to the MoRM Committee,
MBB, and other stakeholders so senior management can make well-informed decisions on acceptance or
further mitigation of model risk.
Business & strategy risk
Introduction
Business & strategy risk for ING has been defined as the risk inherent to strategy decisions, internal
efficiency and the business environment. This risk can be expressed as the value or earnings loss in terms of
volumes, margins, expenses and fee and commission income. Business risk is accounted for within the
economic capital framework and calculated applying the variance-covariance methodology. This covers the
risk that volume, margins, fee and commission income, operating expenses, and regulatory expenses/costs
will deviate from the expected expenses and income over the horizon of the relevant activities.
Risk management
ING applies an explicit risk appetite statement regarding business risk, focusing on earnings stability and
diversification of the business mix. The underlying economic capital risk types (expense risk, volume-margin
risk and regulatory costs) are mitigated and managed via the financial performance of the bank and the
business units. Through this process, the reported numbers are compared quarterly against financial
projections and discussed continuously within different parts of the organisation.
Consolidated
Financial statements
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Contents |  | Strategy |  | Our financial performance |  | Our leadership and corporate governance |  | Capital management |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information and appendices

Contents
Consolidated financial statements 107

Consolidated statement of financial position | 108
Consolidated statement of profit or loss | 109
Consolidated statement of comprehensive income | 110
Consolidated statement of changes in equity | 111
Consolidated statement of cash flows | 114

Notes to the consolidated financial
statements 117

1 Basis of preparation and material accounting policy information | 117

Notes to the consolidated statement of
financial position 107

2 Cash and balances with central banks | 134
3 Loans and advances to banks | 134
4 Financial assets at fair value through profit or loss | 134
5 Financial assets at fair value through other comprehensive income | 136
6 Debt securities | 137
7 Loans and advances to customers | 137
8 Investments in associates and joint ventures | 138
9 Property and equipment | 140
10 Intangible assets | 140
11 Other assets | 141
12 Deposits from banks | 142

13 Customer deposits | 142
14 Financial liabilities at fair value through profit or loss | 142
15 Provisions | 143
16 Other liabilities | 144
17 Debt securities in issue | 144
18 Senior non-preferred debt | 145
19 Subordinated loans | 145
20 Equity | 145

Notes to the consolidated statement
of profit or loss 149

21 Net interest income | 149
22 Net fee and commission income | 150
23 Valuation results and net trading income | 150
24 Investment income | 151
25 Other net income | 151
26 Staff expenses | 151
27 Other operating expenses | 152

Segment reporting 153

28 Segments | 153
29 Information on geographical areas | 157

Additional notes to the consolidated
financial statements 227

30 Pension and other post-employment benefits | 161
31 Taxation | 164
32 Fair value of assets and liabilities | 167
33 Derivatives and hedge accounting | 178
34 Assets by contractual maturity | 186

35 Liabilities and off-balance sheet commitments by maturity | 187
36 Transfer of financial assets, assets pledged and received as collateral | 190
37 Offsetting financial assets and liabilities | 191
38 Contingent liabilities and commitments | 196
39 Legal proceedings | 196
40 Consolidated companies and businesses acquired and divested | 199
41 Principal subsidiaries, investments in associates and joint ventures | 199
42 Structured entities | 200
43 Related parties | 202
44 Capital management | 205
45 Subsequent events | 206

Parent company financial statements 209

Parent company statement of financial position | 209
Parent company statement of profit or loss | 210
Parent company statement of changes in equity | 211
Notes to the parent company financial statements | 212

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

Consolidated statement of financial position
As at 31 December

in EUR million | 2024 | 2023 |  |  | 2024 | 2023
Assets |  |  |  | Liabilities |  |
Cash and balances with central banks 2 | 70,353 | 90,214 |  | Deposits from banks 12 | 16,722 | 23,257
Loans and advances to banks 3 | 21,769 | 16,708 |  | Customer deposits 13 | 699,725 | 662,004
Financial assets at fair value through profit or loss 4,6 |  |  |  | Financial liabilities at fair value through profit or loss 14 |  |
– Trading assets | 72,906 | 60,240 |  | – Trading liabilities | 35,255 | 37,220
– Non-trading derivatives | 2,463 | 2,028 |  | – Non-trading derivatives | 2,101 | 2,019
– Designated as at fair value through profit or loss | 5,740 | 5,775 |  | – Designated as at fair value through profit or loss | 49,539 | 55,399
– Mandatorily at fair value through profit or loss | 56,481 | 54,983 |  | Current tax liabilities | 276 | 351
Financial assets at fair value through other comprehensive income 5,6 | 46,389 | 41,116 |  | Deferred tax liabilities 31 | 287 | 184
Securities at amortised cost 6 | 50,273 | 48,313 |  | Provisions 15 | 752 | 899
Loans and advances to customers 7 | 680,299 | 642,453 |  | Other liabilities 16 | 10,596 | 13,130
Investments in associates and joint ventures 8 | 1,679 | 1,509 |  | Debt securities in issue 17 | 94,459 | 84,423
Property and equipment 9 | 2,434 | 2,399 |  | Senior non-preferred debt 18 | 49,393 | 40,213
Intangible assets 10 | 1,334 | 1,198 |  | Subordinated loans 19 | 17,879 | 15,404
Current tax assets | 599 | 311 |  | Total liabilities | 976,986 | 934,501
Deferred tax assets 31 | 1,069 | 1,280 |  |  |  |
Other assets 11 | 6,935 | 7,109 |  | Equity 20 |  |
|  |  |  | Share capital and share premium | 17,067 | 17,067
|  |  |  | Other reserves | 78 | -769
|  |  |  | Retained earnings | 25,598 | 23,893
|  |  |  | Shareholders’ equity (parent) | 42,743 | 40,191
|  |  |  | Non-controlling interests | 995 | 944
|  |  |  | Total equity | 43,738 | 41,135
Total assets | 1,020,724 | 975,636 |  | Total liabilities and equity | 1,020,724 | 975,636

References relate to the accompanying notes. These are an integral part of the Consolidated financial statements.
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Consolidated statement of profit or loss
for the years ended 31 December

in EUR million | 2024 | 2023 | 2022 |  |  | 2024 | 2023 | 2022
Interest income using effective interest rate method | 49,221 | 44,486 | 24,541 |  | Addition to loan loss provisions | 1,194 | 520 | 1,861
Other interest income | 9,685 | 7,741 | 3,935 |  | Staff expenses 26 | 7,184 | 6,725 | 6,152
Total interest income | 58,905 | 52,228 | 28,476 |  | Other operating expenses 27 | 4,931 | 4,838 | 5,040
|  |  |  |  | Total expenses | 13,310 | 12,083 | 13,053
Interest expense using effective interest rate method | -35,164 | -28,693 | -10,969 |  |  |  |  |
Other interest expense | -8,993 | -7,726 | -3,761 |  | Result before tax | 9,025 | 10,318 | 5,493
Total interest expense | -44,157 | -36,419 | -14,730 |  |  |  |  |
|  |  |  |  | Taxation 31 | 2,580 | 2,926 | 1,723
Net interest income 21 | 14,749 | 15,809 | 13,745 |  | Net result | 6,445 | 7,392 | 3,769
Fee and commission income | 5,598 | 5,100 | 5,085 |  | Net result attributable to: |  |  |
Fee and commission expense | -1,596 | -1,514 | -1,499 |  | Non-controlling interests | 258 | 235 | 102
Net fee and commission income 22 | 4,002 | 3,586 | 3,586 |  | Shareholders of the parent | 6,187 | 7,157 | 3,667
|  |  |  |  |  | 6,445 | 7,392 | 3,769
Valuation results and net trading income 23 | 3,407 | 2,910 | 1,503 |  |  |  |  |
Investment income 24 | 13 | 95 | 181 |  |  |  |  |
Share of result from associates and joint ventures 8 | 205 | 149 | 92 |  |  |  |  |
Impairment of associates and joint ventures 8 | -35 | -5 | -192 |  |  |  |  |
Result on disposal of group companies | 0 | 0 | 6 |  |  |  |  |
Net result on derecognition of financial assets measured at amortised cost | -2 | 3 | -5 |  |  |  |  |
Other net income 25 | -3 | -146 | -369 |  | Dividend per ordinary share | 10.72 | 22.08 | 13.50
Total income | 22,334 | 22,401 | 18,546 |  | Total amount of dividend paid (in million euros) | 4,986 | 10,269 | 6,277

References relate to the accompanying notes. These are an integral part of the Consolidated financial statements.
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Consolidated statement of comprehensive income
for the years ended 31 December

in EUR million | 2024 | 2023 | 2022
Net result (before non-controlling interests) | 6,445 | 7,392 | 3,769
Other comprehensive income |  |  |
Items that will not be reclassified to the statement of profit or loss: |  |  |
Realised and unrealised revaluations property in own use | 3 | 10 | 15
Remeasurement of the net defined benefit asset/liability | -16 | -85 | -19
Net change in fair value of equity instruments at fair value through other comprehensive income | 664 | -30 | -126
Change in fair value of own credit risk of financial liabilities at fair value through profit or loss | -46 | -39 | 165
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 | -261 | 68 | -428
Realised gains/losses on debt instruments at fair value through other comprehensive income reclassified to the statement of profit or loss | 63 | 9 | -26
Changes in cash flow hedge reserve | 383 | 1,138 | -3,158
Exchange rate differences | 563 | -85 | 436
Total other comprehensive income | 1,353 | 986 | -3,140
Total comprehensive income | 7,798 | 8,378 | 629
Comprehensive income attributable to: |  |  |
Non-controlling interests | 303 | 444 | -190
Shareholders of the parent | 7,495 | 7,934 | 819
| 7,798 | 8,378 | 629

Each component of the other comprehensive income is presented after taxation. For the disclosure on the
income tax effects on each component, reference is made to Note 31 'Taxation'.
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Contents |  | Strategy |  | Our financial performance |  | Our leadership and corporate governance |  | Capital management |  | Risk management |  | Consolidated financial statements |  | Parent company financial statements |  | Other information and appendices

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 2023 | 17,067 | -769 | 23,893 |  | 40,191 |  | 944 |  | 41,135
Net result |  | 125 | 6,062 |  | 6,187 |  | 258 |  | 6,445
Other comprehensive income |  | 1,307 |  |  | 1,307 |  | 46 |  | 1,353
Total comprehensive income net of tax |  | 1,432 | 6,062 |  | 7,495 |  | 303 |  | 7,798
Dividends |  |  | -4,986 |  | -4,986 |  | -253 |  | -5,239
Employee share-based compensation plans |  |  | 45 |  | 45 |  | 0 |  | 45
Transfers |  | -585 | 585 |  | 0 |  |  |  | 0
Other changes |  |  | -1 |  | -1 |  | 0 |  | -1
Balance as at 31 December 2024 | 17,067 | 78 | 25,598 |  | 42,743 |  | 995 |  | 43,738

I n 2024, ING Bank updated the presentation of the Consolidated statement of changes in equity to simplify
its structure and reduce duplication. Comparative figures have been updated accordingly.
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 20 'Equity'.
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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 2022 | 17,067 | -984 | 26,462 |  | 42,546 |  | 504 |  | 43,050
Impact of changes in accounting policies 1 |  |  | -45 |  | -45 |  | -1 |  | -46
Balance as at 1 January 2023 | 17,067 | -984 | 26,417 |  | 42,500 |  | 503 |  | 43,004
Net result |  | 336 | 6,821 |  | 7,157 |  | 235 |  | 7,392
Other comprehensive income |  | 777 | 0 |  | 777 |  | 209 |  | 986
Total comprehensive income net of tax |  | 1,113 | 6,821 |  | 7,934 |  | 444 |  | 8,378
Dividends |  |  | -10,269 |  | -10,269 |  | -3 |  | -10,272
Employee share-based compensation plans |  |  | 30 |  | 30 |  | 0 |  | 30
Transfers |  | -899 | 899 |  |  |  |  |  | 0
Other changes |  |  | -5 |  | -5 |  | 0 |  | -5
Balance as at 31 December 2023 | 17,067 | -769 | 23,893 |  | 40,191 |  | 944 |  | 41,135

1 Changes in policy following the adoption of IFRS 17 and change in policy for non-financial guarantees.
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 20 'Equity'.
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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 2021 | 17,067 | 1,069 | 29,778 |  | 47,914 |  | 736 |  | 48,650
Impact of 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 result |  | 161 | 3,506 |  | 3,667 |  | 102 |  | 3,769
Other comprehensive income |  | -2,848 | 0 |  | -2,848 |  | -292 |  | -3,140
Total comprehensive income net of tax |  | -2,687 | 3,506 |  | 819 |  | -190 |  | 629
Dividends |  |  | -6,277 |  | -6,277 |  | -41 |  | -6,319
Employee share-based compensation plans |  |  | 27 |  | 27 |  | 0 |  | 27
Transfers |  | 8 | -8 |  | 0 |  |  |  | 0
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
statement. Changes in individual Reserve components are presented in Note 20 'Equity'.
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Consolidated statement of cash flows

in EUR million, for the years ended 31 December | 2024 | 2023 | 2022
Cash flows from operating activities |  |  |
Result before tax |  | 9,025 | 10,318 | 5,493
Adjusted for: | – Depreciation and amortisation | 673 | 674 | 711
| – Addition to loan loss provisions | 1,194 | 520 | 1,861
| – Revaluations | -780 | -2,836 | 4,706
| – Exchange rate differences and other | 1,134 | 447 | 813
Taxation paid |  | -2,753 | -2,700 | -1,489
Changes in: | – Loans and advances to banks, not available on demand | -7,736 | 12,693 | -5,836
| – Deposits from banks, not payable on demand | -7,819 | -31,804 | -26,976
| – Trading assets | -12,663 | -3,366 | -5,485
| – Trading liabilities | -1,964 | -1,869 | 11,975
| – Loans and advances to customers | -34,416 | -5,815 | -19,306
| – Customer deposits | 38,916 | 12,541 | 27,555
| – Non–trading derivatives | -54 | 2,409 | -5,469
| – Assets designated at fair value through profit or loss | 35 | 256 | 56
| – Assets mandatorily at fair value through profit or loss | 274 | -7,402 | -4,143
| – Other assets | 265 | 1,724 | -2,861
| – Other financial liabilities at fair value through profit or loss | -7,801 | 4,384 | 9,843
| – Provisions and other liabilities | -635 | 2,143 | -667
Net cash flow from/(used in) operating activities | -25,105 | -7,682 | -9,218
Cash flows from investing activities |  |  |
Investments and advances: | - Associates and joint ventures | -26 | -55 | -48
| - Financial assets at fair value through other comprehensive income | -21,091 | -19,995 | -18,806
| – Securities at amortised cost 1 | -110,052 | -49,614 | -24,651
| – Property and equipment | -332 | -246 | -231

|  | 2024 | 2023 | 2022
| – Other investments | -383 | -310 | -198
Disposals and redemptions: | – Associates and joint ventures | 107 | 164 | 58
| – Disposal of subsidiaries, net of cash disposed | 0 | 0 | 7
| - Financial assets at fair value through other comprehensive income | 16,949 | 11,913 | 14,526
| – Securities at amortised cost 1 | 108,732 | 49,525 | 23,943
| – Property and equipment | 50 | 57 | 83
| – Other investments | 13 | 15 | 10
Net cash flow from/(used in) investing activities | -6,033 | -8,545 | -5,307
Cash flows from financing activities |  |  |
Proceeds from senior non-preferred debt | 9,533 | 7,013 | 10,347
Repayments of senior non-preferred debt | -3,692 | -5,451 | -3,897
Proceeds from debt securities 1 | 115,308 | 110,477 | 81,636
Repayments of debt securities 1 | -109,358 | -86,061 | -78,609
Proceeds from issuance of subordinated loans | 4,603 | 2,225 | 983
Repayments of subordinated loans | -2,931 | -2,894 | -1,090
Repayments of principal portion of lease liabilities | -290 | -291 | -296
Dividends paid | -5,239 | -10,272 | -6,319
Net cash flow from/(used in) financing activities | 7,935 | 14,746 | 2,755
Net cash flow |  | -23,203 | -1,481 | -11,770
Cash and cash equivalents at beginning of year | 93,011 | 95,390 | 107,664
Effect of exchange rate changes on cash and cash equivalents | -740 | -898 | -505
Cash and cash equivalents at end of year | 69,068 | 93,011 | 95,390

1 Cash flows are reported on a gross basis and include investments and borrowings of short term securities.
ING Bank Annual Report 2024 115

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Consolidated statement of cash flows - continued

Cash and cash equivalents
in EUR million | 2024 | 2023 | 2022
Treasury bills and other eligible bills included in securities at AC | 37 | 0 | 1
Deposits from banks | -6,303 | -5,132 | -6,172
Loans and advances to banks | 4,981 | 7,930 | 13,947
Cash and balances with central banks | 70,353 | 90,214 | 87,614
Cash and cash equivalents at end of year | 69,068 | 93,011 | 95,390

Cash and cash equivalents include deposits from banks and loans and advances to banks that are payable
on demand.
Included in Cash and cash equivalents are minimum mandatory reserve deposits held at various central
banks. Reference is made to Note 36 'Transfer of financial assets, assets pledged and received as collateral'
for restrictions on Cash and balances with central banks.
References relate to the accompanying notes. These are an integral part of the Consolidated financial
statements.

Changes in liabilities arising from financing activities
| Debt securities in issue | Subordinated Loans | Lease liabilities | Senior non-preferred debt
in EUR million | 2024 | 2023 | 2022 | 2024 | 2023 | 2022 | 2024 | 2023 | 2022 | 2024 | 2023 | 2022
Opening balance | 84,423 | 58,075 | 57,443 | 15,404 | 15,789 | 16,719 | 1,162 | 1,174 | 1,220 | 40,213 | 37,806 | 34,303
Cash flows: |  |  |  |  |  |  |  |  |  |  |  |
Additions | 115,308 | 110,477 | 81,636 | 4,603 | 2,225 | 983 |  |  |  | 9,533 | 7,013 | 10,347
Redemptions / Disposals | -109,358 | -86,061 | -78,609 | -2,931 | -2,894 | -1,090 | -290 | -291 | -296 | -3,692 | -5,451 | -3,897
Non cash changes: |  |  |  |  |  |  |  |  |  |  |  |
Amortisation | 1,062 | 730 | 281 | 28 | 34 | 31 | 27 | 28 | 15 | -3 | 1 | -7
Other | 111 | 403 | -66 | 24 | 12 | 8 | 212 | 256 | 239 | 1,669 | 102 | 106
Changes in unrealised revaluations | 594 | 1,279 | -3,746 | 188 | 473 | -1,470 |  |  |  | 544 | 1,436 | -3,866
Foreign exchange movement | 2,318 | -479 | 1,135 | 564 | -236 | 608 | 5 | -4 | -4 | 1,129 | -694 | 820
Closing balance | 94,459 | 84,423 | 58,075 | 17,879 | 15,404 | 15,789 | 1,116 | 1,162 | 1,174 | 49,393 | 40,213 | 37,806

Part of Debt securities in issue and subordinated loans are subject to fair value hedge accounting. Hence,
changes in unrealised revaluations represent fair value adjustments to the hedged item attributable to the
hedged interest rate risk. Reference is made to the paragraph 'fair value hedge accounting' in Note 33
'Derivatives and hedge accounting'.
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The table below presents the Interest and dividend received and paid.

in EUR million | 2024 | 2023 | 2022
Interest received | 57,201 | 51,030 | 28,110
Interest paid | -41,459 | -33,859 | -14,201
| 15,742 | 17,171 | 13,909
Dividend received | 235 | 205 | 229
Dividend paid | -5,239 | -10,272 | -6,319

Dividends received from associates and joint ventures are included in investing activities; interest received,
interest paid and other dividends received are included in operating activities; and dividend paid is included
in financing activities in the Consolidated statement of cash flows.
ING Bank Annual Report 2024 117

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Notes to the Consolidated financial statements
1 Basis of preparation and material accounting policy information
1.1 Reporting entity and authorisation of the Consolidated financial statements
ING 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 2024, 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.
The ING Bank Consolidated financial statements, as at and for the year ended 31 December 2024, were
authorised for issue in accordance with a resolution of the Management Board Banking on 3 March 2025. 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 1.5.4 ‘Derivatives and hedge
accounting’ of this note and to Note 33 '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 Changes to accounting policies and presentation
ING Bank has consistently applied its accounting policies to all periods presented in these Consolidated
financial statements.
In 2024, ING Bank updated the presentation of the Consolidated statement of changes in equity to simplify
its structure and reduce duplication. Comparative figures have been updated accordingly. Furthermore, ING
has changed the presentation and classification of Senior non-preferred instruments respectively in the
consolidated statement of financial position and consolidated statement of cash flows. ING believes this
change further improves presentation about these instruments and related cash flows. Comparative figures
have been updated accordingly. In addition, presentation in Note 28 'Segments' was updated to reflect the
clarified requirements for segment disclosures as issued by the IFRIC in an agenda decision issued in July
2024.
1.3.1 Changes in IFRS effective in 2024
The following amendments to IFRS became effective in the current reporting period (and have been EU
endorsed) with no significant impact for ING Bank:
• 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) and Non-current liabilities with Covenants (issued in October 2022).
• Amendments to IAS 7 'Statement of Cash flows' and IFRS 7 'Financial Instruments: Disclosures': Supplier
Finance Arrangements (issued in May 2023).
1.3.2 Upcoming changes in IFRS after 2024
ING Bank has not early adopted any of the following Standards, interpretations or amendments that have
been issued, but are not yet effective and is assessing their potential impact on for ING Bank.
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> Notes to the consolidated financial statements
Effective in 2025 (endorsed by the EU):
• Amendments to IAS 21 'The Effects of Changes in Foreign Exchange Rates': Lack of Exchangeability
(issued in August 2023).
The implementation of the above amendments is expected to have no significant impact on ING Bank's
Consolidated financial statements when they become effective.
Effective in 2026 (not yet endorsed by the EU):
• Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosure': Classification
and Measurement of Financial Instruments (issued in May 2024).
• Amendments to IFRS 9 'Financial Instruments' and IFRS 7 'Financial Instruments: Disclosure': Contracts
Referencing Nature-dependent Electricity (issued in December 2024).
• Annual Improvements to IFRS Accounting Standards: Volume 11 (issued in July 2024).
Effective in 2027 (not yet endorsed by the EU):
• New Standard IFRS 18 'Presentation and Disclosure in Financial Statements' (issued in April 2024).
In addition, in May 2024, the IASB also issued a new accounting Standard IFRS 19 'Subsidiaries without Public
Accountability: Disclosures'. However, it is not applicable for the consolidated financial statements of ING
Bank.
1.4 Significant judgements and critical accounting estimates and assumptions
The preparation of the Consolidated financial statements requires management to make judgements in the
process of applying its accounting policies and to use estimates and assumptions. The estimates and
assumptions affect the reported amounts of the assets and liabilities and the amounts of the contingent
assets and contingent liabilities at the balance sheet date, as well as reported income and expenses for the
year. The actual outcome may differ from these estimates. The process of setting assumptions is subject to
internal control procedures and approvals.
ING 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) (refer to Note 1.5.6 ‘Impairment of financial assets');
• The determination of the fair values of financial assets and liabilities (refer to Note 1.5.3 for ‘Fair values of
financial assets and liabilities’);
• Investment in associate - assessment of additional impairment losses or reversal of previous impairment
losses (refer to Note 1.10 ‘Investments in associates and joint ventures); and
• Provisions (refer to Note 1.15 ‘Provisions, contingent liabilities and contingent assets’).
In March 2024 ING repaid the final EUR 6 billion of its Targeted Longer-Term Refinancing Operations (TLTRO) III
participation. As a result, accounting for TLTRO is no longer an area of significant judgement in 2024, while it was
as such in 2023 and 2022.
1.5 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.
1.5.1 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
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.
1.5.2 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).
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> Notes to the consolidated financial statements
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).
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 Other interest income or Other
interest expense in the period in which it arises. The interest arising on a debt instrument that is part of a
hedge relationship, but not subject to hedge accounting, is recognised in profit or loss and presented
within Other interest income or Other interest expense in the period in which it arises.
ING 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.
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> Notes to the consolidated financial statements
Other remaining equity investments are measured at FVPL. All changes in the fair value are recognised in
Valuation result and Net trading income in the Consolidated statement of profit or loss.
Financial liabilities
Financial liabilities are classified and subsequently measured at AC, except for financial guarantee contracts,
derivatives and liabilities designated at FVPL. Financial liabilities classified and measured at FVPL are
presented as follows:
• the amount of change in the fair value that is attributable to changes in own credit risk of the liability
designated at FVPL is presented in OCI. Upon derecognition this Debit Valuation Adjustment (DVA) impact
does not recycle from OCI to profit or loss; and
• the remaining amount of change in the fair value is presented in profit or loss in ‘Valuation results and
net trading income’. Interest on financial liabilities at FVPL is also recognised in the valuation result,
except for items voluntarily designated as FVPL for which interest is presented within ‘Other interest
income (expense).
A financial guarantee contract is a contract that requires ING 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’.
Repurchase transactions and reverse repurchase transactions
Securities sold subject to repurchase agreements (repo's), 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, 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.
1.5.3 Fair values of financial assets and liabilities
All financial assets and liabilities are recognised initially at fair value. The fair value of a financial instrument
on initial recognition is generally its transaction price (that is, the fair value of the consideration given or
received). However, if there is a material difference between the transaction price and the fair value of
financial instruments whose fair value is based on a valuation technique using significant unobservable
inputs, the entire 'day one' difference (a ‘Day One Profit or Loss’) is deferred. ING 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.
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.
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> Notes to the consolidated financial statements
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.
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 such as Bid-Offer adjustments, Model Risk
Adjustments and Collateral Valuation Adjustments (CollVA).

Significant judgements and critical accounting estimates and assumptions: • Even if market prices are available, when markets are less liquid there may be a range of prices for the same security from different price sources. Selecting the most appropriate price requires judgement and could result in different estimates of fair value. • Valuation techniques are subjective in nature and significant judgement is involved in establishing fair values for certain financial assets and liabilities. Valuation techniques involve various assumptions regarding pricing factors. The use of different valuation techniques and assumptions could produce significantly different estimates of fair value. • Price testing is performed to assess whether the process of valuation has led to an appropriate fair value of the position and to minimise the potential risks of economic losses due to incorrect or misused models. • Assessing whether a market is active, and whether an input is observable and significant, requires judgement. ING 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 32 'Fair value of assets and liabilities ' and to the ‘Market risk’ paragraph in the ‘Risk management’ section of the Annual Report for the basis of the determination of the fair value of financial instruments and related sensitivities.

1.5.4 Derivatives and hedge accounting
IFRS 9 includes an accounting policy choice to defer the adoption of IFRS 9 hedge accounting and to continue
with hedge accounting under IAS 39. ING 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 or so-called economic hedges that are not in a formal hedge accounting relationship where a
component is presented separately in interest result in line with ING Bank’s risk management strategy.
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
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> Notes to the consolidated financial statements
adjustment of the hedged item is, in the case of interest-bearing instruments, amortised through the
statement of profit or loss over the remaining term of the original hedge or recognised directly when the
hedged item is derecognised. For non-interest bearing instruments, the cumulative adjustment of the
hedged item is recognised in the statement of profit or loss only when the hedged item is derecognised.
Cash flow hedges
The effective portion of changes in the fair value of derivatives that are designated and qualify as cash flow
hedges are recognised in the Other Comprehensive Income. The gain or loss relating to the ineffective
portion is recognised immediately in the statement of profit or loss. Amounts accumulated in the Other
Comprehensive Income are recycled to the statement of profit or loss in the periods in which the hedged
item affects net result. When a hedging instrument expires or is sold, or when a hedge no longer meets the
criteria for hedge accounting, any cumulative gain or loss existing in the Other Comprehensive Income at
that time remains in the Other Comprehensive Income and is recognised when the forecast transaction is
ultimately recognised in the statement of profit or loss. When a forecast transaction is no longer expected to
occur, the cumulative gain or loss that was reported in the Other Comprehensive Income is transferred
immediately to the statement of profit or loss.
Net investment hedges
Hedges of net investments in foreign operations are accounted for in a similar way to cash flow hedges. Any
gain or loss on the hedging instrument relating to the effective portion of the hedge is recognised in the
Other Comprehensive Income and the gain or loss relating to the ineffective portion is recognised
immediately in the statement of profit or loss. Gains and losses accumulated in the Other Comprehensive
Income are included in the statement of profit or loss when the foreign operation is disposed.
Benchmark rate reform – specific policies for hedges directly affected by the benchmark rate
reform
As explained in the ‘Impact of the benchmark rate reform’ paragraph of the ‘Risk management’ section, a
fundamental review of important interest rate benchmarks has been carried out, and is still ongoing for
some of them (for instance, WIBOR).
Given that the benchmark rate reform may have various accounting implications, the IASB has undertaken a
two-phase project. Phase 1 (issued in 2019) addresses those issues that affect financial reporting before the
replacement of an existing benchmark. Phase 2 (issued in 2020) focuses on issues that may affect financial
reporting when the existing benchmark rate is reformed or replaced.
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.
• 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 benchmark rate
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 the benchmark
interest rate exposure part of the benchmark rate 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 2024 (mainly for WIBOR hedges).
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 ‘Risk management/ Impact of the benchmark
rate reform’ for the disclosures relating to the application of the amendments as part of Phase 1.
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 benchmark rate
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. By applying these
mandatory amendments, ING Bank avoids hedge accounting discontinuations when modifying both hedged
items and hedging instruments (and related hedge documentation) as a consequence of the benchmark
rate reform that would otherwise be required in the absence of Phase 2 amendments. During 2024, 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.
More specifically, the following temporary reliefs are part of the Phase 2 amendments:
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> Notes to the consolidated financial statements
Relief from discontinuing hedging relationships
• Amendments in the hedge documentation as a consequence of changes required by the benchmark rate
reform do not result in the discontinuation of the hedge relationship nor the designation of a new hedge
relationship. The changes can be in the 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 benchmark rate 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
benchmark rate reform, the hedging strategy remains and is not discontinued. As items within the
hedged group transition at different times from the benchmark rates to RFRs, they are transferred to sub-
groups of instruments that reference RFRs as the hedged risk. The existing benchmark rates 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 decision 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.
As explained above, Phase 1 and Phase 2 benchmark rate amendments to IFRS provide specific hedge
accounting reliefs that allow hedge accounting relationships to continue when the benchmark rate reform is
ongoing. Phase 1 reliefs cease to apply when uncertainty arising from the benchmark rate reform is no
longer present with respect to the timing and amount of the benchmark rate-based cash flows of the
relevant instruments, or when the hedging instrument is discontinued. It is ING Bank’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. Refer to note ‘Risk management/Impact of the benchmark rate reform’ for
the disclosures relating to the application of the amendments as part of Phase 2.
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.
1.5.5 Offsetting of financial assets and financial liabilities
Financial assets and financial liabilities are offset, and the net amount is reported in the statement of
financial position, when ING 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 derivatives, repurchase and reverse repurchase agreements and cash pooling
agreements. A significant portion of offsetting is applied to derivatives and related cash margin balances,
which are either directly cleared through central clearing parties or cleared through clearing members of
central clearing parties. For more information, reference is made to Note 39 ‘Offsetting financial assets and
liabilities’.
1.5.6 Impairment of financial assets
An Expected Credit Loss (ECL) model is applied to financial assets accounted for at AC or FVOCI such as loans,
debt securities and lease receivables, as well as off-balance sheet items such as undrawn loan
commitments, certain financial guarantees issued, and undrawn committed revolving credit facilities. Under
the ECL model, ING Bank calculates the ECL by considering on a discounted basis the cash shortfall it would
incur in case of a default and multiplying the shortfall by the probability of a default occurring. The ECL is the
sum of the probability-weighted outcomes. The ECL estimates are unbiased and include reasonable and
supportable information about past events, current conditions, and forecasts of future economic conditions.
ECL is recognised on the balance sheet as loan loss provisions (LLP).
Three stage approach
Financial assets are classified in one of the below three stages at each reporting date. A financial asset can
move between Stages during its lifetime. The Stages are based on changes in credit quality since initial
recognition and defined as follows:
• Stage 1
Financial assets that have not had a significant increase in credit risk since initial recognition (i.e. no
Stage 2 or 3 triggers apply). Assets are classified as Stage 1 upon initial recognition (with the exception
of purchased or originated credit impaired (POCI) assets) and ECL is determined by the probability that
a default occurs in the next 12 months (12 months ECL);
• Stage 2
Financial assets showing a significant increase in credit risk since initial recognition. For assets in Stage
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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. Reference is made to the ‘Criteria for identifying a significant increase in credit risk (SICR)’ in
the ‘Risk management’ section of the Annual Report.
An asset that is in Stage 2 will move back to Stage 1 when none of the above criteria are in place anymore.
However, if the asset was moved to Stage 2 based on the forbearance status, then the asset stays in Stage 2
for at least 24 months. If the asset was classified as Stage 2 due to the '30 days past due' trigger, then the
asset is moved back to Stage 1 only after three months from when the trigger no longer applies.
Credit-impaired financial assets (Stage 3)
Financial assets are assessed for credit-impairment at each reporting date and more frequently when
circumstances warrant further assessment. Evidence of credit-impairment includes arrears of over 90 days
on any material credit obligation, indications that the borrower is experiencing significant financial difficulty,
a breach of contract, bankruptcy or distressed restructuring. The definition of 'credit-impaired' under IFRS 9
(Stage 3) is aligned with the definition of 'default' used by ING 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 enriched with the internal ING Bank view. A baseline, up-scenario and 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.
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). The management 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 is disclosed in the 'Alternative
Scenarios and Probability Weights' section. Additionally, this approach is detailed in the sensitivity analysis
within the 'Risk Management' section of the Annual Report.
Measurement of ECL
ING 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 the loan type, industry, geographic location,
collateral type, past due status and other relevant factors. These characteristics are relevant to the
estimation of future cash flows for groups of such assets by being indicative of the debtors’ ability to pay all
amounts due according to the contractual terms of the assets being evaluated and the loss in case the
debtor is not able to pay all amounts due.
For Stage 3 assets the PD equals 100% and the LGD and EAD represent a lifetime view of the losses based on
characteristics of defaulted facilities.
For the measurement of ECL, ING 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.
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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.
The best estimate of ECL is calculated as the weighted-average of the shortfall (gross carrying amount
minus discounted expected future cash flow using the original EIR) per scenario, based on best estimates of
expected future cash flows. Recoveries can arise from, among other things, repayment of the loan, collateral
recovery and the sale of the asset. Cash flows from collateral and other credit enhancements are included in
the measurement of ECL of the related financial asset when it is part of or integral to the contractual terms
of the financial asset and the credit enhancement is not recognised separately. For the individual
assessment, with granular (company or asset-specific) scenarios, specific factors can have a larger impact
on the future cash flows than macroeconomic factors.
When a financial asset is credit-impaired, interest income is no longer recognised based on the gross
carrying amount of the asset. Instead, interest income is calculated by applying the original effective
interest rate to the amortised cost of the asset, which is the gross carrying amount less the related loan loss
provision.
Purchased or Originated Credit Impaired (POCI) assets
POCI assets are financial assets that are credit-impaired on initial recognition. Impairment on a POCI asset is
determined based on lifetime ECL from initial recognition. POCI assets are recognised initially at an amount
net of ECL and are measured at AC using a credit-adjusted effective interest rate. In subsequent periods any
changes to the estimated lifetime ECL are recognised in profit or loss. Favourable changes are recognised as
an impairment gain if the lifetime ECL at the reporting date is lower than the estimated lifetime ECL at
origination.
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 also 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.
Presentation of ECL
ECL for financial assets measured at AC is deducted from the gross carrying amount of the assets. For debt
instruments at FVOCI, the ECL is recognised in OCI, instead of deducting it from the carrying amount of the
asset. ECL also reflects any credit losses related to the portion of the loan commitment that is expected to
be drawn down over the remaining life of the instrument. The ECL on issued financial guarantee contracts, in
scope of IFRS 9 and not measured at FVPL, is recognised as liabilities and presented in Other provisions. ECL
are presented in profit or loss in Addition to loan loss provision.
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Significant judgements and critical accounting estimates and assumptions: The calculation of ECL requires a number of judgements and estimates. In particular: • ING Bank makes various assumptions about the risk of default, the credit loss rates in case of a default and expected future cash flows. For collective provisions, ING Bank applies significant judgement when estimating modelled parameters such as PD, LGD and EAD, including the selection and calibration of relevant models. For stage 3 individual provisioning, the determination and probabilities of restructuring and recovery scenarios as well as the amount and timing of expected future cash flows may be particularly subjective. • Forward-looking macroeconomic scenarios used in impairment assessments are uncertain in nature. The use of alternate forward-looking macroeconomic scenarios can produce significantly different estimates of ECL. This is demonstrated in the sensitivity analysis in the ‘Risk Management’ section of the Annual Report, where the un-weighted ECL under each of the three scenarios for some significant portfolios is disclosed. • When determining whether the credit risk on a financial asset has increased significantly (criteria for identifying a significant increase in credit risk), ING 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. • Judgement is exercised in management’s evaluation of whether there is objective evidence that exposures are credit-impaired. • To reflect the risks that are not properly captured by the ECL models (including climate risk), a number of management adjustments to the model-based ECL were necessary as at 31 December 2024, which required significant judgement. Reference is made to the ‘Management adjustments applied this reporting period’ paragraph in the ‘Risk management’ section of the Annual Report.

1.5.7 Modification of financial instruments
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 are executed based on credit concerns they are also referred to as forbearance (refer to the ‘Risk
Management’ section of the Annual Report for more details) and require analysis on whether the contractual
terms have been substantially modified or not. A similar assessment is needed when contractual terms are
modified for reasons other than forbearance.
ING Bank determines whether there has been a substantial modification using both quantitative and
qualitative factors. If the modification results in a substantial modification of the terms of the loan, the
original loan is derecognised and a new loan is recognised at fair value at the modification date. In case of a
non-substantial modification, a modification gain or loss is recognised in profit or loss.
Benchmark rate reform– specific policies for modifications necessary to implement the benchmark rate
reform
As explained in the ‘Benchmark rate reform – specific policies for hedges directly affected by the benchmark
rate reform’ paragraph of section ‘1.5.4 Derivatives and hedge accounting’, given that the benchmark rate
reform may have various accounting implications, the IASB undertook a two-phase project. Apart from
hedge accounting, Phase 2 amendments to IFRS relate to accounting for changes in the basis for
determining the contractual cash flows of financial assets and liabilities due to the benchmark rate reform.
Specifically, Phase 2 amendments require that the effective interest rate on debt financial instruments is
adjusted, but only to the extent that the modifications made to financial instruments are those necessary to
implement the benchmark rate reform and that the new basis for calculating cash flows is ‘economically
equivalent’ to the previous basis. By applying these mandatory amendments, ING Bank 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 the benchmark rate reform are treated as a
reset to the instrument’s variable interest rate). Refer to note ‘Risk management/Impact of the benchmark
rate reform’ for the disclosures relating to the application of the amendments as part of Phase 2.
1.5.8 Accounting for Targeted Longer-Term Refinancing Operations (TLTRO)
ING Bank participated in the Targeted Longer-Term Refinancing Operations (TLTRO III), which mainly affected
comparative periods as, in March 2024, ING repaid the final EUR 6 billion of its TLTRO III participation. ING
Bank considered TLTRO funding provided by the ECB to banks to be on market terms on the basis that the
ECB has established a separate market with TLTRO programmes. They have specific terms which are
different from other sources of funding available to banks, including those provided by the ECB.
Consequently, the rate under TLTRO was considered to be a market conforming rate and TLTRO funding was
recognised fully as a financial liability.
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ING Bank interpreted the whole rate set by the ECB under TLTRO as a floating rate on the financial liability,
being the market rate for each specific period in time. This resulted in discrete rates for discrete interest
periods over the life of TLTRO. The change in the applicable rate between interest periods was seen as a
change in the floating rate and was accounted for prospectively. Similarly, if the ECB announced changes in
the rate for the amounts already drawn under the existing TLTRO, then such changes also represented a
change in a floating rate. Following this, such changes led to the recognition of an increased/decreased
interest in the relevant period of life of the exposure, rather than by the recognition of an immediate
modification gain or loss at the moment of the change of terms by the ECB. If the change related to the
periods already passed, the impact for those past periods was recognised in profit or loss immediately.
Reference is made to Note 12 ‘Deposits from banks’ and to Note 21 ‘Net interest income’ for the presentation
of ING Bank’s participation in TLTRO programmes.
1.6 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.
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 41 ‘Principal subsidiaries’ and a description of ING's activities
involving structured entities is included in Note 42 '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.
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 in certain
countries, in addition to the restrictions on the amount of funds that may be transferred in the form of
dividends, or otherwise, to the parent company.
Furthermore, in addition to the restrictions regarding the minimum capital requirements that are imposed
by industry regulators in the countries in which the subsidiaries operate, other limitations exist in certain
countries.
1.7 Segment reporting
An operating segment is a distinguishable component of ING 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)) who decide which resources to allocate 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 reviews and assesses ING Bank's performance primarily by line of business. As a result, ING
identified five operating segments which are are also disclosed as reportable segments. Additionally, the
CODM receives information by geographical area based on the location of the office where trasnsactions
originate.
1.8 Hyperinflation accounting
Since the second quarter of 2022, Türkiye has been considered a hyperinflationary economy for accounting
purposes. As ING Bank has a subsidiary in Türkiye, ING Bank has applied IAS 29 ‘Financial Reporting in
Hyperinflationary Economies’ to its operations since 2022 as if the economy in Türkiye had always been
hyperinflationary. Given that ING Bank presents its results in EUR, comparatives do not get restated. As a
result, the impact of the first-time application of IAS 29, as well as the effect for that year were both
recognised in 2022. IAS 29 continued to be relevant for ING’s operations in Türkiye in 2023 and 2024. Under
IAS 29, the results of the operations in Türkiye should be stated in terms of the current purchasing power at
the reporting date. For that, the consumer price index (CPI) as determined by the Turkish Statistical Institute
was used. The CPI for Türkiye (2003=100) at 31 December 2024 was 2,684.55, at 31 December 2023 was
1,859.38 and for 2022 was 1,128.45 (movement 2024: 44.38%; movement 2023: 64.77%, movement 2022:
64.27%). The effect of such restatement for inflation in the current period of the statement of
comprehensive income and the balance sheet has been recognised in the statement of profit or loss within
‘Other net income’ as a ‘Net monetary gain or loss’. The net monetary loss for the period represents the loss
of purchasing power by the net monetary position (monetary assets exceeding monetary liabilities) of ING
Türkiye.
After the application of the above restatement procedures in Turkish Lira under IAS 29, the financial position
and the results for the period of ING Türkiye were translated and presented in EUR at the exchange rate on
31 December 2024. 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 chose to present both the restatement effect resulting from restating
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> Notes to the consolidated financial statements
ING Bank’s interest in the equity of ING Türkiye as required by IAS 29, and the translation effect from
translating at a closing rate that differs from the previous closing rate, in the Currency translation reserve.
1.9 Foreign currency translation
Functional and presentation currency
Items included in the financial statements of each of ING 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 23 ‘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 20 '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 Türkiye are translated at the closing rate; and
• All resulting exchange rate differences are recognised in a separate component of equity.
On consolidation, exchange rate differences arising from the translation of a monetary item that forms part
of the net investment in a foreign operation, and of borrowings and other instruments designated as hedges
of such investments, are taken to shareholders’ equity. When a foreign operation is sold, the corresponding
exchange rate differences are recognised in the statement of profit or loss as part of the gain or loss on sale.
Goodwill and fair value adjustments arising from the acquisition of a foreign operation are treated as assets
and liabilities of the foreign operation and translated at the exchange rate prevailing at the balance sheet
date.
1.10 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:
• 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.
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.
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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: Identification of impairment indicators as well as indicators of potential reversal of previous impairments of ING Bank’s investment in TMBThanachart Bank Public Company Limited (hereafter: TTB), an associate, requires significant judgement. When there is objective evidence of impairment or indicators that prior period impairment losses no longer exist or may have decreased, value in use (VIU) needs to be determined. Estimation of VIU involves significant estimates and management assumptions. See Note 8 ‘Investments in associates and joint ventures’.

1.11 Property and equipment
Property in own use
Land and buildings held for own use are stated at fair value at the balance sheet date. Depreciation is
recognised on a straight-line basis over the estimated useful life (in general 20–50 years). On disposal, the
related revaluation reserve is transferred to retained earnings.
Equipment
Equipment is stated at cost less accumulated depreciation and any impairment losses. The cost of the assets
is depreciated on a straight line basis over their estimated useful lives, which are generally as follows: two to
five years for data processing equipment, and four to ten years for fixtures and fittings.
Disposals of property and equipment
The difference between the proceeds on disposal and net carrying value is recognised in the statement of
profit or loss under Other net income.
Right-of-use assets
ING 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.
Right-of-use assets are measured at cost comprising the amount of the initial measurement of the lease
liability, any lease payments made at or before the commencement date less any lease incentives received
and any initial direct costs and restoration costs.
The right-of-use asset is included in the statement of financial position line-item ‘Property and equipment’.
The lease liability is included in the statement of financial position line-item ‘Other liabilities’. Refer to Note 9
‘Property and equipment’ and to Note 16 ‘Other liabilities’.
Subsequent to initial recognition, the right-of-use asset amortises using a straight-line method to the
income statement over the life of the lease. The lease liability increases for the accrual of interest and
decreases when payments are made. Any remeasurement of the lease liability due to a lease modification
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> Notes to the consolidated financial statements
or other reassessment results in a corresponding adjustment to the carrying amount of the right-of-use
asset.
1.12 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.
1.13 Goodwill and other intangible assets
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. Impairment of goodwill, if
applicable, is included in the statement of profit or loss in Other operating expenses and is not subsequently
reversed.
Computer software
Computer software that has been purchased or generated internally for own use is stated at cost less
amortisation and any impairment losses. Amortisation is calculated on a straight-line basis over its useful
life, which generally does not exceed five years. Amortisation is included in Other operating expenses.
1.14 Taxation
Income tax on the result for the year consists of current and deferred tax. Income tax is recognised in the
statement of profit or loss but it is recognised directly in equity if the tax relates to items that are recognised
directly in equity.
Uncertain tax positions are assessed continually by ING Bank and in case it is probable that there will be a
cash outflow, a current tax liability is recognised.
Deferred income tax
Deferred income tax is provided in full, using the liability method, for temporary differences arising between
the tax basis of assets and liabilities and their carrying amounts in the Consolidated statement of financial
position. Deferred income tax is determined using tax rates (and laws) that have been enacted or
substantively enacted at the balance sheet date and are expected to apply when the related deferred
income tax asset is realised or the deferred income tax liability is settled. Deferred tax assets and liabilities
are not discounted.
Deferred tax assets are recognised when it is probable that future taxable profit will be available against
which the temporary differences can be utilised. Deferred income tax is provided for temporary differences
arising from investments in subsidiaries and associates, except where the timing of the reversal of the
temporary difference is controlled by ING 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.
1.15 Provisions, contingent liabilities and contingent assets
A provision is a present obligation arising from past events, the settlement of which is expected to result in
an outflow of resources embodying economic benefits. However, the timing or the amount is uncertain.
Provisions are discounted when the effect of the time value of money is significant using a pre-tax discount
rate.
Reorganisation provisions include employee termination benefits when ING 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
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> Notes to the consolidated financial statements
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.

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 39 'Legal proceedings'. Critical accounting estimates and assumptions for the reorganisation provision are in estimating the amounts and timing of cash flows as the announced transformation initiatives are implemented over a period of several years. Reference is made to Note 15 'Provisions'.

1.16 Irrevocable Payment Commitments on contributions to SRF and DGS
ING makes contributions to the Single Resolution Fund (SRF) and Deposit Guarantee Schemes (DGS). The
annual contributions are paid in cash or, in some cases, partly using Irrevocable Payment Commitments
(IPCs) that become payable if and when called. Cash contributions are accounted for as levies as described in
section 1.15 above while IPCs are disclosed as contingent liabilities in Note 38 Contingent liabilities and
commitments. Cash collateral posted on IPCs to the SRF is accounted for as an interest bearing financial
asset at amortised cost. Government bonds posted as collateral on IPCs to DGS continue to be recognised as
assets of ING as securities at amortised cost.
1.17 Other liabilities
Defined benefit plans
The net defined benefit asset or liability recognised in the statement of financial position in respect of
defined benefit pension plans is the fair value of the plan assets less the present value of the defined benefit
obligation at the balance sheet date.
Changes in plan assets include mainly:
• Return on plan assets are recognised as staff costs in the statement of profit or loss. It is determined
using a high quality corporate bond rate (identical to the discount rate used in determining the defined
benefit obligation) at the start of the reporting period; and
• Remeasurements which are recognised in Other comprehensive income.
The defined benefit obligation is calculated by internal and external independent qualified actuaries through
actuarial models and calculations using the projected unit credit method. This method considers expected
future payments required to settle the obligation resulting from employee service in the current and prior
periods, discounted using a high quality corporate bond rate. Inherent in these actuarial models are
assumptions including discount rates, rates of increase in future salary and benefit levels, mortality rates,
consumer price index and the expected level of indexation. The assumptions are based on available market
data as well as management expectations and are updated regularly.
Changes in the defined benefit obligation include mainly:
• Service cost which is recognised as staff costs in the statement of profit or loss;
• Interest expenses are recognised as staff costs in the Statement of profit or loss. It is determined using a
high quality corporate bond rate at the start of the period;
• Remeasurements which are recognised in Other comprehensive income (equity) and not recycled to the
Statement of profit or loss;
• Any past service cost relating to a plan amendment is recognised in profit or loss in the period of the plan
amendment; and
• Gains and losses on curtailments and settlements are recognised in the Statement of profit or loss when
the curtailment or settlement occurs.
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> Notes to the consolidated financial statements
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
completion of a minimum service period. The expected costs of these benefits are accrued over the period of
employment using an accounting methodology similar to that for defined benefit pension plans.
1.18 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.
1.19 Expense recognition
Expenses are recognised in the statement of profit or loss as incurred or when a decrease in future economic
benefits related to a decrease in an asset or an increase in a liability has arisen that can be measured
reliably. Fee and commission expenses generally result from contracts with ING service providers, who
perform their service for 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,
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> Notes to the consolidated financial statements
even if the share based payment scheme is discontinued. The rights are subject to certain conditions,
including a pre-determined continuous period of service.
1.20 Statement of cash flows
The statement of cash flows is prepared in accordance with the indirect method, distinguishing cash flows
from operating, investing and financing activities. In the net cash flow from operating activities, the result
before tax is adjusted for those items in the statement of profit or loss and changes in items per the
statement of financial position, which do not result in actual cash flows during the year.
For the purposes of the statement of cash flows, Cash and cash equivalents include deposits from banks and
loans and advances to banks that are on demand. Furthermore, it includes treasury bills and other eligible
bills shorter than three months. Investments qualify as a cash equivalent if they are readily convertible to a
known amount of cash and are subject to an insignificant risk of changes in value.
Cash flows arising from foreign currency transactions are translated into the functional currency using the
exchange rates at the date of the cash flows.
The net cash flow shown in respect of Loans and advances to customers relates only to transactions
involving actual payments or receipts. The Addition to loan loss provision, which is deducted from the item
Loans and advances to customers in the statement of financial position, has been adjusted accordingly from
the result before tax and is shown separately in the statement of cash flows.
The difference between the Net cash flow in accordance with the statement of cash flows and the change
between the opening and closing balance of Cash and cash equivalents in the statement of financial position
is due to exchange rate differences and is presented separately in the cash flow statement.
Liabilities arising from financing activities are debt securities, lease liabilities and subordinated loans.
1.21 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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Notes to the Consolidated statement of financial position
2 Cash and balances with central banks

Cash and balances with central banks
in EUR million | 2024 | 2023
Amounts held at central banks 1 | 68,708 | 88,627
Cash and bank balances | 1,645 | 1,587
| 70,353 | 90,214

1 Amounts held at central banks include an amount of EUR -14 million (2023 : EUR -5 million) of Loan loss provisions.
Amounts held at central banks reflect on-demand balances. The movement reflects ING’s active liquidity
management.
Reference is made to Note 36 '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 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Loans and advances to banks | 14,352 | 9,451 | 7,439 | 7,287 | 21,791 | 16,738
Loan loss provisions | -8 | -11 | -13 | -18 | -22 | -30
| 14,343 | 9,440 | 7,426 | 7,268 | 21,769 | 16,708

Loans and advances include balances of reverse repurchase transactions. For more information, refer to
Note 4 'Financial assets at fair value through profit or loss'. Furthermore, it includes on-demand and term
loans, and cash collateral transactions. Reference is made to Note 7 'Loans and advances to customers' for
information on finance lease receivables included in Loans and advances to banks.
As at 31 December 2024 and at 31 December 2023, 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 | 2024 | 2023
Trading assets | 72,906 | 60,240
Non-trading derivatives | 2,463 | 2,028
Designated at fair value through profit or loss | 5,740 | 5,775
Mandatorily measured at fair value through profit or loss | 56,481 | 54,983
| 137,590 | 123,026

(Reverse) repurchase transactions
Financial assets at fair value through profit or loss include securities lending and sales and repurchase
transactions with securities. At ING, these types of transactions are recognised in several lines in the
statement of financial position depending on business model assessment and counterparty. Furthermore,
for repurchase agreements the gross amount of assets must be considered together with the gross amount
of related liabilities, which are presented separately on the statement of financial position since IFRS does
not always allow the netting of these positions in the statement of financial position. Netting is applicable to
repurchase agreements that are governed by an established Global Master Repurchase Agreement (GMRA).
This netting is restricted to transactions involving the same currency and maturity date, and must occur
within the same legal entity. Reference is made to Note 37 'Offsetting financial assets and liabilities'.
Securities purchased under agreements to resell (reverse repos), securities borrowings and similar
agreements are not recognised in the consolidated statement of financial position as the counterparty
continues to be exposed to substantially all risks and rewards of the transferred security. Based on the
business model assessment and counterparty, the consideration paid to purchase securities is recognised as
Loans and advances to customers, Loans and advances to banks, financial assets mandatorily at FVPL or
Trading assets.
Securities sold subject to repurchase agreements (repos), securities lending and similar agreements continue
to be recognised in the consolidated statement of financial position as ING Bank continues to be exposed to
substantially all risks and rewards of the transferred financial asset. The counterparty liability is designated
and measured at FVPL if the asset is measured mandatorily at FVPL. Otherwise, the counterparty liability is
included in Deposits from banks, Customer deposits or Trading.
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> Notes to the Consolidated statement of financial position
Reference is made to Note 36 'Transfer of financial assets, assets pledged and received as collateral' for
information on transferred assets which were not derecognised.
ING Bank’s exposure to (reverse) repurchase transactions is included in the following lines in the statement of
financial position:

Exposure to (reverse) repurchase agreements
in EUR million | 2024 | 2023
Reverse repurchase transactions |  |
Loans and advances to banks | 10,777 | 5,251
Loans and advances to customers | 3,471 | 499
Trading assets, loans and receivables | 12,033 | 12,121
Loans and receivables mandatorily measured at fair value through profit or loss | 53,393 | 51,536
| 79,675 | 69,407
Repurchase transactions |  |
Deposits from banks | 33 | 2,064
Customer deposits | 1 | 97
Trading liabilities, funds on deposit | 5,269 | 10,337
Funds entrusted designated and measured at fair value through profit or loss | 38,420 | 45,729
| 43,723 | 58,227

Trading assets

Trading assets by type
in EUR million | 2024 | 2023
Equity securities | 20,726 | 15,423
Debt securities | 10,080 | 6,907
Derivatives | 29,805 | 25,680
Loans and receivables | 12,295 | 12,231
| 72,906 | 60,240

Trading assets include assets that 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 | 2024 | 2023
Derivatives used in |  |
- fair value hedges | 617 | 716
- cash flow hedges | 158 | 440
- hedges of net investments in foreign operations | 82 | 100
Other non-trading derivatives | 1,606 | 771
| 2,463 | 2,028

Reference is made to Note 33 'Derivatives and hedge accounting' for information on derivatives designated
in hedge accounting.
Other non-trading derivatives mainly includes interest rate swaps, foreign exchange swaps, and cross
currency swaps for which no hedge accounting is applied.
Designated at fair value through profit or loss

Designated at fair value through profit or loss by type
in EUR million | 2024 | 2023
Debt securities | 4,718 | 4,470
Loans and receivables | 1,022 | 1,306
| 5,740 | 5,775

‘Financial assets designated at fair value through profit or loss’ is partly economically hedged by credit
derivatives. The hedges do not meet the criteria for hedge accounting and the loans and debt securities are
recorded at fair value to avoid an accounting mismatch. The maximum credit exposure of the loans and
receivables and debt securities included in ‘Financial assets designated at fair value through profit or loss’
approximates its carrying value and amounts to EUR 5,740 million (2023: EUR 5,775 million). In 2024, the
change in fair value of these loans and debt securities amounts EUR 5 million (2023: EUR -48 million).
ING has mitigated the credit risk exposure on part of the portfolio. The cost at initial recognition of the
financial assets designated at fair value through profit or loss that are economically hedged by credit
derivatives is EUR 3,797 million (31 December 2023: EUR 3,181 million) and the cumulative change in fair
value attributable to changes in credit risk is EUR 173 million (31 December 2023: EUR 150 million).
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> Notes to the Consolidated statement of financial position
The notional value of the related credit derivatives is EUR 3,807 million (2023: EUR 3,679 million). The
cumulative change in fair value of the credit derivatives since the financial assets were first designated,
amounts to EUR -214 million (2023: EUR -119 million) and the change for the current year is EUR -95 million
( 2023: EUR -122 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 | 2024 | 2023
Equity securities | 228 | 179
Debt securities | 789 | 894
Loans and receivables | 55,464 | 53,911
| 56,481 | 54,983

Equity securities are individually insignificant for ING Bank . For total exposure to debt securities, reference is
made to Note 6 'Debt securities' . Loans and receivables include mainly reverse repurchase agreements.
5 Financial assets at fair value through other comprehensive income

Financial assets at fair value through other comprehensive income by type
in EUR million | 2024 | 2023
Equity securities | 2,562 | 1,885
Debt securities 1 | 42,219 | 38,281
Loans and advances 1 | 1,608 | 951
| 46,389 | 41,116

1 Debt securities include an amount of EUR -12 million (2023: EUR -13 million) and the Loans and advances includes EUR -7 million
(2023: EUR -8 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 | 2024 | 2023 | 2024 | 2023
Investment in Bank of Beijing | 2,241 | 1,590 | 101 | 98
Other Investments | 321 | 295 | 16 | 8
| 2,562 | 1,885 | 117 | 105

As at 31 December 2024 ING holds approximately 13% (2023: 13% ) of the shares of Bank of Beijing, a bank
listed on the stock exchange of Shanghai. The stake in Bank of Beijing is part of the Corporate Line segment.
As per regulatory requirements set by the China Banking and Insurance Regulatory Commission, ING, as a
shareholder holding more than 5% of the shares, is required to supply additional capital when necessary. No
request for additional capital was received in 2024 ( 2023: nil ).
Changes in fair value through other comprehensive income
The following table presents changes in financial assets at fair value through other comprehensive income.

Changes in fair value through other comprehensive income financial assets
| FVOCI equity securities | FVOCI debt instruments 1 | Total
in EUR million | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Opening balance as at 1 January | 1,885 | 1,887 | 39,231 | 29,739 | 41,116 | 31,625
Additions | 11 | 28 | 21,080 | 19,967 | 21,091 | 19,995
Amortisation |  |  | 77 | 31 | 77 | 31
Transfers and reclassifications |  | 5 | 1 |  | 1 | 5
Changes in unrealised revaluations 2 | 605 | 68 | -96 | 657 | 509 | 725
Impairments |  |  | 2 | -1 | 2 | -1
Reversals of impairments |  |  | -7 | 6 | -7 | 6
Disposals and redemptions | -1 | -2 | -16,906 | -11,912 | -16,907 | -11,913
Exchange rate differences | 62 | -100 | 443 | 751 | 506 | 651
Other changes |  |  |  | -6 |  | -6
Closing balance | 2,562 | 1,885 | 43,827 | 39,231 | 46,389 | 41,116

1 Fair value through other comprehensive income debt instruments includes both debt securities and loans and advances.
2 Changes in unrealised revaluations of FVOCI debt instruments include changes on hedged items which are recognised in the
statement of profit or loss. Reference is made to Note 20 'Equity' for details on the changes in revaluation reserve.
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> Notes to the Consolidated statement of financial position
FVOCI equity securities
Exchange rate differences of EUR 62 million (31 December 2023: EUR -100 million) are mainly related to the
stake in Bank of Beijing following the appreciation of CNY versus EUR. In 2024, changes in unrealised
revaluations of equity securities are mainly related to a revaluation of the stake in Bank of Beijing of EUR
590 million (31 December 2023: EUR 77 million) following a change in the share price.
FVOCI debt instruments
In 2024, ING sold the remaining NNHB mortgages, amounting to EUR 263 million to Nationale Nederlanden.
ING agreed in 2012 to transfer a portfolio of NNHB mortgages to NN as part of the required restructuring of
ING Group by the European Commission after having received state support during the global financial crisis
(2008). The majority of these mortgages were not sold immediately but only at the interest reset date of
these mortgages.
In 2024, interest rates in the shorter and longer tenors decreased which resulted in changes in unrealised
revaluations of debt securities of EUR -96 million. During 2023 interest rates in the longer tenors decreased
significantly resulting in unrealised revaluations of EUR 657 million.
Reference is made to Note 6 'Debt securities' for details on ING Bank’s total exposure to debt securities.
6 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 | 2024 | 2023
Debt securities at fair value through other comprehensive income | 42,219 | 38,281
Debt securities at amortised cost | 50,273 | 48,313
Debt securities at fair value through other comprehensive income and amortised cost | 92,493 | 86,594
Trading assets | 10,080 | 6,907
Debt securities designated and measured at fair value through profit or loss | 4,718 | 4,470
Debt securities mandatorily measured at fair value through profit or loss | 789 | 894
Total debt securities at fair value through profit or loss | 15,586 | 12,270
| 108,078 | 98,864

ING Bank’s total exposure to debt securities (excluding debt securities held in the trading portfolio) of EUR
97,999 million (31 December 2023: EUR 91,957 million) is specified as follows:

Debt securities by type of exposure
| Debt Securities at FVPL 1 | Debt Securities at FVOCI | Debt Securities at AC | Total
in EUR million | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Government bonds | 289 | 362 | 24,757 | 20,988 | 22,734 | 24,050 | 47,780 | 45,400
Central bank bonds | 444 | 446 |  |  | 2,900 | 2,043 | 3,344 | 2,489
Sub-sovereign, Supranationals and Agencies | 1,027 | 1,354 | 11,513 | 11,587 | 15,445 | 14,639 | 27,985 | 27,580
Covered bonds |  |  | 4,108 | 4,084 | 5,683 | 5,231 | 9,791 | 9,315
Corporate bonds | 848 | 799 | 79 | 127 | 106 | 109 | 1,033 | 1,035
Financial institutions' bonds | 2,141 | 1,645 | 980 | 483 | 139 | 186 | 3,261 | 2,314
ABS portfolio | 757 | 758 | 794 | 1,025 | 3,281 | 2,077 | 4,832 | 3,860
| 5,506 | 5,363 | 42,231 | 38,293 | 50,288 | 48,335 | 98,026 | 91,991
Loan loss provisions |  |  | -12 | -13 | -15 | -22 | -27 | -34
Debt securities portfolio | 5,506 | 5,363 | 42,219 | 38,281 | 50,273 | 48,313 | 97,999 | 91,957

1 Debt securities at FVPL includes both debt securities designated - and mandatorily measured at fair value through profit or loss.
7 Loans and advances to customers

Loans and advances to customers by type
| Netherlands | Rest of the world | Total
in EUR million | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Loans and advances to public authorities | 1,888 | 1,070 | 16,773 | 13,314 | 18,661 | 14,384
Residential mortgages | 117,223 | 110,475 | 227,992 | 214,120 | 345,216 | 324,596
Other personal lending | 5,007 | 5,036 | 31,789 | 31,535 | 36,797 | 36,571
Corporate Lending | 66,987 | 62,728 | 218,473 | 209,795 | 285,459 | 272,523
| 191,105 | 179,309 | 495,027 | 468,764 | 686,132 | 648,074
Loan loss provisions | -811 | -830 | -5,023 | -4,791 | -5,833 | -5,621
| 190,295 | 178,480 | 490,004 | 463,973 | 680,299 | 642,453

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 2024 EUR 680,085 million ( 2023: EUR 642,260 million) of loans and advances to
customers are non-subordinated.
ING Bank Annual Report 2024 138

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> Notes to the Consolidated statement of financial position
Loans and advances to customers and, to a lesser extent, to banks include finance lease receivables which
are detailed as follows:

Finance lease receivables 1
in EUR million | 2024 | 2023
Maturities of gross investment in finance lease receivables |  |
- within 1 year | 3,962 | 3,827
- between 1-2 years | 2,961 | 2,742
- between 2-3 years | 2,283 | 2,133
- between 3-4 years | 1,577 | 1,475
- between 4-5 years | 902 | 875
- more than 5 years | 1,555 | 1,451
| 13,240 | 12,503
Unearned future finance income on finance leases | -1,145 | -1,040
Net investment in finance leases | 12,095 | 11,463
Included in Loans and advances to banks | 5 | 5
Included in Loans and advances to customers | 12,091 | 11,459
| 12,095 | 11,463

1 The total loan loss provision for finance lease receivables is EUR 193 million (2023: EUR 160 million).
The finance lease receivables mainly relate to the financing of equipment and real estate for third parties
where ING is the lessor and are mainly part of corporate lending. Interest income in 2024 on finance lease
receivables amounts to EUR 522 million (2023: EUR 429 million).
8 Investment in associates and joint ventures

Investments in associates and joint ventures
in EUR million 2024 | 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% | 1,164 | 1,266 | 49,147 | 42,554 | 1,474 | 1,050
Other investments in associates and joint ventures |  |  | 412 |  |  |  |
|  |  | 1,679 |  |  |  |

Investments in associates and joint ventures
in EUR million 2023 | 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% | 976 | 1,128 | 46,666 | 40,776 | 1,386 | 943
Other investments in associates and joint ventures |  |  | 381 |  |  |  |
|  |  | 1,509 |  |  |  |

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's shareholding and representation on the Board. TTB is part of the Corporate Line segment.
Other investments in associates and joint ventures
Included in Other investments in associates and joint ventures are mainly financial services and (non-)
financial technology funds or vehicles operating predominantly in Europe, and are individually not significant
to ING 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, the rating agency and
regulatory views, which can change over time.
ING Bank Annual Report 2024 139

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> Notes to the Consolidated statement of financial position

Changes in Investments in associates and joint ventures
in EUR million | 2024 | 2023
Opening balance as at 1 January | 1,509 | 1,500
Additions | 26 | 55
Transfers | -7 | 0
Revaluations | 0 | 4
Share of results | 205 | 149
Dividends received | -91 | -74
Disposals | -16 | -89
Impairments | -35 | -5
Exchange rate differences | 87 | -32
Other | 0 |
Closing balance | 1,679 | 1,509

Share of results from associates and joint ventures of EUR 205 million (2023: EUR 149 million) as included in
the table above is mainly attributable to our share in the results of TTB of EUR 123 million (2023: EUR 107
million) and our share in the result of an associate in Belgium of EUR 77 million following a one-off profit.
The total impairment losses of EUR 35 million relate to associates that are not individually significant.
Impairments and reversal thereof on the investment in TTB
Accumulated impairments on the investment in TTB of EUR 395 million (2023: EUR 395 million) were
recognised in previous years. There is no impairment trigger observed as per 31 December 2024. A Value in
Use ('VIU') was estimated following the prolonged increase of the quoted TTB share price over the original
cost price of the investment and the sustained improved broker consensus outlook. As VIU did not exceed
the carrying amount of the investment in TTB no reversal of impairment, was recognised.
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and VIU. Fair
value less costs of disposal is based on observable share price. The VIU calculation uses discounted cash flow
projections based on management’s best estimates. VIU is derived using a Dividend Discount Model (DDM)
where distributable equity, i.e. future earnings available to ordinary shareholders, is used as a proxy for
future cash flows. The valuation looks at expected cash flows into perpetuity resulting in two main
components to the VIU calculation:
• The estimation of future earnings over a 5-year forecast period; and
• the terminal value being the extrapolation of earnings into perpetuity applying a long-term growth rate.
The earnings that are used for extrapolation represent the stable long-term financial results and position
of TTB, i.e. a steady state. The terminal value comprises the majority of the total VIU.
Key assumptions used in the VIU calculation as at 31 December 2024
The VIU is determined using a valuation model which is subject to multiple management assumptions. The
key assumptions, i.e. those to which the overall result is most sensitive to, are the following:
• Expected future earnings of TTB: Short- to medium-term expectations are based on forecasts derived
from broker consensus. Longer-term and steady-state expectations into perpetuity are derived using
reasonable and supportable assumptions capturing a combination of TTB specific and market data points;
A capital maintenance charge is applied, which is management’s forecast of the earnings that need to be
withheld in order for TTB to meet target regulatory requirements over the forecast period;
• Discount rate (cost of equity): 10.96%, based on the capital asset pricing model (CAPM) calculated for TTB
using current market data; and
• Terminal growth rate: 2.74% consistent with current long term government bond yield in Thailand as a
proxy for a risk-free rate.
The model was evaluated for reasonably possible changes to key assumptions in the model. This reflects the
sensitivity of the VIU to each key assumption on its own and it is possible that more than one favourable
and/or unfavourable change may occur at the same time. The selected rates of reasonably possible changes
to key assumptions are based on external analysts’ forecasts and other relevant external data sources,
which can change period to period. The sensitivity of the VIU to each key assumption is as follows:
• A favourable change of 10% in the cash flows would result in an increase in VIU of EUR 57 million, while
an unfavourable change of -10% would result in a decrease in VIU of EUR -59 million;
• A favourable change of -1% in the discount rate would result in an increase in VIU of EUR 95 million, while
an unfavourable change of 1% would result in a decrease in VIU of EUR -75 million;
• A favourable change of 1% in the terminal growth rate would result in an increase in VIU of EUR 68
million, while an unfavourable change of -1% would result in a decrease in VIU of EUR -53 million;
ING Bank Annual Report 2024 140

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> Notes to the Consolidated statement of financial position
9 Property and equipment

Property and equipment by type |  |
in EUR million | 2024 | 2023
Property in own use | 758 | 616
Equipment: |  |
- Data processing equipment | 218 | 213
- Other equipment | 426 | 492
Right- of- use assets: |  |
- ROU property | 895 | 972
- ROU cars | 124 | 97
- ROU other leases | 13 | 9
| 2,434 | 2,399

Changes in property and equipment |  |  |  |  |
| Property in own use | Equipment | Right-of-use assets | Total
in EUR million | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Opening balance as at 1 January | 616 | 681 | 705 | 689 | 1,078 | 1,076 | 2,399 | 2,446
Additions | 92 | 4 | 240 | 241 | 141 | 279 | 473 | 525
Transfers | 83 | -1 | -78 | -4 | -4 | -4 | 1 | -9
Depreciation | -11 | -12 | -204 | -204 | -242 | -246 | -457 | -461
Impairments 1 | -9 | -19 | -10 | -10 | -4 | -12 | -23 | -41
Reversals of impairments 1 | 5 | 10 |  |  |  |  | 5 | 10
Remeasurements | 5 | 4 |  |  | 75 | 9 | 80 | 13
Disposals | -36 | -47 | -14 | -10 | -18 | -20 | -68 | -78
Exchange rate differences | 13 | -4 | 5 | 4 | 8 | -4 | 25 | -5
Closing balance | 758 | 616 | 643 | 705 | 1,033 | 1,078 | 2,434 | 2,399
Cost price | 871 | 753 | 3,027 | 3,140 | 1,933 | 1,851 | 5,831 | 5,744
Accumulated depreciation | -298 | -305 | -2,376 | -2,430 | -1,098 | -904 | -3,772 | -3,639
Accumulated impairments | -97 | -99 | -8 | -6 | -31 | -32 | -136 | -136
Accumulated revaluation surplus | 282 | 267 |  |  |  |  | 282 | 267
Accumulated remeasurement |  |  |  |  | 229 | 163 | 229 | 163
Net carrying value | 758 | 616 | 643 | 705 | 1,033 | 1,078 | 2,434 | 2,399

1 Impairments and reversals of impairments of property and equipment are presented as Other operating expenses in the statement of
Profit or Loss.
ING considers valuations from third-party experts in determining the fair values of property in own use. The
vast majority of the land and buildings were appraised during 2024. Property in own use purchase costs
amounted to EUR 871 million (2023: EUR 753 million). Cost or the purchase price less accumulated
depreciation and impairments would have been EUR 476 million ( 2023: EUR 350 million) had property in own
use been valued at cost instead of at fair value.
The reported impairment losses of EUR -23 million ( 2023: EUR -41 million) mainly result from the closure of
branches and unfavourable office market developments.
10 Intangible assets

Changes in intangible assets
| Goodwill | Software | Other | Total
in EUR million | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Opening balance as at 1 January | 469 | 464 | 727 | 636 | 2 | 2 | 1,198 | 1,102
Additions | 6 |  | 43 | 64 | 1 |  | 50 | 64
Capitalised expenses |  |  | 324 | 246 |  |  | 324 | 246
Amortisation |  |  | -215 | -213 |  |  | -216 | -213
Impairments 1 |  |  | -12 | -5 |  |  | -12 | -5
Exchange rate differences | 1 | 5 | 8 | 2 |  |  | 9 | 7
Disposals |  |  | -9 | -10 |  |  | -9 | -10
Changes in the composition of the group and other changes |  |  | -10 | 8 |  | 1 | -10 | 8
Closing balance | 476 | 469 | 855 | 727 | 3 | 2 | 1,334 | 1,198
Gross carrying amount | 476 | 469 | 2,986 | 2,646 | 8 | 8 | 3,471 | 3,123
Accumulated amortisation |  |  | -2,079 | -1,876 | -4 | -4 | -2,084 | -1,879
Accumulated impairments |  |  | -52 | -43 | -2 | -2 | -53 | -45
Net carrying value | 476 | 469 | 855 | 727 | 3 | 2 | 1,334 | 1,198

1 Impairments of intangible assets are presented within Other operating expenses in the statement of Profit or Loss.
ING Bank Annual Report 2024 141

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> Notes to the Consolidated statement of financial position
Goodwill
Goodwill is allocated to groups of cash generating units (CGUs) as follows:

Goodwill allocation to group of CGUs
in EUR million | Method used for recoverable amount | Discount rate | Terminal growth rate | Goodwill | Goodwill
Group of CGUs |  |  |  | 2024 | 2023
Retail Netherlands | Value in use | 7.81% | 2.00% | 30 | 30
Retail Germany | Value in use | 7.77% | 2.00% | 356 | 349
Retail Poland | Value in use | 9.30% | 2.50% | 76 | 75
Retail Romania | Value in use | 11.45% | 3.00% | 15 | 15
|  |  |  | 476 | 469

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. In 2024, no triggering events were identified.
At the annual impairment test in the fourth quarter, the recoverable amount exceeds the carrying value of
the CGUs as at 31 December 2024 and therefore no impairment is required (31 December 2023: nil).
Methodology
The recoverable amount is determined as the higher of the fair value less costs of disposal and Value in Use
(VIU). The VIU calculation is based on a Dividend Discount model using three-year management-approved
plans, updated for expected changes in the macroeconomic environment. When estimating the VIU of a
CGU, local conditions and requirements determine the capital requirements, discount rates, and terminal
growth rates. These local conditions and requirements determine the ability to upstream excess capital and
profits to ING 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 is based on the long-term inflation rate obtained from market
sources. The impacts of climate risk are included to the extent that they are observable in discount rates and
assets prices.
Sensitivity of key assumptions
Key assumptions in the goodwill impairment test model are the projected locally available cash flows (based
on local capital requirements and projected profits), discount rates (cost of equity), and long-term growth
rates.
The recoverable amounts of the CGUs are sensitive to the above key assumptions. A decrease in the
available cash flows of 10%, an increase in the discount rate of 1 percent point or a reduction of the future
growth rate to zero are considered reasonably possible changes in key assumptions. If the aforementioned
changes occur to one of the above key assumptions holding the other key assumptions constant, goodwill of
the remaining CGUs will continue to be recoverable.
Software
Software includes internally developed software amounting to EUR 768 million (2023: EUR 628 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 2024, individually immaterial
items were impaired for an amount of EUR 12 million (31 December 2023: EUR 5 million).
11 Other assets

Other assets by type
in EUR million | 2024 | 2023
Net defined benefit assets | 568 | 554
Investment properties | 19 | 14
Property development and obtained from foreclosures | 18 | 32
Prepayments | 412 | 436
Accrued assets | 496 | 521
Amounts to be settled | 3,548 | 3,869
Other | 1,875 | 1,683
| 6,935 | 7,109

Disclosures in respect of Net defined benefit assets are provided in Note 30 'Pensions and other post-
employment benefits'.
Amounts to be settled include primarily transactions not settled at the balance sheet date. The nature of
these transactions is short term and they are expected to settle shortly after the closing date of the balance
sheet. Other relates to various receivables in the normal course of business, including short-term receivables
from mortgages issued to notary accounts pending transfer to customers and other amounts receivable
from customers.
ING Bank Annual Report 2024 142

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> Notes to the Consolidated statement of financial position
12 Deposits from banks

Deposits from banks by type
| Netherlands | Rest of the world | Total
in EUR million | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Non-interest bearing | 4 | 3 | 166 | 174 | 170 | 177
Interest bearing | 5,845 | 7,803 | 10,707 | 15,277 | 16,553 | 23,080
| 5,849 | 7,806 | 10,873 | 15,451 | 16,722 | 23,257

Deposits from banks include non-subordinated deposits and repurchase transactions. For more information on
reverse repurchase transaction, refer to Note 4 'Financial assets at fair value through profit or loss'.
In 2023, deposits from banks included ING’s participation in the Targeted Longer-Term Refinancing
Operations (TLTRO) of EUR 6.0 billion which was fully repaid in March 2024.
13 Customer deposits

Customer deposits
in EUR million | 2024 | 2023
Current accounts / Overnight deposits | 227,951 | 222,478
Savings accounts | 354,560 | 334,287
Time deposits | 115,636 | 103,186
Other 1 | 1,579 | 2,053
| 699,725 | 662,004

1 ING changed the presentation for the senior non-preferred debt and the comparative figure for 2023 has been adjusted.
Current accounts / Overnight deposits, Saving accounts and Time deposits include balances with individuals,
respectively EUR 107,068 million (2023: EUR 107,711 million), EUR 324,134 million (2023: EUR
305,734 million) and EUR 56,599 million (2023: EUR 46,762 million).

Customer deposits by type
| Netherlands | Rest of the world | Total
in EUR million | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Non-interest bearing | 26 | 239 | 27,142 | 25,316 | 27,168 | 25,556
Interest bearing 1 2 | 245,375 | 244,193 | 427,182 | 392,255 | 672,557 | 636,448
| 245,401 | 244,433 | 454,324 | 417,571 | 699,725 | 662,004

1 Interest bearing includes current accounts which are not remunerated. However ING holds the contractual right to revise the rates.
2 ING changed the presentation for the senior non-preferred debt and the comparative figures for 2023 have been adjusted.
In 2024, Customer deposits includes EUR 8,064 million (31 December 2023: EUR 11,737 million) from ING
Group in time deposits and current accounts.
14 Financial liabilities at fair value through profit or loss

Financial liabilities at fair value through profit or loss
in EUR million | 2024 | 2023
Trading liabilities | 35,255 | 37,220
Non-trading derivatives | 2,101 | 2,019
Designated at fair value through profit or loss | 49,539 | 55,399
| 86,896 | 94,637

Trading liabilities

Trading liabilities by type
in EUR million | 2024 | 2023
Equity securities | 467 | 1,156
Debt securities | 3,185 | 2,492
Funds on deposit | 5,437 | 10,443
Derivatives | 26,166 | 23,129
| 35,255 | 37,220

Non-trading derivatives

Non-trading derivatives by type
in EUR million | 2024 | 2023
Derivatives used in: |  |
- fair value hedges | 79 | 113
- cash flow hedges | 573 | 458
- hedges of net investments in foreign operations | 117 | 92
Other non-trading derivatives | 1,332 | 1,356
| 2,101 | 2,019

Reference is made to Note 33 'Derivatives and hedge accounting' for information on derivatives used for
hedge accounting.
Other non-trading derivatives mainly include interest-rate swaps, foreign-exchange swaps and cross-
currency swaps for which no hedge accounting is applied.
ING Bank Annual Report 2024 143

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> Notes to the Consolidated statement of financial position
Designated at fair value through profit or loss

Designated at fair value through profit or loss by type
in EUR million | 2024 | 2023
Debt securities | 9,326 | 8,219
Funds entrusted | 40,092 | 47,085
Subordinated liabilities | 122 | 95
| 49,539 | 55,399

As at 31 December 2024 , 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 17 million on a cumulative basis ( 2023: EUR -34
million). This change has been determined as the amount of change in fair value of the financial liability that
is not attributable to changes in market conditions that gave rise to market risk (i.e. mainly interest-rate risk
based on yield curves).
The amount that ING 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 11,376 million (2023: EUR 9,958 million).
Funds entrusted include mainly repurchase agreements. For more information on repurchase transactions
refer to Note 4 'Financial assets at fair value through profit or loss'.
15 Provisions

Provisions by type
in EUR million | 2024 | 2023
Reorganisation provisions | 201 | 231
Litigation provisions | 288 | 193
Other provisions | 118 | 334
| 606 | 758
Loan loss provisions for guarantees | 146 | 142
| 752 | 899

Changes in provisions
| Reorganisation | Litigation | Other provisions | Total
in EUR million | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Opening balance as at 1 January | 231 | 418 | 193 | 150 | 334 | 433 | 758 | 1,001
Additions 1 | 146 | 207 | 116 | 78 | 26 | 39 | 288 | 325
Interest |  |  |  |  |  |  |  |
Releases 1 | -4 | -34 | -15 | -26 | -46 | -22 | -64 | -82
Utilised | -163 | -356 | -31 | -23 | -196 | -11 | -390 | -389
Exchange rate differences |  | -1 | 1 | 1 | -1 | -3 |  | -4
Other changes | -10 | -3 | 25 | 13 |  | -104 | 15 | -94
Closing balance | 201 | 231 | 288 | 193 | 118 | 334 | 606 | 758

1 Additions to provisions and unused amounts released are presented in Note 27 'Other operating expenses' in the Statement of Profit
or Loss.
As at 31 December 2024, amounts expected to be settled within 12 months in provisions amount to EUR 552
million ( 2023: EUR 699 million). The amounts included are based on best estimates with regard to amounts
and timing of cash flows required to settle the obligation.
Reorganisation provisions
The additions in 2024 mainly relate to restructuring activities in Belgium, the Netherlands, and at head office.
In 2023, the additions to the reorganisation provisions mainly relate to restructuring activities in Belgium,
Poland, and the Netherlands.
These initiatives are implemented over a period of several years and the estimate of the reorganisation
provisions is inherently uncertain.
Litigation provisions
Reference is made to Note 39 'Legal proceedings' for developments in litigation provisions.
Other provisions
In 2024, the utilisations in the Other provisions mainly relate to the provision for the compensation of Dutch
retail customers for past interest charges that did not sufficiently track market rates. This provision of EUR
180 million was recognized in 2021 and subsequently had been increased by EUR 75 million in 2023.
In 2023, ING Bank voluntarily changed its accounting policy for non-financial guarantees that are subject to
contractual indemnification rights from IAS 37 principles to loan commitment accounting under IFRS 9. The
ING Bank Annual Report 2024 144

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> Notes to the Consolidated statement of financial position
change from IAS 37 to IFRS 9 resulted in derecognition of the existing IAS 37 provision of EUR 109 million as
per 1 January 2023 and recognition of a provision for expected credit losses of EUR 151 million for non-
financial guarantees as per 1 January 2023 (EUR 42 million pre-tax impact on Equity at the beginning of
2023). This change is included in Other changes in the movement table.
For details and changes on loan loss provisioning, refer to ‘Risk management – Credit risk’ paragraph 'Loan
loss provisioning'.
16 Other liabilities

Other liabilities by type
In EUR million | 2024 | 2023
Net defined benefit liability | 152 | 164
Other post-employment benefits | 38 | 30
Other staff-related liabilities | 784 | 719
Other taxation and social security contributions | 899 | 641
Rents received in advance | 14 | 14
Costs payable | 1,763 | 2,170
Amounts to be settled | 4,290 | 6,509
Lease liabilities | 1,116 | 1,162
Other | 1,538 | 1,721
| 10,596 | 13,130

Disclosures in respect of Net defined benefit liabilities are provided in Note 30 'Pensions and other post-
employment benefits'.
Other staff-related liabilities includes vacation leave provisions, jubilee provisions, disability/illness provisions
and liabilities related with variable compensations.
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 2024 was EUR 290 million (2023: EUR
291 million).
The line Other relates mainly to 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 | 2024 | 2023
Fixed rate debt securities |  |
Within 1 year | 26,358 | 29,790
More than 1 year but less than 2 years | 5,718 | 4,660
More than 2 years but less than 3 years | 4,429 | 6,279
More than 3 years but less than 4 years | 5,907 | 4,068
More than 4 years but less than 5 years | 6,105 | 4,722
More than 5 years | 12,335 | 13,139
Total fixed rate debt securities | 60,851 | 62,658
Floating rate debt securities |  |
Within 1 year | 26,262 | 17,871
More than 1 year but less than 2 years | 2,343 | 226
More than 2 years but less than 3 years | 1,080 | 2,176
More than 3 years but less than 4 years | 117 | 75
More than 4 years but less than 5 years | 902 | 0
More than 5 years | 2,903 | 1,417
Total floating rate debt securities | 33,607 | 21,765
Total debt securities | 94,459 | 84,423

Reference is made to the consolidated statement of cash flows for further information on issuances,
redemptions and non-cash movements.
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> Notes to the Consolidated statement of financial position
18 Senior non-preferred debt

Senior non-preferred debt
In EUR million | 2024 | 2023
Senior non-preferred debt | 49,393 | 40,213
| 49,393 | 40,213

Senior non-preferred debt is lent on by ING Groep N.V. to ING Bank N.V. In the event of bankruptcy, such
senior non-preferred debt ranks senior to subordinated liabilities but junior to any other liabilities of ING Bank
N.V.
19 Subordinated loans

Subordinated loans
In EUR million | 2024 | 2023
Subordinated loans | 17,879 | 15,404
| 17,879 | 15,404

Subordinated loans are bonds issued by ING Groep N.V. and its subsidiaries to raise Tier 1 and Tier 2 (CRR-
eligible) capital. Under IFRS these securities are classified as liabilities and for regulatory purposes, they are
considered as capital. Subordinated loans of EUR 18,403 million (2023: EUR 16,240 million) have been placed
with ING Bank N.V. by ING Groep N.V.
In 2024 ING Groep N.V. issued USD 1.25 billion 8.00% Perpetual AT1 Contingent Convertible Capital Securities
in February, EUR 1.25 billion 4.38% Fixed Rate Subordinated Tier 2 Notes in May, EUR 1.25 billion 4.25% Fixed
Rate Subordinated Tier 2 Notes in August and USD 1 billion 7.25% Perpetual AT1 Contingent Convertible
Capital Securities in September.
In 2024 ING Türkiye issued USD 150 million 8.50% Fixed Rate Subordinated Tier 2 Notes in September.
In 2024 ING Groep N.V. redeemed USD 1.25 billion 6.75% Perpetual AT1 Contingent Convertible Capital
Securities in April, EUR 750 million 2.50% Fixed Subordinated Tier 2 notes in February and EUR 1 billion 1.63%
Fixed Subordinated Tier 2 notes in September on their first call dates.
Reference is made to the consolidated statement of cash flows for further information on issuances and
redemptions.
The average interest rate on subordinated loans is 4.59% (2023: 4.44%).
20 Equity

Total equity
In EUR million | 2024 | 2023 | 2022
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 | 1,816 | 1,152 | 1,187
- Revaluation reserve: Debt instruments at FVOCI | -479 | -277 | -339
- Revaluation reserve: Cash flow hedge | -1,693 | -2,058 | -3,055
- Revaluation reserve: Credit liability | -15 | 31 | 70
- Revaluation reserve: Property in own use | 161 | 178 | 176
- Net defined benefit asset/liability remeasurement reserve | -333 | -317 | -232
- Currency translation reserve | -1,986 | -2,527 | -2,395
- Share of associates and joint ventures and other reserves | 2,607 | 3,048 | 3,604
| 78 | -769 | -984
Retained earnings | 25,598 | 23,893 | 26,462
Shareholders’ equity (parent) | 42,743 | 40,191 | 42,546
Non-controlling interests | 995 | 944 | 504
Total equity | 43,738 | 41,135 | 43,050

Adjustments for hyperinflation
ING applies IAS 29 ‘Hyperinflation’ on its investment in Türkiye since 2022. The IAS 29 indexation impact on
equity was EUR 50 million (2023: EUR 54 million; 2022: EUR 100 million) of which EUR 202 million (2023: EUR
284 million; 2022: EUR 1,011 million) in the currency translation reserve, EUR 0 million (2023: EUR 0 million;
2022: EUR -563 million) in retained earnings, EUR 4 million (2023: EUR 3 million; 2022: EUR -17 million) in
revaluation reserves and EUR -156 million (2023: EUR -234 million; 2022: EUR -331 million) in profit or loss.
ING Bank Annual Report 2024 146

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> Notes to the Consolidated statement of financial position
Share capital and share premium

Share capital
| Ordinary shares (par value EUR 1.13)
| Number x 1,000 | Amount
| 2024 | 2023 | 2022 | 2024 | 2023 | 2022
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 2024, 2023 and 2022.
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 2024, 465 million ordinary shares were issued and fully paid.
ING Bank has 50 authorised preference shares with par value of EUR 1.13 per preference share. As at 31
December 2024, 7 preference shares were issued and fully paid (2023: 7 preference shares; 2022: 7
preference shares) amounting to EUR 8 (2023: EUR 8 and 2022: 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.
Revaluation reserves

Changes in revaluation reserve: Equity securities and Debt instruments at FVOCI
| Equity securities at FVOCI | Debt instruments at FVOCI
In EUR million | 2024 | 2023 | 2022 | 2024 | 2023 | 2022
Opening balance | 1,152 | 1,187 | 1,282 | -277 | -339 | 92
Unrealised revaluations | 664 | -35 | -118 | -265 | 53 | -406
Realised gains/losses transferred to the statement of profit or loss |  |  |  | 62 | 9 | -25
Realised revaluations transferred to retained earnings | 0 | 1 | 23 |  |  |
Closing balance | 1,816 | 1,152 | 1,187 | -479 | -277 | -339

Equity securities at FVOCI
In 2024, the unrealised revaluation of EUR 664 million (2023: EUR -35 million; 2022: EUR -118 million)
includes revaluation of shares in Bank of Beijing for EUR 652 million (2023: EUR -24 million; 2022: EUR -86
million).

Changes in cash flow hedge and credit liability reserve
| Cash flow hedge | Credit liability
In EUR million | 2024 | 2023 | 2022 | 2024 | 2023 | 2022
Opening balance | -2,058 | -3,055 | -153 | 31 | 70 | -80
Changes in credit liability reserve |  |  |  | -46 | -39 | 165
Unrealised revaluations | 365 | 997 | -2,901 |  |  |
Realised revaluations transferred to retained earnings |  |  |  |  |  | -15
Closing balance | -1,693 | -2,058 | -3,055 | -15 | 31 | 70

Cash flow hedge
ING mainly hedges floating rate lending with interest rate swaps. Due to a decrease in forward interest rates
in 2024, the interest rate swaps had a positive revaluation of EUR 365 million which is recognised in the cash
flow hedge reserve.
ING Bank Annual Report 2024 147

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> Notes to the Consolidated statement of financial position

Changes in Property in own use reserve
In EUR million | 2024 | 2023 | 2022
Opening balance | 178 | 176 | 208
Impact IAS 29 on opening balance 1 |  |  | -20
Unrealised revaluations | 3 | 10 | 15
Realised revaluations transferred to retained earnings | -20 | -8 | -26
Closing balance | 161 | 178 | 176

1 Impact of application of hyperinflation accounting under IAS 29.
Net defined benefit asset/liability remeasurement reserve
Reference is made to Note 30 'Pensions and other post-employment benefits'.
Currency translation reserve

Changes in currency translation reserve
In EUR million | 2024 | 2023 | 2022
Opening balance | -2,527 | -2,395 | -3,483
Impact IAS 29 on opening balance 1 |  |  | 647
Unrealised revaluations | -222 | 183 | -7
Realised gains/losses transferred to the statement of profit or loss | 1 |  | 4
Exchange rate differences | 763 | -316 | 444
Closing balance | -1,986 | -2,527 | -2,395

1 Impact of application of hyperinflation accounting under IAS 29.
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 unrealised revaluations and Exchange rate differences of EUR 541
million is related to several currencies including USD (EUR 354 million), TRY (EUR 148 million including EUR
202 million IAS 29 indexation effect), GBP (EUR 75 million), PLN (EUR 18 million), CHF (EUR -10 million), AUD
(EUR -35 million), RUB (EUR -47 million), THB (EUR 31 million), CNY (EUR 3 million) and other currencies (EUR 4
million).
Share of associates and joint ventures and other reserves

Changes in share of associates, joint ventures and other reserves
In EUR million | 2024 | 2023 | 2022
Opening balance | 3,048 | 3,604 | 3,416
Result for the year | 125 | 336 | 161
Transfer to/from retained earnings | -565 | -892 | 26
Closing balance | 2,607 | 3,048 | 3,604

The Share of associates, joint ventures and other reserves includes non-distributable profits from associates
and joint ventures of EUR 940 million (2023: EUR 815 million; 2022: EUR 797 million). Other reserves includes
a statutory reserve of EUR 897 million (2023: EUR 1,602 million; 2022: EUR 2,264 million) related to the
former Stichting Regio Bank and the former Stichting Vakbondsspaarbank SPN and a legal reserve of EUR 768
million (2023: EUR 628 million; 2022: EUR 540 million) related to internally developed software. The transfer
to retained earnings of EUR -565 million includes the release of the Regio bank and Vakbondsspaarbank SPN
reserve of EUR -830 million (2023:EUR -998 million; 2022: EUR 0 million) against regulatory expenses which
are recognised in the statement of profit or loss.
Retained earnings

Changes in retained earnings
In EUR million | 2024 | 2023 | 2022
Opening balance | 23,893 | 26,462 | 29,778
Impact on opening balance 1 |  | -45 | -563
Transfer to/from other reserves | 585 | 899 | -8
Result for the year | 6,062 | 6,821 | 3,506
Dividend and other cash distributions | -4,986 | -10,269 | -6,277
Employee share plans | 45 | 30 | 27
Changes in composition of the group and other changes | -1 | -5 | -1
Closing balance | 25,598 | 23,893 | 26,462

1 2023: Changes in policy following the adoption of IFRS 17 and change in policy for non-financial guarantees. 2022: impact of
application of hyperinflation accounting under IAS 29.
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.
ING Bank Annual Report 2024 148

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> Notes to the Consolidated statement of financial position
As at 31 December 2024, an amount of EUR 897 million (2023: EUR 1,602 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 ventures amounts
to EUR 5,672 million (2023: EUR 6,727 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. Refer to Note
44 'Capital management' for an overview of the minimal capital requirements of ING Bank.
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.
ING Bank Annual Report 2024 149

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Notes to the Consolidated statement of profit or loss
21 Net interest income

Net interest income 1
in EUR million | 2024 | 2023 | 2022 |  |  | 2024 | 2023 | 2022
Interest income on loans 2 | 33,892 | 31,850 | 19,429 |  | Interest expense on deposits 3 | 16,849 | 13,282 | 5,321
Interest income on debt securities at amortised cost | 1,204 | 877 | 591 |  | Interest expense on debt securities in issue | 3,796 | 2,856 | 859
Interest income on financial assets at fair value through OCI | 1,481 | 1,078 | 510 |  | Interest expense on subordinated loans | 752 | 707 | 646
Interest income on non-trading derivatives (hedge accounting) | 12,644 | 10,682 | 4,011 |  | Interest expense on non-trading derivatives (hedge accounting) | 13,767 | 11,849 | 4,144
Total interest income using effective interest rate method | 49,221 | 44,486 | 24,541 |  | Total interest expense using effective interest rate method | 35,164 | 28,693 | 10,969
Interest income on financial assets at fair value through profit or loss | 6,343 | 4,934 | 1,444 |  | Interest expense on financial liabilities at fair value through profit or loss | 5,479 | 4,410 | 1,237
Interest income on non-trading derivatives (no hedge accounting) | 3,168 | 2,637 | 2,390 |  | Interest expense on non-trading derivatives (no hedge accounting) | 3,308 | 3,131 | 2,411
Interest income other | 173 | 171 | 101 |  | Interest expense on lease liabilities | 27 | 28 | 15
Total other interest income | 9,685 | 7,741 | 3,935 |  | Interest expense other | 178 | 157 | 98
|  |  |  |  | Total other interest expense | 8,993 | 7,726 | 3,761
Total interest income | 58,905 | 52,228 | 28,476 |  | Total interest expense | 44,157 | 36,419 | 14,730
|  |  |  |  | Net interest income | 14,749 | 15,809 | 13,745

1 Table has been updated to a more aggregated view for presentation purposes and comparatives have been adjusted accordingly. Negative interest on assets and liabilities is no longer presented separately. Furthermore, interest expense on deposits from customers and banks is
now presented on a combined basis within Interest expense on deposits. Refer to footnote 2 and 3.
2 Includes interest income on loans to customers and banks, cash balances as well as negative interest on liabilities. Negative interest on liabilities amounted to EUR 8 million (2023: EUR 19 million; 2022: EUR 892 million).
3 Includes interest paid on deposits from customers and banks, senior non-preferred debt and negative interest on assets. Negative interest on assets amounted to EUR 1 million (2023: EUR nil; 2022: EUR 285 million).
In 2022, a one-off adjustment was recorded in interest income on loans regarding the credit moratoria in
Poland (EUR -343 million).
Due to prevalent rates during the comparative years, Negative interest on liabilities includes the ECB funding
rate benefit from the TLTRO III programme of EUR 314 million in 2022, while for 2024 Interest expense on
deposits includes interest paid under the TLTRO III programme of EUR 59 million (2023: EUR 557 million). The
funding under this programme was fully repaid during the first quarter of 2024.
The ECB funding rate benefit in 2022 caused the discontinuation of the fair value hedge accounting
relationship on TLTRO III, impacting net interest income of 2022 for an amount of EUR -483 million.
ING Bank Annual Report 2024 150

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> Notes to the Consolidated statement of profit and loss
22 Net fee and commission income

Net fee and commission income
in EUR million | 2024 | 2023 | 2022
Fee and commission income |  |  |
Payment Services | 2,219 | 2,062 | 1,888
Securities business | 734 | 584 | 632
Insurance and other broking | 594 | 529 | 682
Portfolio management | 699 | 625 | 600
Lending business | 650 | 602 | 556
Financial guarantees and other commitments | 454 | 459 | 496
Other fee and commission income | 249 | 239 | 232
Total fee and commission income | 5,598 | 5,100 | 5,085
Fee and commission expenses |  |  |
Payment Services | 756 | 704 | 600
Securities business | 147 | 129 | 160
Distribution of products | 475 | 480 | 555
Other fee and commission expenses | 218 | 202 | 184
Total fee and commission expenses | 1,596 | 1,514 | 1,499
Net fee and commission income | 4,002 | 3,586 | 3,586

Payment services fees are earned for providing services for deposit accounts and cards, cash management
and transaction processing including interchange. Securities fees and commissions are fees for securities
brokerage and securities underwriting. Portfolio management fees include fees earned for asset
management activities, fiduciary and related activities in which ING holds or invests assets on behalf of its
customers. Fees and commissions from lending (syndication) business include income earned for lending
advisory, origination, underwriting and loan commitments which are not part of the effective interest rate.
Financial guarantees and other commitments fees and commissions are earned from bank guarantees,
letters of credit and other trade finance related products, factoring and leasing. Fees paid for distribution of
products are all fees paid for the distribution of ING’s products and services through external providers.
Reference is made to Note 28 'Segments' which includes net fee and commission income, as reported to the
the Management Board Banking, disaggregated by line of business and by geographical segment.
23 Valuation results and net trading income

Valuation results and net trading income
in EUR million | 2024 | 2023 | 2022
Securities trading results | 996 | 873 | -356
Derivatives trading results | 207 | 116 | 11
Other trading results | 336 | 273 | 71
Change in fair value of derivatives relating to |  |  |
– fair value hedges | -766 | -3,028 | 5,265
– cash flow hedges (ineffective portion) | 35 | 48 | 20
– other non-trading derivatives | 1,923 | 563 | 1,164
Change in fair value of assets and liabilities (hedged items) | 750 | 2,962 | -5,150
Valuation results on assets and liabilities designated at FVPL (excluding trading) | 31 | -127 | 444
Foreign exchange transactions results | -105 | 1,230 | 33
| 3,407 | 2,910 | 1,503

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.
Net trading income relates to trading assets and trading liabilities which include assets and liabilities that are
classified under IFRS as Trading but are closely related to servicing the needs of the clients of ING. ING offers
products that are traded on the financial markets to institutional clients, corporate clients, and governments.
ING’s trading books are managed based on internal limits and comprise a mix of products 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 the netting of these positions in the statement of financial position. Reference is made to
Note 4 'Financial assets at fair value through profit or loss' and Note 14 'Financial liabilities at fair value
through profit or loss' for information on trading assets and trading liabilities respectively.
Securities trading results include the results of market making in instruments such as government securities,
equity securities, corporate debt securities, money-market instruments. Derivatives trading results include
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 2024 amount to EUR 20 million (2023:
EUR 160 million; 2022 : EUR -157 million). The majority of the risks involved in security and currency trading
are economically hedged with derivatives. The securities trading results are partly offset by results on these
derivatives. The result of these derivatives is included in Derivatives trading results.
ING Bank Annual Report 2024 151

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> Notes to the Consolidated statement of profit and loss
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.
‘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 item s. In 2024, fluctuations in interest rate had a
significant impact on 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. R eference is made to
Note 33 'Derivatives and hedge accounting' for information on derivatives used for hedge accounting.
Furthermore, derivatives trading results are also impacted by fair value movements arising from changes in
credit spreads (CVA and DVA), bid offer spreads, model risk and incremental cost of funding on derivatives
(FVA and CollVA). Refer to Note 32 'Fair value of assets and liabilities' for information on these valuation
adjustments.
24 Investment income

Investment income
in EUR million | 2024 | 2023 | 2022
Dividend income | 117 | 105 | 149
Realised gains/losses on disposal of debt instruments measured at FVOCI | -104 | -11 | 32
Income from and fair value gains/losses on investment properties |  |  | -1
| 13 | 95 | 181

In 2024, 2023 and 2022 dividend income mainly consists of dividend received from ING’s equity stake in Bank
of Beijing.
25 Other net income
In 2024, Other net income of EUR -3 million (2023: EUR -146 million; 2022 : EUR -369 million) includes EUR
-159 million (2023: EUR -244 million ; 2022: EUR -333 million) net monetary loss reflecting the IAS 29
hyperinflation impact in Türkiye related to the indexation of Türkiye's statement of financial position and
statement of profit or loss with an offsetting effect in the currency translation reserve. Other net income in
2024 also includes EUR 53 million receivable related to a prior insolvency of a financial institution in the
Netherlands and a result of EUR 21 million on the sale of the remaining NNHB mortgages. Furthermore, it
includes the positive recovery of defaulted receivables of EUR 27 million (2023 EUR 25 million; 2022 EUR 32
million).
Other net income as per 31 December 2022 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.
26 Staff expenses

Staff expenses
in EUR million | 2024 | 2023 | 2022
Salaries | 4,906 | 4,559 | 4,145
Pension costs and other staff-related benefit costs | 455 | 418 | 390
Social security costs | 690 | 635 | 584
Share-based compensation arrangements | 45 | 30 | 27
External employees | 720 | 776 | 738
Education | 49 | 50 | 47
Other staff costs | 319 | 256 | 222
| 7,184 | 6,725 | 6,152

Share-based compensation arrangements include EUR 45 million (2023: EUR 30 million; 2022: EUR 26 million)
relating to equity-settled share-based payment arrangements. Cash-settled share-based payment
arrangements were terminated in 2023.
ING Bank Annual Report 2024 152

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> Notes to the Consolidated statement of profit and loss

Number of employees
| Netherlands | Rest of the world | Total
| 2024 | 2023 | 2022 | 2024 | 2023 | 2022 | 2024 | 2023 | 2022
Total average number of internal employees at full time equivalent basis | 14,821 | 14,449 | 14,488 | 46,301 | 44,985 | 43,081 | 61,121 | 59,434 | 57,569

Remuneration of senior management, Management Board Banking and Supervisory
Board
Reference is made to Note 43 'Related parties'.
Share plans
ING grants various types of share awards, namely deferred and upfront shares, which form part of the
variable remuneration offering via the Long-term Sustainable Performance Plan (LSPP). The entitlement to
the LSPP share awards is granted conditionally. If the participant remains in employment for an
uninterrupted period between the grant date and the vesting date, the entitlement becomes unconditional,
with the exception of the upfront shares which are immediately vested upon grant. Upfront and deferred
shares awarded to the 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 months applies for
staff and up to 60 months for Board. ING has the authority to apply a holdback to awarded but unvested
shares and a clawback to vested shares.
The share awards granted in 2024 relate to the performance year 2023. In 2024, 180,994 share awards
(2023: 224,796; 2022: 193,157) were granted to the members of the Management Board Banking. To senior
management and other employees 4,248,400 share awards (2023: 3,244,951; 2022: 2,913,926) were
granted.

Changes in share awards
| Share awards (in numbers) | Weighted average grant date fair values (in euros)
| 2024 | 2023 | 2022 | 2024 | 2023 | 2022
Opening balance as at 1 January | 3,895,787 | 3,697,542 | 3,672,659 | 8.81 | 7.97 | 7.60
Granted | 4,429,394 | 3,469,747 | 3,107,083 | 13.75 | 9.71 | 8.99
Vested | -3,343,429 | -3,113,115 | -2,962,698 | 12.29 | 8.83 | 8.60
Forfeited | -128,223 | -158,387 | -119,502 | 10.73 | 8.54 | 7.63
Closing balance | 4,853,529 | 3,895,787 | 3,697,542 | 10.88 | 8.81 | 7.97

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 2024, total unrecognised compensation costs related to share awards amount to EUR 25
million (2023: EUR 15 million; 2022: EUR 13 million). These costs are expected to be recognised over a
weighted average period of 2.0 years (2023: 2.0 years; 2022: 1.9 years).
27 Other operating expenses

Other operating expenses
in EUR million | 2024 | 2023 | 2022
Regulatory costs | 882 | 1,042 | 1,250
Audit and non-audit services | 43 | 36 | 31
IT related expenses | 1,048 | 948 | 818
Advertising and public relations | 441 | 369 | 331
External advisory fees | 315 | 294 | 306
Office expenses | 277 | 289 | 273
Travel and accommodation expenses | 126 | 125 | 91
Contributions and subscriptions | 133 | 122 | 109
Postal charges | 39 | 36 | 31
Depreciation of property and equipment | 457 | 461 | 485
Amortisation of intangible assets | 216 | 213 | 226
(Reversals of) impairments of property and equipment | 18 | 32 | 19
(Reversals of) impairments of intangible assets | 13 | 6 | 60
Addition to / (unused amounts reversed of) provision for reorganisations | 142 | 173 | 170
Addition to / (unused amounts reversed of) other provisions | 76 | 70 | 117
Other | 705 | 622 | 723
| 4,931 | 4,838 | 5,040

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 39 'Legal proceedings'.
ING Bank Annual Report 2024 153

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> Notes to the Consolidated statement of profit and loss
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 2024, are
contributions to DGS of EUR 230 million (2023: EUR 320 million; 2022: EUR 425 million) mainly related to the
Netherlands, Germany, Belgium and Poland and contributions to the SRF and local resolution funds of EUR
35 million (2023: EUR 251 million; 2022: EUR 354 million). In 2024 local bank taxes increased by EUR 145
million from EUR 472 million in 2023 to EUR 617 million (2022: EUR 470 million).
Audit and non-audit services
Audit and non-audit services include fees for services provided by the Bank’s auditors and increases are due
to one-off additional audit procedures and inflation.
Segment reporting
28 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 material accounting policy information'. The results for the period for each
reportable segment are after intercompany and intersegment eliminations and are those reviewed by the
CODM to assess performance of the segments. Corporate expenses are allocated to business lines based on
time spent by head office personnel, the relative number of staff, or on the basis of income, expenses and/or
assets of the segment. Interest income per segment is reported as net interest income because
management relies primarily on net (rather than gross) interest revenue to assess the performance of the
segments.
The following table specifies the segments by line of business and the main sources of income of each of the
segments:

Specification of the main sources of income of each of the segments by line of business
Segments by line of business | Main source of income
Retail Netherlands | Income from products and services provided to private individuals, business banking clients and private banking clients in the Netherlands. The main products and services offered are daily banking, lending, savings, investments and insurance.
Retail Belgium | Income from products and services provided to private individuals, business banking clients and private banking clients in Belgium and Luxembourg. The main products and services offered are similar to those in the Netherlands.
Retail Germany | Income from products and services provided to private individuals, business banking clients and private banking clients in Germany. The main products and services offered are similar to those in the Netherlands.
Retail Other | Income from products and services provided to private individuals, business banking clients and private banking clients in the other retail countries. The main products and services offered are similar to those in the Netherlands.
Wholesale Banking | Income from wholesale banking activities of which the main products are: lending, payments & cash management, working capital solutions, trade finance, financial markets, corporate finance and treasury.

Specification of geographical split of the segments
Geographical split of the segments | Main countries
The Netherlands |
Belgium | Including Luxembourg
Germany |
Other Challengers 1 | Australia, Italy, Spain and Portugal
Growth Markets 1 | Poland, Romania and Türkiye
Wholesale Banking Rest of World | Other countries in Europe & Middle East, Americas, Asia
Other | Corporate Line

1 In 2022, ING discontinued its retail activities in France (Other Challengers) and the Philippines (Growth Markets).
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 Annual Report 2024 154

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> Segment reporting
ING Bank reconciles the total segment results to the total result using Corporate Line. The Corporate Line
includes capital management activities, as ING Bank applies a system of capital charging for its banking
operations in order to create a comparable basis for the results of business units globally, irrespective of the
business units’ book equity and the currency they operate in.
Corporate Line includes certain other income and expenses that are not allocated to the banking businesses.
Furthermore, as from 2022, results in the Corporate Line have been impacted by the application of
hyperinflation accounting in the consolidation of our subsidiary in Türkiye (IAS 29). Total income for
Corporate Line in 2024 amounted to EUR 97 million compared with EUR 275 million in 2023. This included a
hyperinflation accounting impact of EUR -117 million in 2024 versus EUR -179 million in 2023. Excluding
hyperinflation accounting impact, total income declined by EUR 240 million, mainly attributable to a lower
net interest income from Treasury, partly offset by the recognition of a EUR 53 million receivable related to a
prior insolvency of a financial institution in the Netherlands (recorded in other income). Operating expenses
for Corporate Line were EUR 528 million, 2.4% down from EUR 541 million in 2023. Expenses in 2024 included
a hyperinflation impact of EUR 35 million, EUR 25 million of restructuring costs, EUR 22 million for a one-off
CLA related payment to our staff in the Netherlands and a EUR 21 million litigation provision. Expenses in
2023 had included a hyperinflation impact of EUR 48 million and EUR 51 million that had been provisioned.
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.
ING Bank Annual Report 2024 155

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

> Segment reporting

Segments
12 month period | 2024 |  |  |  |  |  |  | 2023 |  |  |  |  |  |  | 2022 |  |  |  |  |  |
in EUR million | Retail Nether- lands | Retail Belgium | Retail Germany | Retail Other | Wholesale Banking | Corporate Line | Total | Retail Nether- lands | Retail Belgium | Retail Germany | Retail Other | Wholesale Banking | Corporate Line | Total | Retail Nether- lands | Retail Belgium | Retail Germany | Retail Other 1 | Wholesale Banking | Corporate Line | Total
Income |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Net interest income | 3,027 | 1,959 | 2,647 | 3,817 | 3,259 | 40 | 14,749 | 3,096 | 2,063 | 2,862 | 3,437 | 4,028 | 323 | 15,809 | 2,888 | 1,668 | 1,666 | 2,725 | 4,260 | 539 | 13,745
Net fee and commission income | 1,049 | 603 | 433 | 609 | 1,317 | -9 | 4,002 | 959 | 502 | 357 | 519 | 1,259 | -10 | 3,586 | 892 | 511 | 437 | 535 | 1,217 | -6 | 3,586
Total investment and other income | 835 | 189 | -173 | 263 | 2,405 | 65 | 3,584 | 945 | 117 | -67 | 277 | 1,771 | -37 | 3,006 | 417 | -32 | 69 | 377 | 849 | -464 | 1,215
– of which share of result from associates and joint ventures |  | 81 |  | 8 | -36 | 118 | 170 |  | 0 |  | 7 | 31 | 107 | 144 |  | 1 |  | 5 | 18 | -125 | -101
– of which revaluations and trading income | 810 | 81 | -160 | 253 | 2,478 | -55 | 3,407 | 898 | 61 | -57 | 264 | 1,730 | 13 | 2,910 | 327 | 113 | 57 | 200 | 952 | -146 | 1,503
Total income | 4,910 | 2,751 | 2,906 | 4,688 | 6,981 | 97 | 22,334 | 5,001 | 2,683 | 3,152 | 4,233 | 7,057 | 275 | 22,401 | 4,196 | 2,147 | 2,172 | 3,637 | 6,325 | 69 | 18,546
Expenditure |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Operating expenses | 2,124 | 1,811 | 1,303 | 2,792 | 3,558 | 528 | 12,116 | 2,135 | 1,852 | 1,243 | 2,479 | 3,313 | 541 | 11,563 | 2,115 | 1,786 | 1,140 | 2,509 | 3,114 | 529 | 11,193
– of which Regulatory expenses | 114 | 206 | 88 | 261 | 212 | 1 | 882 | 212 | 211 | 96 | 252 | 271 | 0 | 1,042 | 250 | 244 | 93 | 369 | 293 | 0 | 1,250
Addition to loan loss provisions | -8 | 134 | 149 | 291 | 627 | 1 | 1,194 | 5 | 169 | 119 | 313 | -92 | 5 | 520 | 67 | 139 | 131 | 302 | 1,220 | 2 | 1,861
Total expenses | 2,117 | 1,944 | 1,452 | 3,083 | 4,185 | 528 | 13,310 | 2,140 | 2,022 | 1,362 | 2,792 | 3,222 | 546 | 12,083 | 2,182 | 1,924 | 1,271 | 2,812 | 4,334 | 531 | 13,053
Result before taxation | 2,793 | 807 | 1,455 | 1,605 | 2,796 | -431 | 9,025 | 2,861 | 661 | 1,790 | 1,441 | 3,836 | -270 | 10,318 | 2,014 | 223 | 901 | 825 | 1,991 | -462 | 5,493
Taxation | 723 | 210 | 505 | 381 | 693 | 67 | 2,580 | 740 | 182 | 631 | 359 | 900 | 114 | 2,926 | 540 | 72 | 202 | 254 | 581 | 74 | 1,723
Non-controlling interests |  | 0 | 1 | 221 | 35 |  | 258 |  | 0 | 0 | 174 | 61 |  | 235 |  | 0 | 3 | 47 | 52 | 1 | 102
Net result 2 | 2,070 | 597 | 949 | 1,002 | 2,068 | -499 | 6,187 | 2,121 | 479 | 1,159 | 908 | 2,875 | -385 | 7,157 | 1,474 | 151 | 696 | 525 | 1,358 | -537 | 3,667

1 In 2022, ING discontinued its retail activities in France (Other Challengers) and the Philippines (Growth Markets).
2 Net result reflects the net result attributable to shareholders of the parent.
ING Bank Annual Report 2024 156

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

> Segment reporting

Geographical split of the segments
12 month period | 2024 | 2023 | 2022
in EUR million | Nether- lands | Belgium | Ger- many | Other Challen gers | Growth markets | Wholesale Banking Rest of World | Other | Total | Nether- lands | Belgium | Ger- many | Other Challen gers | Growth markets | Wholesale Banking Rest of World | Other | Total | Nether- lands | Belgium | Ger- many | Other Challen gers 1 | Growth markets 1 | Wholesale Banking Rest of World | Other | Total
Income |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Net interest income | 3,063 | 2,478 | 3,182 | 2,131 | 2,409 | 1,448 | 37 | 14,749 | 3,773 | 2,712 | 3,375 | 2,121 | 1,961 | 1,548 | 320 | 15,809 | 3,782 | 2,065 | 2,126 | 1,842 | 1,462 | 1,933 | 534 | 13,745
Net fee and commission income | 1,329 | 832 | 484 | 337 | 445 | 585 | -9 | 4,002 | 1,239 | 715 | 400 | 285 | 384 | 573 | -10 | 3,586 | 1,171 | 714 | 494 | 290 | 375 | 548 | -6 | 3,586
Total investment and other income | 1,889 | 207 | -188 | 27 | 408 | 1,167 | 73 | 3,584 | 1,627 | 145 | -81 | 21 | 487 | 829 | -24 | 3,006 | 577 | -14 | 94 | 182 | 386 | 449 | -460 | 1,215
– of which share of result from associates and joint ventures | -45 | 87 |  |  | 8 |  | 120 | 170 | 31 |  |  |  | 7 |  | 107 | 144 | 16 | 1 |  |  | 5 |  | -123 | -101
– of which revaluations and trading income | 1,916 | 119 | -191 | 2 | 403 | 1,217 | -59 | 3,407 | 1,568 | 95 | -83 | 4 | 479 | 841 | 6 | 2,910 | 453 | 174 | 65 | 3 | 377 | 532 | -101 | 1,503
Total income | 6,282 | 3,517 | 3,478 | 2,495 | 3,262 | 3,200 | 102 | 22,334 | 6,639 | 3,573 | 3,694 | 2,427 | 2,833 | 2,950 | 286 | 22,401 | 5,531 | 2,765 | 2,714 | 2,314 | 2,223 | 2,930 | 69 | 18,546
Expenditure |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
Operating expenses | 3,026 | 2,170 | 1,512 | 1,454 | 1,759 | 1,669 | 526 | 12,116 | 3,065 | 2,195 | 1,437 | 1,320 | 1,495 | 1,509 | 543 | 11,563 | 3,001 | 2,120 | 1,318 | 1,380 | 1,426 | 1,418 | 529 | 11,193
– of which Regulatory expenses | 159 | 228 | 90 | 61 | 260 | 83 | 1 | 882 | 296 | 243 | 103 | 92 | 207 | 101 | 0 | 1,042 | 357 | 283 | 99 | 88 | 324 | 98 | 0 | 1,250
Addition to loan loss provisions | 42 | 148 | 222 | 188 | 214 | 378 | 1 | 1,194 | -111 | 139 | 35 | 166 | 189 | 96 | 5 | 520 | 181 | 230 | 460 | 140 | 230 | 618 | 2 | 1,861
Total expenses | 3,068 | 2,319 | 1,734 | 1,642 | 1,973 | 2,047 | 526 | 13,310 | 2,954 | 2,334 | 1,472 | 1,486 | 1,683 | 1,605 | 548 | 12,083 | 3,182 | 2,350 | 1,778 | 1,519 | 1,657 | 2,036 | 531 | 13,053
Result before taxation | 3,213 | 1,198 | 1,744 | 853 | 1,289 | 1,153 | -425 | 9,025 | 3,685 | 1,239 | 2,222 | 941 | 1,149 | 1,345 | -263 | 10,318 | 2,349 | 415 | 936 | 795 | 567 | 894 | -463 | 5,493
Retail Banking | 2,793 | 807 | 1,455 | 534 | 1,071 |  |  | 6,660 | 2,861 | 661 | 1,790 | 649 | 792 |  |  | 6,753 | 2,014 | 223 | 901 | 547 | 278 |  | 0 | 3,964
Wholesale Banking | 420 | 391 | 289 | 319 | 218 | 1,153 | 7 | 2,796 | 824 | 577 | 432 | 292 | 357 | 1,345 | 8 | 3,836 | 335 | 192 | 34 | 248 | 288 | 894 | 0 | 1,991
Corporate Line |  |  |  |  |  |  | -431 | -431 |  |  |  |  |  |  | -270 | -270 |  |  |  |  |  |  | -462 | -462
Result before taxation | 3,213 | 1,198 | 1,744 | 853 | 1,289 | 1,153 | -425 | 9,025 | 3,685 | 1,239 | 2,222 | 941 | 1,149 | 1,345 | -263 | 10,318 | 2,349 | 415 | 936 | 795 | 567 | 894 | -463 | 5,493
Taxation | 847 | 308 | 563 | 272 | 256 | 267 | 66 | 2,580 | 909 | 349 | 723 | 282 | 225 | 335 | 104 | 2,926 | 658 | 114 | 297 | 258 | 153 | 186 | 58 | 1,723
Non-controlling interests |  | 0 | 1 |  | 256 |  |  | 258 |  | 0 | 0 |  | 234 |  |  | 235 |  | 0 | 3 |  | 98 |  | 1 | 102
Net result 2 | 2,367 | 889 | 1,179 | 581 | 777 | 886 | -491 | 6,187 | 2,776 | 889 | 1,499 | 659 | 690 | 1,011 | -367 | 7,157 | 1,691 | 301 | 636 | 537 | 316 | 708 | -522 | 3,667

1 In 2022, ING discontinued its retail activities in France (Other Challengers) and the Philippines (Growth Markets).
2 Net result reflects the net result attributable to shareholders of the parent.
ING Bank Annual Report 2024 157

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> Segment reporting
29 Information on geographical areas
ING Bank ’s business lines operate in different geographical areas: the Netherlands, Belgium, Germany, Rest
of Europe and Rest of the World. The geographical analyses are based on the location of the office from
which the transactions are originated and do not include countries where ING only has representation
offices. The Netherlands is ING 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 do not include intercompany balances and reconcile to the total assets in the
consolidated statement of financial position of ING Bank.
ING Bank is subject to top-up tax (Global Anti-Base Erosion Model Rules (Pillar Two)) in relation to its
operations in countries where the effective tax rate falls below 15%. This includes Switzerland, Ireland and
Bulgaria as a result of their lower nominal tax rates, as well as Singapore, where special local tax rates for
certain types of income reduce the effective tax rate.
ING Bank has applied a temporary mandatory relief from deferred tax accounting for the impacts of the top-
up tax and accounts for it as a current tax when it is incurred. The total top-up tax that is expected to be paid
by ING Bank per jurisdiction over 2024 amounts to EUR 9.5 million.

Overview Top up tax to be paid per jurisdiction
Country | Top-up tax (EUR million)
Singapore 1 | 6.5
Ireland 2 | 2.1
Bulgaria 2 | 0.6
Switzerland 2 | 0.3
| 9.5

1 Booked and to be paid in the Netherlands.
2 Booked and to be paid locally.
The table below provides additional information, for the years 2024, 2023 and 2022 respectively, on names
of principal subsidiaries and branches, the nature of main activities and the average number of employees
on a full time equivalent basis by country/tax jurisdiction.
ING Bank Annual Report 2024 158

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> Segment reporting

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
|  |  |  | 2024 | 2023 | 2022 | 2024 | 2023 | 2022 | 2024 | 2023 | 2022 | 2024 | 2023 | 2022 | 2024 | 2023 | 2022 | 2024 | 2023 | 2022
Netherlands | Netherlands | ING Bank N.V. | Wholesale / Retail | 14,821 | 14,449 | 14,488 | 4,618 | 5,370 | 5,017 | 300,167 | 292,868 | 308,931 | 833 | 1,651 | 1,069 | 371 | 514 | 418 | 589 | 601 | 392
Belgium | Belgium | ING België N.V. | Wholesale / Retail | 5,994 | 6,392 | 6,582 | 3,274 | 3,246 | 2,353 | 137,225 | 128,437 | 127,085 | 1,266 | 1,209 | 286 | 325 | 339 | 81 | 272 | 169 | 152
| Luxembourg | ING Luxembourg S.A. | Wholesale / Retail | 887 | 939 | 927 | 492 | 608 | 422 | 13,942 | 14,392 | 18,351 | 215 | 349 | 180 | 54 | 89 | 45 | 116 | 40 | 37
Germany | Germany | ING DiBa A.G. | Wholesale / Retail | 5,460 | 5,499 | 5,573 | 3,848 | 3,931 | 2,815 | 172,828 | 168,991 | 161,997 | 2,119 | 2,467 | 1,039 | 686 | 807 | 328 | 663 | 904 | 189
Rest of Europe | Poland 1 | ING Bank Slaski S.A | Wholesale / Retail | 11,575 | 11,677 | 11,130 | 2,620 | 2,350 | 1,652 | 56,090 | 52,134 | 45,598 | 1,313 | 1,236 | 544 | 280 | 286 | 143 | 231 | 136 | -23
| Spain | Branch of ING Bank N.V. | Wholesale / Retail | 1,692 | 1,576 | 1,439 | 1,230 | 1,165 | 877 | 35,912 | 33,083 | 32,262 | 555 | 541 | 299 | 176 | 128 | 98 | 185 | 114 | 101
| Italy | Branch of ING Bank N.V. | Wholesale / Retail | 1,235 | 1,190 | 1,118 | 514 | 438 | 345 | 16,448 | 14,836 | 14,152 | 120 | 133 | 63 | 38 | 55 | 22 | 16 | 19 | 2
| Romania 1 | Branch of ING Bank N.V. | Wholesale / Retail | 4,282 | 3,971 | 3,580 | 749 | 690 | 584 | 12,937 | 11,496 | 10,555 | 401 | 396 | 324 | 67 | 61 | 51 | 76 | 55 | 67
| Türkiye | ING Bank A.S. | Wholesale / Retail | 2,795 | 2,973 | 3,076 | 142 | 14 | 64 | 4,897 | 4,770 | 5,400 | -110 | -232 | -143 | 18 | -20 | 65 | 5 | 29 | 79
| UK | Branch of ING Bank N.V. | Wholesale | 741 | 722 | 692 | 811 | 758 | 693 | 59,615 | 50,572 | 46,066 | 249 | 510 | 286 | 52 | 131 | 81 | 70 | 101 | 58
| Switzerland | Branch of ING Bank N.V. | Wholesale | 300 | 292 | 277 | 228 | 248 | 290 | 9,086 | 8,501 | 9,513 | 104 | 137 | 182 | 16 | 19 | 25 | 29 | 52 | 45
| France 2,3 | Branch of ING Bank N.V. | Wholesale | 194 | 194 | 600 | 241 | 252 | 372 | 7,819 | 8,322 | 8,934 | 4 | 122 | 44 | 4 | 33 | 12 | 9 | 7 | 22
| Ireland | Branch of ING Bank N.V. | Wholesale | 119 | 82 | 72 | 135 | 83 | 66 | 3,592 | 3,907 | 2,771 | 99 | 65 | 26 | 15 | 8 | 3 | 10 | 8 | 6
| Czech Republic 3 | Branch of ING Bank N.V. | Wholesale | 122 | 134 | 137 | 77 | 76 | 78 | 3,382 | 3,191 | 3,192 | 37 | 33 | 38 | 8 | 6 | 6 | 4 | 10 | 13
| Hungary | Branch of ING Bank N.V. | Wholesale | 128 | 127 | 120 | 63 | 85 | 82 | 2,179 | 1,893 | 1,993 | 6 | 35 | 38 | 3 | 7 | 5 | 9 | 9 | 2
| Russia | ING Bank (Eurasia) Z.A.O. | Wholesale | 236 | 259 | 272 | 139 | 136 | 246 | 764 | 925 | 2,783 | 99 | 151 | 128 | 19 | 31 | 9 | 21 | 20 | 21
| Slovakia 1 | Branch of ING Bank N.V. | Wholesale | 1,489 | 1,347 | 1,129 | 22 | 20 | 15 | 612 | 618 | 391 | 8 | 11 | -1 | 3 | 2 | 1 | 4 | 2 | 0
| Portugal | Branch of ING Bank N.V. | Wholesale | 11 | 10 | 11 | 23 | 17 | 15 | 815 | 620 | 689 | 18 | 12 | 9 | 4 | 3 | 3 | 4 | 2 | 2
| Ukraine | PJSC ING Bank Ukraine | Wholesale | 92 | 91 | 91 | 45 | 53 | 45 | 651 | 590 | 385 | 29 | 44 | 9 | 14 | 22 | 2 | 25 | 7 | 2
| Bulgaria | Branch of ING Bank N.V. | Wholesale | 64 | 61 | 60 | 27 | 23 | 15 | 570 | 530 | 436 | 13 | 11 | 1 | 2 | 1 | 0 | 2 | 1 | 0
| Austria | Branch of ING Bank N.V. | Wholesale | 20 | 17 | 17 | 10 | 9 | 19 | 394 | 383 | 261 | -2 | -4 | 9 | 0 | -1 | 2 | 0 | 1 | 3

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 (2023: EUR 0.2 million; 2022: EUR 0.1 million).
3 In 2022, ING exited from the retail banking markets in France and the Philippines.
ING Bank Annual Report 2024 159

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

> Segment reporting

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
|  |  |  | 2024 | 2023 | 2022 | 2024 | 2023 | 2022 | 2024 | 2023 | 2022 | 2024 | 2023 | 2022 | 2024 | 2023 | 2022 | 2024 | 2023 | 2022
Rest of the World | Australia | ING Bank (Australia) Ltd. | Wholesale / Retail | 1,994 | 1,820 | 1,556 | 994 | 1,033 | 948 | 53,895 | 52,734 | 52,728 | 460 | 572 | 557 | 142 | 174 | 172 | 195 | 185 | 135
| USA | ING Financial Holdings Corp. | Wholesale | 659 | 603 | 586 | 1,277 | 1,124 | 892 | 65,197 | 66,143 | 65,024 | 759 | 654 | 413 | 195 | 185 | 115 | 175 | 183 | 135
| Singapore | Branch of ING Bank N.V. | Wholesale | 572 | 576 | 565 | 474 | 354 | 354 | 34,593 | 26,816 | 25,701 | 333 | 172 | 105 | 44 | 24 | 14 | 24 | 13 | 21
| Japan | Branch of ING Bank N.V. | Wholesale | 32 | 32 | 31 | 42 | 40 | 30 | 9,570 | 14,267 | 5,128 | 25 | 17 | 20 | 5 | 7 | 7 | 4 | 10 | -1
| South Korea | Branch of ING Bank N.V. | Wholesale | 86 | 86 | 78 | 86 | 92 | 86 | 8,050 | 6,167 | 7,989 | 32 | 39 | 47 | 7 | 9 | 12 | 7 | 24 | 7
| Hong Kong | Branch of ING Bank N.V. | Wholesale | 100 | 104 | 103 | 76 | 101 | 82 | 3,512 | 4,378 | 4,343 | 24 | -18 | -33 | 4 | -2 | -5 | 0 | 0 | 0
| Taiwan | Branch of ING Bank N.V. | Wholesale | 37 | 37 | 35 | 27 | 39 | 33 | 3,507 | 2,597 | 3,578 | 4 | 0 | -16 | 1 | 1 | -5 | 3 | 0 | 4
| China | Branch of ING Bank N.V. | Wholesale | 78 | 78 | 76 | 29 | 18 | 30 | 1,935 | 998 | 1,181 | -5 | -12 | 4 | -1 | 2 | 5 | 0 | -9 | 13
| Philippines 1,3 | Branch of ING Bank N.V. | Wholesale | 5,290 | 4,079 | 3,098 | 16 | 10 | 10 | 477 | 403 | 381 | 14 | 1 | -39 | 3 | 2 | 8 | 3 | 2 | 2
| United Arab Emirates | Branch of ING Bank N.V. | Wholesale | 12 | 11 | 10 | 0 | -2 | -1 | 1 | 1 | 1 | 0 | -3 | -1 | 0 | 0 | 0 | 0 | 0 | 0
| Sri Lanka | Branch of ING Hubs B.V. | Global services | 5 | 4 | 4 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0
| Brazil | ING ADMINISTRAÇÃO LTDA. | In run-off / liquidation | 0 | 2 | 30 | 4 | 18 | 17 | 63 | 73 | 57 | 3 | 17 | 9 | 25 | 0 | 1 | 1 | 4 | 5
| Mexico | ING Consulting, S.A. de C.V. | In run-off / liquidation | 0 | 0 | 6 | 0 | 0 | 0 | 0 | 0 | 1 | 0 | 0 | -2 | 0 | 0 | 0 | 0 | 0 | 0
| Canada | Payvision Canada Services Ltd. | Dissolved in 2023 |  | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 | 0 |  | 0 | 0
| Macau | Payvision Macau Ltd. | Liquidated in 2022 |  |  | 0 |  |  | 0 |  |  | 0 |  |  | 0 |  |  | 0 |  |  | 0
| Indonesia | PT ING Securities Indonesia | Liquidated in 2022 |  |  | 0 |  |  | 0 |  |  | 0 |  |  | 0 |  |  | 0 |  |  | 0
| Malaysia | Branch of ING Bank N.V. | Closed in 2022 |  |  | 0 |  |  | 0 |  |  | 1 |  |  | 0 |  |  | 0 |  |  | 0
| Mauritius | ING Mauritius Investment I | Liquidated in 2022 |  |  | 0 |  |  | 0 |  |  | 0 |  |  | 0 |  |  | 0 |  |  | 0
Total |  |  |  | 61,121 | 59,434 | 57,569 | 22,334 | 22,401 | 18,546 | 1,020,724 | 975,636 | 967,861 | 9,025 | 10,318 | 5,493 | 2,580 | 2,926 | 1,723 | 2,753 | 2,700 | 1,489

1 Includes significant number of FTEs in relation to global services provided.
3 In 2022, ING exited from the retail banking markets in France and the Philippines.
ING Bank Annual Report 2024 160

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> Segment reporting
2024
The higher tax charge of 45% in the Netherlands (compared to the statutory rate of 25.8%) was mainly
caused by the non-deductible Dutch bank tax (EUR 246 million) and other non-deductible expenses.
The positive tax charge reported for ING Türkiye with respect to its loss was mainly caused by the non-
deductibility for tax purposes of the accounting loss based on hyperinflation accounting.
The high tax charge in Brazil is caused by tax corrections prior periods in connection with the run-off of our
Brazilian operations.
ING has taken on no new business with Russian companies in 2024, has scaled down operations and has
taken actions to separate the business from ING’s networks and systems. On 28 January 2025, ING
announced that it has reached an agreement on the sale of its business in Russia to Global Development
JSC. For further information, reference is made to Note 45 'Subsequent events '.
2023
The higher tax charge of 31% in the Netherlands (compared to the statutory rate of 25.8%) was mainly
caused by the non-deductible Dutch bank tax (EUR 189 million) and other non-deductible expenses.
The lower tax charge in Spain was caused by a tax refund (EUR 43 million) regarding previous years.
ING continued reducing Russian-related exposure during 2023, the local results on a standalone basis were
positively impacted by releases of loan loss provisions following improved macroeconomic indicators and
decrease in exposures following sales and repayments.
The lower negative tax charge reported for ING Türkiye with respect to its loss was mainly caused by the non
deductibility for tax purposes of the accounting loss based on hyperinflation accounting.
2022
The higher tax charge of 39% in the Netherlands (compared to the statutory rate of 25.8%) was mainly
caused by the non-deductible Dutch bank tax (EUR 179 million) and the non-deductible impairments
regarding goodwill ING Türkiye (EUR 32 million) and TTB (EUR 165 million).
The higher positive tax charge of Türkiye combined with an accounting loss based on hyperinflation
accounting was mainly caused by the non deductibility of this loss for tax purposes.
Since the Russian invasion of 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 standalone basis were higher compared to 2021. 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 EUR (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..
ING Bank Annual Report 2024 161

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Additional notes to the Consolidated
financial statements
30 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 post-employment
benefits are primarily discounts on ING products.
Defined contribution plans
ING, as part of the labour agreements with its employees, sponsors a number of defined contribution plans.
ING’s obligation is limited to contributions which are agreed in advance and also includes employee
contributions. The most significant plans are in the Netherlands and Belgium. The employer's contribution is
recognised as an expense which amounted in 2024 to EUR 423 million (2023: EUR 391 million)
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 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
The Netherlands | 325 | 331 | 415 | 426 | -90 | -95
United States | 250 | 257 | 235 | 245 | 15 | 12
United Kingdom | 1,206 | 1,257 | 751 | 790 | 455 | 467
Belgium | 513 | 516 | 450 | 473 | 63 | 43
Other countries | 341 | 317 | 368 | 353 | -26 | -37
Funded status (Net defined benefit asset/liability) | 2,636 | 2,678 | 2,219 | 2,288 | 416 | 390
Presented as: |  |  |  |  |  |
- Other assets |  |  |  |  | 568 | 554
- Other liabilities |  |  |  |  | -152 | -164
|  |  |  |  | 416 | 390

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 2024. 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.
ING Bank Annual Report 2024 162

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> Additional notes to the Consolidated financial statements
Changes in the fair value of plan assets for the period were as follows:

Changes in fair value of plan assets
in EUR million | 2024 | 2023
Opening balance as at 1 January | 2,678 | 2,637
Interest income | 106 | 115
Remeasurements: Return on plan assets excluding amounts included in interest income | -118 | -8
Employer's contribution | 23 | 28
Participants contributions | 4 | 4
Benefits paid | -128 | -119
Effect of curtailment or settlement | -8 |
Exchange rate differences | 79 | 22
Closing balance | 2,636 | 2,678
Actual return on the plan assets | -12 | 107

As at 31 December 2024 the defined benefit plans did not hold any direct investments in ING Groep N.V.
(2023: nil). During 2024 and 2023 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 2025.
Changes in the present value of the defined benefit obligation and other post-employment benefits for the
period were as follows:

Changes in defined benefit obligation and other post-employment benefits
| Defined benefit obligation | Other post- employment benefits
in EUR million | 2024 | 2023 | 2024 | 2023
Opening balance as at 1 January | 2,288 | 2,159 | 30 | 29
Current service cost | 28 | 27 | 1 | 1
Interest cost | 87 | 92 | 3 | 2
Remeasurements: Actuarial gains and losses arising from changes in demographic assumptions | -3 | -9 |  |
Remeasurements: Actuarial gains and losses arising from changes in financial assumptions | -94 | 127 | 5 | 1
Participants’ contributions | 3 | 3 |  |
Benefits paid | -132 | -123 | -1 | -1
Past service cost | 1 | 1 |  |
Effect of curtailment or settlement | -9 |  |  |
Exchange rate differences and other changes | 51 | 12 | 1 | -2
Closing balance | 2,219 | 2,288 | 38 | 30

Amounts recognised directly in Other comprehensive income were as follows:

Changes in the net defined benefit assets/liability remeasurement reserve
in EUR million | 2024 | 2023
Opening balance as at 1 January | -317 | -232
Remeasurement of plan assets | -118 | -8
Actuarial gains and losses arising from changes in demographic assumptions | 3 | 9
Actuarial gains and losses arising from changes in financial assumptions | 94 | -127
Taxation and Exchange rate differences | 5 | 40
Total Other comprehensive income movement for the year | -16 | -85
Closing balance | -333 | -317

In 2024, the EUR -118 million (2023: EUR -8 million) of remeasurements of plan assets, that is recognised as
a loss in other comprehensive income, is driven by yield changes on investments. The EUR 94 million (2023:
EUR -127 million) of actuarial gains arising from changes in financial assumptions in the calculation of the
defined benefit obligation is mainly due to an increase in discount rates.
ING Bank Annual Report 2024 163

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> Additional notes to the Consolidated financial statements
The accumulated amount of remeasurements recognised directly in Other comprehensive income is EUR
-447 million(EUR -333 million after tax) as at 31 December 2024 (2023: EUR -397 million; EUR -317 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 | 2024 | 2023 | 2022 | 2024 | 2023 | 2022 | 2024 | 2023 | 2022
Current service cost | 28 | 27 | 33 | 1 | 1 | 1 | 29 | 28 | 34
Past service cost | 1 | 1 |  |  |  | -1 | 1 | 1 |
Net Interest cost | -19 | -23 | -8 | 3 | 2 | 1 | -16 | -21 | -6
Effect of curtailment or settlement | -1 |  |  |  |  |  | -1 |  |
Defined benefit plans | 9 | 5 | 26 | 4 | 3 | 2 | 13 | 8 | 27
Defined contribution plans |  |  |  |  |  |  | 423 | 391 | 364
Pension and other post employment benefits |  |  |  |  |  |  | 435 | 399 | 392
Other staff related benefits |  |  |  |  |  |  | 20 | 19 | -2
Pension and other staff-related benefits |  |  |  |  |  |  | 455 | 418 | 390

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 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 2024 was 4.4% (2023: 4.0%) 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 2024 was 5.7% (2023:
5.2%).
Sensitivity analysis of key assumptions
ING performs sensitivity analyses on the most significant assumptions: discount rates, mortality, expected
rate of salary increase, and indexation. The sensitivity analysis has been carried out under the assumption
that the changes occurred at the end of the reporting period.
The sensitivity analysis calculates the financial impact on the defined benefit obligation of an increase or
decrease of the weighted averages of each significant actuarial assumption with all other assumptions held
constant. In practice, this is unlikely to occur, and some changes of the assumptions may be correlated.
Changes to mortality, expected rate of salary increase, and indexation would have no material impact on
the defined benefit obligation. The most significant impact would be from a change in the discount rate. An
increase or decrease in the discount rate of 1.0% creates an impact on the defined benefit obligation of
EUR 212 million (increase) and EUR 253 million (decrease), respectively.
Expected cash flows
ING Bank’s subsidiaries should fund the cost of the entitlements expected to be earned on a yearly basis.
For 2025, the expected contributions to defined benefit pension plans are EUR -48 million.
The benefit payments for defined benefit and other post-employment benefits expected to be made by the
plan between 2025-2029 are estimated to be between EUR 145 million and EUR 156 million per year. From
2029 to 2033, the total payments made by the plan are expected to be EUR -768 million.
ING Bank Annual Report 2024 164

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> Additional notes to the Consolidated financial statements
31 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 2024 | Net liability (-) Net asset (+) opening balance | Change through equity | Change through net result | Exchange rate differences | Changes in the composition of the group and other changes | Net liability (-) Net asset (+) ending balance
Financial assets at FVOCI | 63 | 71 | -8 |  |  | 126
Financial assets and liabilities at FVPL | -3 |  | -28 | 12 |  | -19
Depreciation | -13 |  | -9 |  |  | -22
Cash flow hedges | 502 | -138 |  | -1 |  | 363
Pension and post-employment benefits | -33 | 6 | 1 | -5 | -1 | -32
Other provisions | 48 |  | 12 | 1 | 1 | 62
Loans and advances | 475 |  | -49 |  |  | 427
Unused tax losses carried forward | 209 |  | -128 | 3 |  | 85
Other | -154 | -41 | -9 | -5 | 1 | -208
Total | 1,096 | -102 | -219 | 6 |  | 781
Presented in the statement of financial position as: |  |  |  |  |  |
– Deferred tax liabilities | -184 |  |  |  |  | -287
– Deferred tax assets | 1,280 |  |  |  |  | 1,069
| 1,096 |  |  |  |  | 781

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 178 million
(2023: EUR 195 million and 2022: EUR 205 million ) and a deferred tax amount for lease liabilities of EUR 197
million (2023: EUR 217 million and 2022: EUR 231 million).
The deferred tax on cash flow hedges relate to floating rate lending with interest rate swaps. Due to
decreased (longer-term) interest rate yield curve in 2024 there was a positive revaluation of the cash flow
hedge through other comprehensive income. This resulted in a decline in the deferred tax asset by EUR -138
million compared to the decline deferred tax assets in 2023 by EUR -251 million due to the decline in the
interest yield curve. The deferred tax asset in cash flow hedges decreased from EUR 502 million in 2023 to
EUR 363 million in 2024.
The deferred tax on Loans and advances changes through net result in 2024 EUR -49 million (2023: EUR
-140 million) relates mainly to valuation changes of collectively assessed expected credit losses.
Unused tax losses carried forward declined by EUR 124 million mainly due to realised results on derivatives
used in Cash flow hedging which in previous years led to a tax loss in Poland.
The deferred tax changes through equity - Other in 2024 of EUR -41 million (2023: EUR 13 million) is due to
FX developments following the USD appreciation and the application of IAS 29 Hyperinflation in Türkiye and
also due to the decline in the Credit Liability Reserve due to credit spread tightening.

Changes in deferred tax
in EUR million 2023 | 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 | 80 | -10 | -3 | -4 |  | 63
Financial assets and liabilities at FVPL | 28 |  | -44 | 13 |  | -3
Depreciation | -13 |  | -6 | 3 | 4 | -13
Cash flow hedges | 752 | -251 |  | 1 |  | 502
Pension and post-employment benefits | -54 | 31 | -7 | -4 |  | -33
Other provisions | 59 |  | -12 | -3 | 4 | 48
Loans and advances | 612 | 8 | -140 | -6 | 2 | 475
Unused tax losses carried forward | 327 |  | -128 | 11 | -1 | 209
Other | -251 | 13 | 90 | -2 | -4 | -154
Total | 1,539 | -209 | -249 | 10 | 5 | 1,096
Presented in the statement of financial position as: |  |  |  |  |  |
– deferred tax liabilities | -257 |  |  |  |  | -184
– deferred tax assets | 1,796 |  |  |  |  | 1,280
| 1,539 |  |  |  |  | 1,096

ING Bank Annual Report 2024 165

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> Additional notes to the Consolidated financial statements

Deferred tax in connection with unused tax losses carried forward
in EUR million | 2024 | 2023
Total unused tax losses carried forward | 1,345 | 1,870
Unused tax losses carried forward not recognised as a deferred tax asset | 951 | 815
Unused tax losses carried forward recognised as a deferred tax asset | 394 | 1,055
Average tax rate | 21.6% | 19.9%
Deferred tax asset | 85 | 209

Total unused tax losses carried forward analysed by expiry terms
| No deferred tax asset recognised | Deferred tax asset recognised
in EUR million | 2024 | 2023 | 2024 | 2023
Within 1 year |  |  |  |
More than 1 year but less than 5 years | 135 | 126 | 14 | 633
More than 5 years but less than 10 years | 9 | 9 | 66 | 2
More than 10 years but less than 20 years |  |  |  |
Unlimited | 808 | 681 | 313 | 421
| 951 | 815 | 394 | 1,055

Deferred tax assets are recognised for temporary deductible differences, for tax losses carried forward and
unused tax credits only to the extent that realisation of the related tax benefit is probable

Breakdown of certain net deferred tax asset positions by jurisdiction
in EUR million | 2024 | 2023
Poland |  | 244
Slovakia |  | 1
China | 9 | 2
Australia | 1 | 1
Hong Kong | 5 | 8
United States of America | 1 |
Türkiye | 40 | 41
Taiwan | 10 | 11
| 66 | 308

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 2024 as in 2023, ING Bank Slaski (Poland) realised a tax profit following the value changes of the cash flow
hedge derivatives which are settled net via a central clearing party, whereas in the years before, ING Bank
Slaski incurred a tax loss following the large value changes of the cash flow hedge derivatives. In 2024 ING
Slaski utilised the tax assets related to the 2023 unused tax losses carried forward.
At 31 December 2024 and 2023, ING Bank had no significant temporary differences associated with the
parent company’s investments in subsidiaries and associates as any economic benefit from those
investments will not be taxable at parent company level.
Statement of profit or loss – Taxation

Taxation by type
| Netherlands | Rest of the world | Total
in EUR million | 2024 | 2023 | 2022 | 2024 | 2023 | 2022 | 2024 | 2023 | 2022
Current taxation | 384 | 558 | 496 | 1,977 | 2,120 | 1,510 | 2,361 | 2,677 | 2,006
Deferred taxation | -13 | -45 | -79 | 232 | 293 | -204 | 219 | 249 | -283
| 371 | 513 | 417 | 2,209 | 2,413 | 1,306 | 2,580 | 2,926 | 1,723

ING Bank Annual Report 2024 166

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> Additional notes to the Consolidated financial statements

Reconciliation of the weighted average statutory income tax rate to ING Bank’s effective income tax rate
in EUR million | 2024 | 2023 | 2022
Result before tax from continuing operations | 9,025 | 10,318 | 5,493
Weighted average statutory tax rate | 25.1% | 25.5% | 24.8%
Weighted average statutory tax amount | 2,263 | 2,634 | 1,363
Permanent differences affecting current tax |  |  |
Participation exemption | -87 | -43 | -64
Other income not subject to tax | -64 | -68 | -40
Expenses not deductible for tax purposes | 424 | 398 | 403
Current tax from previously unrecognised amounts | -1 | 1 | 10
State and local taxes | 77 | 99 | 68
Adjustments to prior periods | -34 | -72 | -29
Differences affecting deferred tax |  |  |
Impact on deferred tax from change in tax rates | -1 | 2 | 5
Deferred tax benefit from previously unrecognised amounts | -1 | -30 | -3
Write-off/reversal of deferred tax assets | 4 | 4 | 10
Effective tax amount | 2,580 | 2,926 | 1,723
Effective tax rate | 28.6% | 28.4% | 31.4%

The weighted average statutory tax rate in 2024 (25.1%) declined compared to that of 2023 ( 25.5%).
The effective tax rate of 28.6% in 2024 is higher than the weighted average statutory tax rate. This is mainly
caused by the impact in 2024 of the following non-deductible items for income tax purposes: hyperinflation
accounting loss in Türkiye, interest expenses, and bank- and local taxes in various countries.
The weighted average statutory tax rate in 2023 (25.5%) was higher than the rate of 24.8% in 2022.
The effective tax rate of 28.4% in 2023 was higher than the weighted average statutory tax rate. This is
mainly caused by the impact in 2023 of the following non-deductible items income tax purposes:
hyperinflation accounting loss in Türkiye, interest expenses, and bank- and local taxes in various countries.
Adjustments to prior periods mainly relate to a tax refund in Spain.
The effective tax rate of 31.4% in 2022 was higher than the weighted average tax rate. This is mainly caused
by the impact in 2022 of the following non-deductible items for income tax purpose: hyperinflation
accounting loss in Türkiye, impairments on TTB and interest expenses in various countries.
Equity – Other comprehensive income

Income tax related to components of other comprehensive income
in EUR million | 2024 | 2023 | 2022
Unrealised revaluations financial assets at fair value through other comprehensive income and other revaluations | 100 | -7 | 140
Realised gains/losses transferred to the statement of profit or loss (reclassifications from equity to profit or loss) | -29 | -3 | 8
Changes in cash flow hedge reserve | -138 | -251 | 875
Remeasurement of the net defined benefit asset/liability | 6 | 31 | 6
Changes in fair value of own credit risk of financial liabilities at fair value through profit or loss | 5 | 2 | 19
Exchange rate differences and other | -46 | 19 | -141
Total income tax related to components of other comprehensive income | -102 | -209 | 907

ING Bank Annual Report 2024 167

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> Additional notes to the Consolidated financial statements
32 Fair value of assets and liabilities
a) Valuation methods
The estimated fair values represent the price that would be received to sell an asset or paid to transfer a
liability in an orderly transaction between market participants at the measurement date. It is a market-
based measurement, which is based on assumptions that market participants would use and takes into
account the characteristics of the asset or liability that market participants would take into account when
pricing the asset or liability.
Fair values of financial assets and liabilities are based on quoted prices in active market where available.
When such quoted prices are not available, the fair value is determined by using valuation techniques.
b) Valuation control framework
The valuation control framework covers the product approval process (PARP), pricing, market data
assessment and independent price verification (IPV), valuation adjustments, model use, fair value hierarchy
and day one profit or loss. Valuation processes are governed by various governance bodies, including Local
Parameter Committees, the Global Valuation and Impairment Committee, the Market Data Committee and
the Valuation Model Committee. All relevant committees meet on a regular basis (monthly/quarterly), where
the 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 Global
Financial Markets Parameter Committee reviews the consolidated valuation outcome and resulting P&L for
Financial Market products, targeting a globally consistent treatment across Financial Markets. The Market
Data Committee is responsible for the approval of the market data used in valuation.
c) Valuation adjustments
Valuation adjustments are an integral part of the fair value. They are the adjustments to the output from a
valuation technique in order to appropriately determine a fair value in accordance with IFRS13. ING considers
various fair value adjustments including Bid-Offer adjustments, Model Risk adjustments, Bilateral Valuation
Adjustments (BVA, consisting of Credit Valuation Adjustments or CVA, and Debit valuation Adjustments or
DVA), Collateral Valuation Adjustment (CollVA) and Funding Valuation Adjustment (FVA).
For financial instruments where the fair value at initial recognition is based on one or more significant
unobservable inputs, a difference between the transaction price and the fair value resulting from the internal
valuation process can occur. Such difference is referred to as Day One Profit or Day One Loss (hereafter:
DOP). ING defers material DOP of instruments with significant unobservable valuation inputs, which are the
financial instruments classified as Level 3 and financial instruments with material unobservable inputs into
CVA which are not necessarily classified as Level 3. The DOP is amortised over the life of the instrument, or
until the significant unobservable inputs become observable, or until the significant unobservable inputs
become non-significant. Both the impact on the profit and loss in 2024 and the DOP reserve is disclosed in
the below table.
Deferred Day One Profit or Loss Reserve
The table below summarises the movement in the aggregate DOP not recognised when financial instruments
were initially recognised, because of the use of valuation techniques for which not all the inputs were market
observable data.

Deferred day one profit or loss reserve
in EUR million | 2024 | 2023
Opening balance at 1 January | -90 | -108
DOP deferred on new transactions during the period | -62 | -83
DOP recognised in the statement of profit or loss during the period: |  |
– of which release | 27 | 85
– of which amortisation and exchange differences | 32 | 15
Closing balance at 31 December | -94 | -90

The following table presents the model reserves for financial assets and liabilities.
ING Bank Annual Report 2024 168

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> Additional notes to the Consolidated financial statements

Valuation adjustment reserves on financial assets and liabilities
in EUR million | 2024 | 2023
Deferred Day One Profit or Loss | -94 | -90
Own credit adjustments | -17 | 34
Bid/Offer | -130 | -154
Model Risk | -33 | -26
CVA | -123 | -131
DVA | 50 | 55
CollVA | -3 | -4
FVA | -64 | -68
Other valuation adjustments | 2 | 0
Total Valuation Adjustments | -412 | -385

Own Credit Adjustment
Own issued debt and structured notes that are designated at fair value through profit or loss are adjusted for
ING`s own credit risk by means of DVA.
Bid-Offer Adjustment
For positions priced based upon mid-market input parameters, Bid-Offer adjustments are required in order to
reflect the valuation of that position based on bid price or offer price. In practice this adjustment accounts for
the difference in valuation from ‘mid to bid’ and ‘mid to offer’ for long and short exposures respectively. In
principle, assets are valued at the bid prices and liabilities are valued at the offer price. For certain assets or
liabilities, where a market-quoted price is not available, the price used is the fair value that is most
representative within the bid-offer spread.
Model Risk Adjustment
Financial instruments that are valued using a valuation model can be subject to model risk. Model risk is the
risk of possible financial loss resulting from a pricing model or model-based parameter deficiencies and/or
uncertainties.
Bilateral Valuation Adjustments (Credit and Debit Valuation Adjustments)
Bilateral Valuation Adjustment is the valuation adjustment reflecting the counterparty credit risk of
derivative contracts. It has a bilateral nature, where both the counterparty’s credit risk (i.e. Credit Valuation
Adjustment or CVA) and ING’s own credit risk (Debit Valuation Adjustment or DVA) are taken into account:
• CVA is the fair value adjustment applicable to derivative instruments to account for the possibility that the
counterparty defaults (i.e. it is the market value of the counterparty’s credit risk).
• DVA is the fair value adjustment applicable to derivative instruments to account for the possibility that
ING defaults (i.e. it is the market value of ING’s credit risk).
The calculation of CVA and DVA on derivatives is based on their expected exposures, and the counterparties’
and ING’s risk of default, taking into account the collateral agreements as well as netting agreements. The
counterparties’ risk of default is measured by probability of default and expected loss given default, which is
based on market information including credit default swap (CDS) spreads. Where counterparty CDS spreads
are not available, relevant proxy spreads are used. Additionally, wrong-way risk (which occurs when the
probability of default by the counterparty increases or decreases when ING’s exposure to the counterparty
increases (decreases)) and right-way risk (which occurs when the probability of default by the counterparty
increases (decreases) when ING’s exposure to the counterparty decreases (increases)) are included in the
adjustment.
Collateral Valuation Adjustment (CollVA)
Collateral Valuation Adjustment is a fair valuation adjustment applied on derivative instruments to capture
specific features of CSA (Credit Support Annex) with a counterparty that the regular OIS discounting
framework does not capture. Non-standard CSA features may include deviations in relation to the currencies
in which ING posts or receives collateral, deviations in the remuneration rate on collateral which may pay
lower or higher rate than the overnight rate or even no interest at all; other deviations can be posting
securities rather than cash as collateral.
Funding Valuation Adjustment (FVA)
Funding Valuation Adjustment (FVA) is a fair valuation adjustment applied on derivative instruments to
address the asymmetry in funding costs or funding benefits between collateralised and uncollateralised
derivative portfolios. This adjustment is based on the expected exposure profiles of the uncollateralised or
partially collateralised OTC derivatives and market-based funding spreads.
Other Valuation Adjustments
This pertains to other valuation adjustments that are immaterial to ING. Most of the balance consists of the
Market Price Uncertainty (MPU) adjustment in fair value, which accounts for the price uncertainty risk
inherent in the valuation inputs to fair value.
d) Fair value hierarchy
ING 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.
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> Additional notes to the Consolidated financial statements
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.
L evel 2 – Valuation technique supported by observable inputs
This category includes financial instruments whose fair value is based on market observable inputs, either
directly or indirectly, other than quoted prices included within Level 1. The fair value for financial instruments
in this category can be determined by reference to quoted prices for similar instruments in active markets,
quoted prices for identical or similar instruments in markets that are not active, inputs other than quoted
prices that are observable or market-corroborated inputs. ING analyses how the prices are derived and
determines whether the prices are liquid tradable prices or model-based consensus prices taking various
data as inputs.
For financial instruments that do not have a reference price available, fair value is determined using a
valuation technique (e.g., a model), where inputs in the model are taken from an active market or are
observable, such as interest rates and yield curves observable at commonly quoted intervals, implied
volatilities, and credit spreads.
Instruments where inputs are unobservable are classified in this category, provided that the impact of those
unobservable inputs on the overall valuation is insignificant. The notion of significant is particularly relevant
for the distinction between Level 2 and Level 3 assets and liabilities, as the significance assessment of the
valuation input on the entire fair value measurement will determine whether the instrument should be
classified as Level 2 or Level 3. Expert judgement is required on the significance assessment approach.
Level 3 – Valuation technique supported by unobservable inputs
This category includes financial instruments whose fair value is determined using a valuation technique for
which a significant part of the overall valuation is driven by unobservable valuation inputs. Where valuation
inputs are unobservable, the Group must use the best information available to value the instruments. This
may require internally derived inputs taking into account market participants' assumptions that are
reasonably available, including assumptions on the risk inherent in a particular valuation technique used to
measure fair value and the risk inherent in the inputs to the valuation technique. Unobservable inputs may
include, among others, volatility, correlation, spreads to discount rates, default rates, recovery rates,
prepayment rates, and certain credit spreads.
Financial instruments at fair value
The fair values of the financial instruments were determined as follows:

Methods applied in determining fair values of financial assets and liabilities (carried at fair value)
| Level 1 | Level 2 | Level 3 | Total
in EUR million | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Financial Assets |  |  |  |  |  |  |  |
Financial assets at fair value through profit or loss |  |  |  |  |  |  |  |
- Equity securities | 20,798 | 15,449 | 15 | 3 | 141 | 150 | 20,954 | 15,602
- Debt securities | 7,485 | 4,825 | 4,596 | 4,081 | 3,505 | 3,364 | 15,586 | 12,270
- Derivatives | 1 | 39 | 31,792 | 27,134 | 475 | 535 | 32,268 | 27,708
- Loans and receivables | 0 | 0 | 62,168 | 63,316 | 6,614 | 4,131 | 68,782 | 67,446
| 28,285 | 20,314 | 98,571 | 94,533 | 10,734 | 8,179 | 137,590 | 123,026
Financial assets at fair value through other comprehensive income |  |  |  |  |  |  |  |
- Equity securities | 2,292 | 1,622 |  |  | 270 | 263 | 2,562 | 1,885
- Debt securities | 39,859 | 35,848 | 2,360 | 2,433 | 0 | 0 | 42,219 | 38,281
- Loans and receivables | 0 | 0 | 1,608 | 275 | 0 | 676 | 1,608 | 951
| 42,151 | 37,470 | 3,967 | 2,707 | 270 | 938 | 46,389 | 41,116
Financial liabilities |  |  |  |  |  |  |  |
Financial liabilities at fair value through profit or loss |  |  |  |  |  |  |  |
– Debt securities | 824 | 575 | 8,437 | 7,603 | 67 | 47 | 9,328 | 8,224
– Deposits |  |  | 45,648 | 57,607 |  | 13 | 45,648 | 57,620
– Trading securities | 3,631 | 3,604 | 12 | 41 | 10 |  | 3,653 | 3,645
– Derivatives | 45 | 41 | 27,528 | 24,437 | 694 | 670 | 28,267 | 25,148
| 4,501 | 4,220 | 81,625 | 89,687 | 770 | 729 | 86,896 | 94,637

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> Additional notes to the Consolidated financial statements
The following methods and assumptions were used by ING to estimate the fair value of the financial
instruments:
Equity securities
Instrument description: Equity securities include stocks and shares, corporate investments and private
equity investments.
Valuation: If available, the fair values of publicly traded equity securities and private equity securities are
based on quoted market prices. In the absence of active markets, fair values are estimated by analysing the
investee’s financial position, result, risk profile, prospect, price, earnings comparisons and revenue multiples.
Additionally, reference is made to valuations of peer entities where quoted prices in active markets are
available. For equity securities, best market practice will be applied using the most relevant valuation
method. All non-listed equity investments, including investments in private equity funds, are subject to a
standard review framework which ensures that valuations reflect the fair values.
Fair value hierarchy: The majority of equity securities are publicly traded, and quoted prices are readily and
regularly available. Hence, these securities are classified as Level 1. Equity securities which are not traded in
active markets mainly include corporate investments, fund investments and other equity securities and are
classified as Level 3.
Debt securities
Instrument description: Debt securities include government bonds, financial institutions bonds and Asset-
backed securities (ABS).
Valuation: Where available, fair values for debt securities are generally based on quoted market prices.
Quoted market prices are obtained from an exchange market, dealer, broker, industry group, pricing service,
or regulatory service. The quoted prices from non-exchange sources are reviewed on their tradability of
market prices. If quoted prices in an active market are not available, fair value is based on an analysis of
available market inputs, which include consensus prices obtained from one or more pricing services.
Furthermore, fair values are determined by valuation techniques discounting expected future cash flows
using market interest rate curves, ref erenced credit spreads, maturity of the investment, and estimated
prepayment rates where applicable.
Fair value hierarchy: Government bonds and financial institution bonds are generally traded in active
markets. Where quoted prices are readily and regularly available, they are classified as Level 1. The
remaining positions are classified as Level 2 or Level 3 depending on the trading activity and observability of
prices. Asset backed securities for which no active market is available and a wide discrepancy in quoted
prices exists, are classified as Level 3.
Derivatives
Instrument description: Derivative contracts can either be exchange-traded or over the counter (OTC).
Derivatives include interest rate derivatives, FX derivatives, credit derivatives, equity derivatives and
commodity derivatives.
Valuation: The fair value of exchange-traded derivatives is determined using quoted market prices in an
active market and are classified as Level 1 of the fair value hierarchy. For instruments that are not actively
traded, fair values are estimated based on valuation techniques. OTC derivatives and derivatives trading in an
inactive market are valued using valuation techniques. The valuation techniques and inputs depend on the
type of derivatives and the nature of the underlying instruments. The principal techniques used to value
these instruments are based on, among others, discounted cash flows, option pricing models and Monte
Carlo simulations. These valuation models calculate the present value of expected future cash flows, based
on ‘no-arbitrage’ principles. The models are commonly used in the financial industry and inputs to the
validation models are determined from observable market data where possible. Certain inputs may not be
observable in the market, but can be determined from observable prices via valuation model calibration
procedures. These inputs include prices available from exchanges, dealers, brokers or providers of pricing,
yield curves, credit spreads, default rates, recovery rates, dividend rates, volatility of underlying interest
rates, equity prices, and foreign currency exchange rates and reference is made to quoted prices, recently
executed trades, independent market quotes and consensus data, where available. For uncollateralised OTC
derivatives, ING applies Credit Valuation Adjustment to correctly reflect the counterparty credit risk in the
valuation and Debit Valuation Adjustments to reflect the credit risk of ING for its counterparty. In addition, for
these derivatives ING applies Funding Valuation Adjustment. See sections CVA/DVA and FVA in section c)
Valuation Adjustments for more details regarding the calculation.
Fair value hierarchy: The majority of the derivatives are priced using observable inputs and are classified as
Level 2. Derivatives for which the input cannot be implied from observable market data are classified as Level 3.
Loans and receivables
Instrument description: Loans and receivables are non-derivative financial assets with fixed or determinable
payments that are not quoted in an active market. Loans and receivables carried at fair value include trading
loans, being securities lending and similar agreement comparable to collateralised lending, syndicated loans,
loans expected to be sold and receivables with regards to reverse repurchase transactions.
Valuation: The fair value of loans and receivables is generally estimated by discounting expected future cash
flows using a discount rate that reflects credit risk, liquidity, and other current market conditions. The fair
value of mortgage loans is estimated by taking into account prepayment behaviour.
Fair value hierarchy: Loans and receivables are predominantly classified as Level 2. Loans and receivables
for which current market information about similar assets to use as observable, corroborated data for all
significant inputs into a valuation model is not available, are classified as Level 3.
Financial liabilities at fair value through profit and loss
Instrument description: Financial liabilities at fair value through profit and loss include debt securities and
debt instruments, primarily comprised of structured notes, which are held at fair value under the fair value
option. Besides that, they include derivative contracts and repurchase agreements.
Valuation: The fair values of securities in the trading portfolio and other liabilities at fair value through profit
or loss are based on quoted market prices, where available. For those securities not actively traded, fair
ING Bank Annual Report 2024 171

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> Additional notes to the Consolidated financial statements
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 a EUR 0.8 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 2024.
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 2024 of EUR 11.0 billion
(31 December 2023: EUR 9.1 billion), an amount of EUR 9.6 billion (87.2%) (31 December 2023: EUR 7.0 billion,
being 76.7%) is based on unadjusted quoted prices in inactive markets. As ING does not generally adjust
quoted prices using its own inputs, there is no significant sensitivity to ING’s own unobservable inputs.
Furthermore, Level 3 financial assets include EUR 0.1 billion (31 December 2023: EUR 0.3 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 1.3 billion (31 December 2023: EUR 1.8 billion) of the fair value classified in Level 3
financial assets is established using valuation techniques that incorporate certain inputs that are
unobservable.
Of the total amount of financial liabilities classified as Level 3 as at 31 December 2024 of EUR 0.8 billion
(31 December 2023: EUR 0.7 billion), an amount of EUR 0.6 billion (75.7%) (31 December 2023: EUR 0.4 billion,
being 50.0%) 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.
Furthermore, Level 3 financial liabilities include EUR 0.1 billion (31 December 2023: EUR 0.3 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 2023: 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).
ING Bank Annual Report 2024 172

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> Additional notes to the Consolidated financial statements

Valuation techniques and range of unobservable inputs (Level 3)
| Assets | Liabilities | Valuation techniques | Significant unobservable inputs | Lower range | Upper range
In EUR million | 2024 | 2023 | 2024 | 2023 |  |  | 2024 | 2023 | 2024 | 2023
At fair value through profit or loss |  |  |  |  |  |  |  |  |  |
Debt securities | 3,504 | 3,364 | 10 | 0 | Price based | Price (%) | 0% | 0% | 120% | 122%
|  |  |  |  |  | Price (price per share) | 327 | 97 | 520 | 236
|  |  |  |  | Present value techniques | Credit spread (bps) | n.a. | 94 | n.a. | 94
|  |  |  |  |  | Price (%) | 95.85% | n.a. | 100% | n.a.
Equity securities | 141 | 150 |  |  | Price based | Price (price per share) | 0 | 0 | 5,475 | 5,457
Loans and advances | 1,565 | 2,298 | 0 | 13 | Price based | Price (%) | 0% | 0% | 107% | 117%
|  |  |  |  | Present value techniques | Credit spread (bps) | 576 | 1 | 629 | 12
|  |  |  |  |  | Prepayment rate (%) | 2% | n.a. | 100% | n.a.
(Reverse) repo's | 5,050 | 1,832 |  |  | Present value techniques | Interest rate (%) | 2% | n.a. | 2% | n.a.
Structured notes |  |  | 67 | 47 | Price based | Price (%) | 93% | 88% | 104% | 96%
|  |  |  |  | Option pricing model | Equity volatility (%) | n.a. | 9% | n.a. | 23%
|  |  |  |  |  | Equity/Equity correlation | 0.7 | 0.8 | 0.7 | 0.9
|  |  |  |  |  | Equity/FX correlation | n.a. | -0.2 | n.a. | 0.6
|  |  |  |  |  | Dividend yield (%) | n.a. | 0% | n.a. | 4%
|  |  |  |  | Present value techniques | Credit spreads (bps) | n.a. | 100 | n.a. | 101
|  |  |  |  |  | Prepayment rate (%) | 99.59% | n.a. | 100.09% | n.a.
Derivatives |  |  |  |  |  |  |  |  |  |
– Rates | 413 | 283 | 389 | 301 | Option pricing model | Interest rate volatility (bps) | n.a. | 1 | n.a. | 3
|  |  |  |  | Present value techniques | Reset spread (%) | 2% | n.a. | 2% | n.a.
|  |  |  |  |  | Prepayment rate (%) | n.a. | 0% | n.a. | 0%
– FX | 6 | 2 | 8 | 3 | Option pricing model | Implied volatility (%) | 2% | 3% | 15% | 18%
– Credit | 39 | 216 | 241 | 343 | Present value techniques | Credit spread (bps) | 0 | 3 | 91 | 149
|  |  |  |  | Price based | Price (%) | 0% | 0% | 100% | 100%
– Equity | 10 | 20 | 47 | 17 | Option pricing model | Equity volatility (%) | 7% | 12% | 81% | 75%
|  |  |  |  |  | Equity/Equity correlation | 0.0 | 0.2 | 1.0 | 1.0
|  |  |  |  |  | Equity/FX correlation | -0.6 | -0.5 | 0.6 | 1.0
|  |  |  |  |  | Dividend yield (%) | 0% | 0% | 33% | 14%
|  |  |  |  | Price based | Price (%) | n.a. | 0% | n.a. | 21%
– Other | 6 | 14 | 9 | 7 | Option pricing model | Commodity volatility (%) | 13.1% | 11% | 61% | 94%
|  |  |  |  |  | Com/FX correlation | -0.40 | n.a. | -0.25 | n.a.
|  |  |  |  | Price based | Price (commodity) | 68 | n.a. | 68 | n.a.
At fair value through other comprehensive income |  |  |  |  |  |  |  |  |  |
– Loans and advances |  | 676 |  |  | Price based | Price (%) | n.a. | 85% | n.a. | 96%
– Equity | 270 | 263 |  |  | Present value techniques | Credit spread (bps) | 5.67 | 5.2 | 5.76 | 5.2
|  |  |  |  |  | Interest rate (%) | 1.5% | 4% | 3.5% | 4%
|  |  |  |  |  | Payout ratio (%) | 70% | n.a. | 90% | n.a.
|  |  |  |  | Price based | Price (%) | 122% | 122% | 122% | 122%
Total | 11,005 | 9,118 | 770 | 729 |  |  |  |  |  |

1 The abbreviation n.a. stands for not applicable or not available.
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> Additional notes to the Consolidated financial statements
Price
For securities where market prices are not available, fair value is measured by comparison with observable
pricing data from similar instruments. Prices of 0% are distressed to the point that no recovery is expected,
while prices significantly in excess of 100% or par are expected to pay a yield above current market rates.
Credit spreads
Credit spread is the premium above a benchmark interest rate required by the market participant to accept a
lower credit quality. Higher credit spreads indicate lower credit quality and a lower value of an asset.
Volatility
Volatility is a measure for variation of the price of a financial instrument or other valuation input over time.
Volatility is one of the key inputs in option pricing models. Typically, the higher the volatility, the higher value
of the option. Volatility varies by the underlying reference (equity, commodity, foreign currency and interest
rates), by strike, and maturity of the option. The minimum level of volatility is 0% and there is no theoretical
maximum.
Correlation
Correlation is a measure of dependence between two underlying references which is relevant for valuing
derivatives and other instruments having more than one underlying reference. High positive correlation
(close to 1) indicates a strong positive (statistical) relationship, where underliers move, everything else equal,
into the same direction. The same holds for a high negative correlation.
Interest rate
An interest rate is the amount of interest due per period, as a proportion of the amount lent, deposited, or
borrowed.
Reset spread
Reset spreads are key inputs to mortgage-linked prepayment swaps valuation. Reset spread is the future
spread at which mortgages will re-price at interest rate reset dates.
Dividend yield
Dividend yield is an important input for equity option pricing models showing how much dividends a
company is expected to pay out each year relative to its share price. Dividend yields are generally expressed
as an annualised percentage of share price.
Payout ratio
Dividend payout ratio is an input that shows the percentage of dividends a company is expected to pay out
each year relative to its net income.
Prepayment rate
Prepayment rate is a key input to mortgage and loan valuation. Prepayment rate is the estimated rate at
which mortgage borrowers will repay their mortgages early, e.g. 5% per year. Prepayment rate and reset
spread are key inputs to mortgage-linked prepayment swaps valuation.
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> Additional notes to the Consolidated financial statements
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 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Opening balance as at 1 January | 848 | 873 | 286 | 421 | 3,499 | 1,849 | 3,547 | 3,492 | 938 | 891 | 9,118 | 7,526
Realised gain/loss recognised in the statement of profit or loss during the period 1 | -175 | 235 | -38 | -142 | 294 | -33 | -54 | -383 |  | 0 | 28 | -322
Revaluation recognised in other comprehensive income during the period 2 |  |  |  |  |  |  |  |  | -3 | -6 | -3 | -6
Purchase of assets | 486 | 1,246 | 198 | 76 | 4,424 | 2,208 | 1,600 | 873 | 154 | 331 | 6,862 | 4,735
Sale of assets | -111 | -889 | -257 | -55 | -1,605 | -1,109 | -10 | -138 | -418 | -243 | -2,402 | -2,433
Maturity/settlement | -140 | -1,005 | -7 | -15 | -294 | -576 | -988 | -292 | -20 | -22 | -1,449 | -1,910
Reclassifications | 0 | 0 | 0 | 0 | 0 | 723 | 0 | 0 | 0 | 5 | 0 | 728
Transfers into Level 3 | 370 | 879 | 0 | 0 | 615 | 981 | 30 | 1 | 0 | 0 | 1,014 | 1,860
Transfers out of Level 3 | -454 | -459 | -114 | 0 | -1,214 | -534 | -3 | 0 | -384 | 0 | -2,169 | -994
Exchange rate differences | 0 | -31 | 0 | 0 | 5 | -9 | -2 | -9 | 9 | -10 | 12 | -59
Changes in the composition of the group and other changes | 0 | 0 | 0 | 0 | -1 | 0 | 0 | 2 | -5 | -8 | -6 | -6
Closing balance | 824 | 848 | 68 | 286 | 5,721 | 3,499 | 4,121 | 3,547 | 270 | 938 | 11,005 | 9,118

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 -41 million (2023: EUR 316 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 comprehen sive income’.
In 2024 and 2023, transfers into and out of Level 3 of financial assets mandatorily at fair value mainly relate
to (long- term) reverse repurchase transactions for which the valuation being significantly impacted by
unobservable inputs and no longer significantly impacted by unobservable inputs, respectively.
In 2024, the transfer into Level 3 trading assets consisted of cross currency swap trades, which were
transferred to Level 3 as a result of the valuation being significantly impacted by unobservable inputs.
Conversely, the transfer out of Level 3 in trading assets and non-trading derivatives primarily involved
derivative instruments, as their valuations were no longer significantly impacted by unobservable inputs.
In 2024, the transfer out of Level 3 of financial assets at FVOCI relates to HtC&S portfolio transferred to Level
2 resulting from change in methodology.
In 2023, the transfer into Level 3 trading assets is mainly driven by debt securities that are part of a structure
transferred into level 3 due to market illiquidity which decreased observability for an input.
ING Bank Annual Report 2024 175

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> Additional notes to the Consolidated financial statements

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 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Opening balance as at 1 January | 382 | 229 | 301 | 449 | 47 | 54 | 729 | 732
Realised gain/loss recognised in the statement of profit or loss during the period 1 | -104 | 224 | -98 | -151 | -5 | -2 | -206 | 72
Additions | 55 | 53 | 190 | 72 | 29 | 18 | 274 | 142
Redemptions | -12 | -102 | -209 | -53 | 0 | -2 | -222 | -156
Maturity/settlement | -15 | -13 | -7 | -16 | -4 | -1 | -26 | -30
Transfers into Level 3 | 364 | 40 | 0 | 0 | 34 | 32 | 399 | 72
Transfers out of Level 3 | -33 | -49 | -111 | 0 | -34 | -54 | -179 | -102
Exchange rate differences | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 0
Closing balance | 637 | 382 | 67 | 301 | 67 | 47 | 770 | 729

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 -206 million (2023: EUR 72 million) of unrealised gains and losses recognised in the statement of profit or loss.
In 2024, the transfers into Level 3 mainly consisted of trading liabilities attributed to cross currency swap
trades transferred into Level 3 as a result of the valuation being significantly impacted by unobservable
inputs. The transfers out of Level 3 for non-trading derivatives are driven by interest rate swap trades, which
were reclassified out of Level 3 as their valuations were no longer influenced by significantly unobservable
inputs.
In 2023, transfers of financial liabilities 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 relate to Level 3 assets and liabilities are included in the line item ‘Valuation results and net trading
income’ in the statement of profit or loss.
h) Level 3: Sensitivity analysis of unobservable inputs
Where the fair value of a financial instrument is determined using inputs which are unobservable and which
have a more than insignificant impact on the fair value of the instrument, the actual value of those inputs at
the balance date may be drawn from a range of reasonably possible alternatives. In line with market
practice, the upper and lower bounds of the range of alternative input values reflect a level of valuation
certainty. The actual levels chosen for the unobservable inputs in preparing the financial statements are
consistent with the valuation methodology used for fair valued financial instruments.
In practice, valuation uncertainty is measured and managed per exposure to individual valuation inputs (i.e.
risk factors) at portfolio-level across different product categories. Where the disclosure looks at individual
Level 3 inputs, the actual valuation adjustments may also reflect the benefits of portfolio offsets.
This disclosure does not attempt to indicate or predict future fair value movement. The numbers in isolation
give limited information as in most cases these Level 3 assets and liabilities should be seen in combination
with other instruments (for example as a hedge) that are classified as Level 2.
The valuation uncertainty in the table below is broken down by related risk class rather than by product. The
possible impact of a change of unobservable inputs in the fair value of financial instruments where
unobservable inputs are significant to the valuation is as follows:

Sensitivity analysis of Level 3 instruments
| Positive fair value movements from using reasonable possible alternatives | Negative fair value movements from using reasonable possible alternatives
in EUR million | 2024 | 2023 | 2024 | 2023
Equity (equity derivatives, structured notes) | 21 | 18 | -20 | -9
Interest rates (Rates derivatives, FX derivatives) | 5 | 3 | 0 | 0
Credit (Debt securities, Loans, structured notes, credit derivatives) | 2 | 45 | -27 | -54
Loans and advances | 0 | 3 | 0 | -17
| 28 | 69 | -47 | -80

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.
ING Bank Annual Report 2024 176

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> Additional notes to the Consolidated financial statements

Methods applied in determining fair values of financial assets and liabilities (carried at amortised cost)
| Carrying Amount | Carrying amount presented as fair value 1 | Level 1 | Level 2 | Level 3 | Total fair value
in EUR million | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Financial Assets |  |  |  |  |  |  |  |  |  |  |  |
Loans and advances to banks | 21,769 | 16,708 | 3,194 | 2,721 |  |  | 15,614 | 11,430 | 2,957 | 2,511 | 21,766 | 16,662
Loans and advances to customers | 680,299 | 642,453 | 18,296 | 15,686 |  |  | 18,626 | 14,602 | 630,493 | 593,098 | 667,415 | 623,386
Securities at amortised cost | 50,273 | 48,313 |  |  | 42,871 | 40,041 | 2,908 | 4,277 | 2,523 | 1,693 | 48,303 | 46,010
| 752,341 | 707,474 | 21,490 | 18,407 | 42,871 | 40,041 | 37,149 | 30,308 | 635,973 | 597,302 | 737,483 | 686,058
Financial liabilities |  |  |  |  |  |  |  |  |  |  |  |
Deposits from banks | 16,722 | 23,257 | 4,347 | 3,764 |  |  | 8,208 | 15,066 | 3,943 | 3,968 | 16,498 | 22,799
Customer deposits 2 | 699,725 | 662,004 | 582,511 | 556,766 |  |  | 69,790 | 63,348 | 46,984 | 41,063 | 699,285 | 661,177
Debt securities in issue 3 | 94,459 | 84,423 |  |  | 33,019 | 25,898 | 59,141 | 38,301 | 2,000 | 20,225 | 94,161 | 84,424
Senior non-preferred debt 2 | 49,393 | 40,213 |  |  |  |  | 50,230 | 40,607 |  | 186 | 50,230 | 40,793
Subordinated loans | 17,879 | 15,404 |  |  |  |  | 18,357 | 15,361 |  |  | 18,357 | 15,361
| 878,178 | 825,300 | 586,857 | 560,530 | 33,019 | 25,898 | 205,726 | 172,684 | 52,927 | 65,443 | 878,530 | 824,555

1 In accordance with IFRS and for the purpose of this disclosure, the carrying amount of financial instruments with an immediate on demand feature is presented as fair value
2 The presentation on senior non-preferred debt change has led to adjustments in the comparative figures for customer deposits and senior non-preferred debt.
3 In 2023, debt securities included a commercial paper issued classified as Level 3. Following a change in valuation technique in 2024, it transferred to Level 2.
The aggregation of the fair values presented above does not represent, and should not be construed as
representing, the underlying value of I NG. These fair values were calculated for disclosure purposes only. The
carrying amount of financial instruments presented in the above table includes, when applicable, the fair
value hedge adjustment, this explains why (for these cases) 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.
Securities at amortised cost
Where available, fair values for debt securities are generally based on quoted market prices. Quoted market
prices are obtained from an exchange market, dealer, broker, industry group, pricing service, or regulatory
service. The quoted prices from non-exchange sources are reviewed on their tradability of market prices. If
quoted prices in an active market are not available, fair value is based on an analysis of available market
inputs, which include consensus prices obtained from one or more pricing services. Furthermore, fair values
are determined by valuation techniques discounting expected future cash flows using market interest rate
curves, referenced credit spreads, maturity of the investment, and estimated prepayment rates where
applicable.
Deposits from banks
For short-term payables to banks, carrying amounts represent a reasonable estimate of the fair value. The
fair value of long-term payables to banks is estimated by discounting expected future cash flows using a
discount rate based on available market interest rates and appropriate spreads that reflect ING’s own credit
risk.
ING Bank Annual Report 2024 177

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> Additional notes to the Consolidated financial statements
Customer deposits
In the current interest rate environment, there is significant embedded value in our on-demand deposits.
However, for the purpose of this disclosure and in accordance with IFRS, the carrying amounts of deposits
with an immediate on demand feature are presented as fair value.
The fair value of deposits with fixed contractual terms has been estimated based on discounting future cash
flows using the interest rates currently applicable to deposits of similar maturities.
Debt securities in issue
The fair value of debt securities in issue is generally based on quoted market prices, or if not available, on
estimated prices by discounting expected future cash flows using a current market interest rate and credit
spreads applicable to the yield, credit quality and maturity.
Subordinated loans
The fair value of publicly traded subordinated loans are based on quoted market prices when available.
Where no quoted market prices are available, fair value of the subordinated loans is estimated using
discounted cash flows based on interest rates and credit spreads that apply to similar instruments.
ING Bank Annual Report 2024 178

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> Additional notes to the Consolidated financial statements
33 Derivatives and hedge accounting
Use of derivatives
ING uses derivatives for economic hedging purposes to manage its asset and liability portfolios and
structural risk positions. The primary objective of ING’s hedging activities is to manage the risks which arise
from structural imbalances in the duration and other profiles of its assets and liabilities. The objective of
economic hedging is to enter into positions with an opposite risk profile to an identified risk exposure to
reduce that exposure. The main risks which are being hedged are interest rate risk and foreign currency
exchange rate risk. These risks are primarily hedged with interest rate swaps, cross currency swaps and
foreign exchange forwards/swaps.
ING uses credit derivatives to manage its economic exposure to credit risk, including total return swaps and
credit default swaps, to sell or buy protection for credit risk exposures in the loan, investment, and trading
portfolios. Hedge accounting is not applied in relation to these credit derivatives.
Hedge accounting
Derivatives that qualify for hedge accounting under IFRS are classified and accounted for in accordance with
the nature of the instrument hedged and the type of IFRS hedge accounting model that is applicable. The
three models applicable under IFRS are: fair value hedge accounting, cash flow hedge accounting, and hedge
accounting of a net investment in a foreign operation. How and to what extent these models are applied are
described under the relevant headings below. The company’s detailed accounting policies for these three
hedge models are set out in paragraph 1.5 ‘Financial instruments’ of Note 1 ‘Basis of preparation and
material accounting policy information’.
The benchmark rate reform
Reference is made to note 'Risk management / The impact of the benchmark rate reform' for information on
how ING is managing the transition to alternative benchmark rates and ING’s progress in completing the
transition with respect to derivatives in hedge accounting relationships.
Fair value hedge accounting
ING’s fair value hedges principally consist of interest rate swaps that are used to protect against changes in
the fair value of fixed-rate instruments due to movements in market interest rates. ING’s approach to
managing market risk, including interest rate risk, is discussed in ‘Risk management –Market risk’. ING’s
exposure to interest rate risk is disclosed in paragraph ‘Interest rate risk in banking book’.
ING 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, because
the fair value of a fixed-rate instrument varies directly in response to changes in its benchmark interest rate.
By using derivative financial instruments to hedge exposures to changes in interest rates, ING also exposes
itself to credit risk of the derivative counterparty, which is not offset by the hedged item. ING minimises
counterparty credit risk in derivative instruments by clearing most of the derivatives through Central Clearing
Counterparties. In addition, ING only enters into transactions with high-quality counterparties and requires
posting collateral.
ING 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 values 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.
ING Bank Annual Report 2024 179

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> Additional notes to the Consolidated financial statements
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 2024 | Liabilities 2024 | Assets 2023 | Liabilities 2023
As at 31 December |  |  |  |
Hedging instrument on interest rate risk |  |  |  |
– Interest rate swaps | 26,963 | 24,107 | 32,612 | 27,350
– Other interest derivatives | 207 | 23 | 284 | 34
Hedging instrument on FX rate risk |  |  |  |
– Cross currency swaps | 12 | 3 |  |

The derivatives used for fair value hedge accounting are included in the statement of financial position line-
item ‘Financial assets at fair value through profit or loss – Non-trading derivatives’ for EUR 617 million (2023:
EUR 716 million) respectively ‘Financial liabilities at fair value through profit or loss – Non-trading derivatives’
EUR 79 million (2023: EUR 113 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 1.69% (2023: 1.32%) for EUR and 4.22% (2023: 3.93%) 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 2024 | Less than 1 month | 1 to 3 months | 3 to 12 months | 1 to 2 years | 2 to 3 years | 3 to 4 years | 4 to 5 years | >5 years | Total
Hedging instrument on interest rate risk |  |  |  |  |  |  |  |  |
– Interest rate swaps | 43 | 1,224 | 4,308 | 15,305 | 2,179 | 4,580 | 3,259 | -51,039 | -20,140
– Other interest derivatives | -4 | 29 | 182 | 248 | 91 | -193 | 121 | 383 | 858
Hedging instrument on FX rate risk |  |  |  |  |  |  |  |  |
– Cross currency swaps | -142 | -60 | -98 |  |  |  |  |  | -299
As at 31 December 2023 |  |  |  |  |  |  |  |  |
Hedging instrument on interest rate risk |  |  |  |  |  |  |  |  |
- Interest rate swaps | -670 | 253 | 8,381 | 4,156 | 3,193 | -800 | 7,559 | -58,679 | -36,609
– Other interest derivatives |  | 25 | 190 | 116 | 302 | 250 | -144 | 974 | 1,712

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.
ING Bank Annual Report 2024 180

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> Additional notes to the Consolidated financial statements

Hedged items included in a fair value hedging relationship
| Carrying amount of the hedged items | Accumulated amount of fair value hedge adjustment on the hedged item included in the carrying amount of the hedged item | Change in fair value of the hedged item for measuring ineffectiveness for the period | Change in fair value hedging instruments for the period | Hedge ineffectiveness recognised in the statement of profit or loss gain (+) / loss (-)
in EUR million | Assets | Liabilities | Assets | Liabilities |  |  |
As at 31 December 2024 |  |  |  |  |  |  |
Interest rate risk and FX rate risk |  |  |  |  |  |  |
– Debt securities at fair value through other comprehensive income | 35,119 |  | n/a |  | 269 |  |
– Loans at FVOCI |  |  | n/a |  | 1 |  |
– Loans and advances to customers | 73,364 |  | -5,177 |  | 1,771 |  |
– Debt instruments at amortised cost | 13,802 |  | -179 |  | 49 |  |
– Debt securities in issue |  | 38,246 |  | -915 | -594 |  |
– Senior non-preferred debt |  | 45,423 |  | -1,320 | -544 |  |
– Subordinated loans |  | 17,143 |  | -665 | -188 |  |
– Customer deposits and other funds on deposit |  | 29 |  | -1 | -14 |  |
– Discontinued hedges |  |  | 1,851 | -5 |  |  |
Total | 122,285 | 100,842 | -3,505 | -2,906 | 750 | -766 | -17
As at 31 December 2023 |  |  |  |  |  |  |
Interest rate risk and FX rate risk |  |  |  |  |  |  |
– Debt securities at fair value through other comprehensive income | 31,224 |  | n/a |  | 1,224 |  |
– Loans at FVOCI | 5 |  | n/a |  | 1 |  |
– Loans and advances to customers | 78,787 |  | -7,104 |  | 4,705 |  |
– Debt instruments at amortised cost | 8,272 |  | -205 |  | 234 |  |
– Debt securities in issue |  | 32,432 |  | -1,511 | -1,279 |  |
– Senior non-preferred debt 1 |  | 37,850 |  | -1,872 | -1,402 |  |
– Subordinated loans |  | 14,646 |  | -834 | -473 |  |
– Customer deposits and other funds on deposit 1 |  | 1,527 |  | -17 | -49 |  |
– Discontinued hedges |  |  | 2,285 | 3 |  |  |
Total | 118,287 | 86,455 | -5,024 | -4,230 | 2,962 | -3,028 | -66

1 ING changed the presentation for the senior non-preferred debt and the comparative figure for 2023 has been adjusted.
During 2024, the interest rate movements significantly affected the fair value changes of both the
derivatives and the hedged items designated in fair value hedges. However, no material hedging relationship
was discontinued as a result of the interest rate movements in 2024. Refer to Note 23 'Valuation results and
net trading income'.
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> Additional notes to the Consolidated financial statements
In addition, the net decrease in hedged items is mainly due to higher volumes in debt securities in issue
designated in hedge accounting. Discontinued hedges 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 a micro and macro level. ING’s cash flow hedges mainly consist
of interest rate swaps and cross-currency swaps that are used to protect against the exposure to variability
in future cash flows on non-trading assets and liabilities that bear interest at variable rates or are expected
to be refunded or reinvested in the future. The amounts and timing of future cash flows, representing both
principal and interest flows, are projected for each portfolio of financial assets and liabilities, based on
contractual terms and other variables including estimates of prepayments. These projected cash flows form
the basis for identifying the notional amount subject to interest rate risk or foreign currency exchange rate
risk that is designated under cash flow hedge accounting.
ING’s approach to manage market risk, including interest rate risk and foreign currency exchange rate risk, is
discussed in ‘Risk management – Market risk’. ING determines the amount of the exposures to which it
applies hedge accounting by assessing the potential impact of changes in interest rates and foreign
currency exchange rates on the future cash flows from its floating-rate assets and liabilities. This assessment
is performed using analytical techniques.
As noted above for fair value hedges, by using derivative financial instruments to hedge exposures to
changes in interest rates and foreign currency exchange rates, ING exposes itself to credit risk of the
derivative counterparty, which is not offset by the hedged items. This exposure is managed similarly to that
for fair value hedges.
Gains and losses on the effective portions of derivatives designated under cash flow hedge accounting are
recognised in Other Comprehensive Income. Interest cash flows on these derivatives are recognised in the
statement of profit or loss in ‘Net interest income’ consistent with the manner in which the forecasted cash
flows affect the net result. The gains and losses on ineffective portions of such derivatives are recognised
immediately in the statement of profit or loss in ‘Valuation results and net trading income’.
ING determines an economic relationship between the cash flows of the hedged item and the hedging
instrument based on an evaluation of the quantitative characteristics of these items and the hedged risk
that is supported by quantitative analysis. ING considers whether the critical terms of the hedged item and
hedging instrument closely align when assessing the presence of an economic relationship. ING evaluates
whether the cash flows of the hedged item and the hedging instrument respond similarly to the hedged risk,
such as the benchmark interest rate of foreign currency. In addition, a regression analysis is performed to
assess whether the hedging instrument is expected to be and has been highly effective in offsetting changes
in the fair value of the hedged item.
ING uses the following derivative financial instruments in a cash flow hedge accounting relationship:

Gross carrying value of derivatives used for cash flow hedge accounting
| Assets | Liabilities | Assets | Liabilities
in EUR million | 2024 | 2024 | 2023 | 2023
As at 31 December |  |  |  |
Hedging instrument on interest rate risk |  |  |  |
– Interest rate swaps | 10,635 | 12,814 | 11,839 | 14,051
Hedging instrument on FX rate risk |  |  |  |
– Cross currency swaps | 472 | 339 | 324 | 39
Hedging instrument on combined interest and FX rate risk |  |  |  |
– Cross currency interest rate swaps |  | 10 | 57 |

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 158 million (2023: EUR
440 million) respectively ‘Financial liabilities at fair value through profit or loss – Non-trading derivatives’ EUR
573 million (2023: EUR 458 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.
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> Additional notes to the Consolidated financial statements
For the main currencies the average fixed rate for interest rate swaps used in cash flow hedge accounting
are 1.79% (2023: 1.26%) for EUR, 4.37% (2023: 4.09%) for PLN, 3.99% (2023: 4.33%) for USD and 3.29%
(2023: 2.80%) for AUD. The average currency exchange rates for cross currency swaps used in cash flow
hedge accounting is for EUR/USD 1.03 (2023: 0.98) and for EUR/AUD 1.52 (2023: 1.58).
The following table shows the net notional amount of derivatives designated in cash flow hedging split into
the maturity of the instruments. The net notional amounts presented in the table are a combination of
payer (+) and receiver (-) swaps.

Maturity derivatives designated in cash flow hedging
in EUR million |  |  |  |  |  |  |  |  |
As at 31 December 2024 | Less than 1 month | 1 to 3 months | 3 to 12 months | 1 to 2 years | 2 to 3 years | 3 to 4 years | 4 to 5 years | >5 years | Total
Hedging instrument on interest rate risk |  |  |  |  |  |  |  |  |
– Interest rate swaps | -1,805 | -768 | -10,590 | -13,389 | -10,551 | -6,040 | -4,522 | -3,222 | -50,886
Hedging instrument on FX rate risk |  |  |  |  |  |  |  |  |
– Cross currency swaps |  | -241 | -972 | 122 | -1,029 | -262 | -238 | -999 | -3,619
Hedging instrument on combined interest and FX rate risk |  |  |  |  |  |  |  |  |
– Cross currency interest rate swaps |  |  | -25 |  | -1,283 | -1,578 |  |  | -2,887
As at 31 December 2023 |  |  |  |  |  |  |  |  |
Hedging instrument on interest rate risk |  |  |  |  |  |  |  |  |
– Interest rate swaps | -214 | 184 | -8,557 | -18,551 | -6,636 | -7,246 | -4,896 | -3,384 | -49,300
Hedging instrument on FX rate risk |  |  |  |  |  |  |  |  |
– Cross currency swaps |  | 249 | 1,029 | -932 | 503 | -683 | 167 | -693 | -362
Hedging instrument on combined interest and FX rate risk |  |  |  |  |  |  |  |  |
– Cross currency interest rate swaps |  |  |  | -24 | -1,232 | -1,479 |  |  | -2,736

The following table shows the cash flow hedge accounting impact on profit or loss and comprehensive income:
ING Bank Annual Report 2024 183

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> Additional notes to the Consolidated financial statements

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 ineffectivenes s 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 2 | Change in value of hedging instrument recognised in OCI for the period | Hedge ineffectivenes s recognised in the statement of profit or loss, gain (+) / loss (-)
As at 31 December 2024 |  |  |  |  |
Interest rate risk on: |  |  |  |  |
– Floating rate lending | -668 | -2,850 | 496 |  |
– Floating rate borrowing | 114 | 125 | -425 |  |
– Other | 1 | 1 |  |  |
– Discontinued hedges |  | 89 | -51 |  |
Total interest rate risk | -553 | -2,635 | 20 | 526 | 39
FX rate risk on: |  |  |  |  |
– Floating rate lending | -79 | -55 | -121 |  |
– Floating rate borrowing | 12 | 5 | -37 |  |
– Other |  |  |  |  |
– Discontinued hedges |  |  | -4 |  |
Total FX risk | -67 | -51 | -162 | 220 | -3
Combined interest and FX rate risk on: |  |  |  |  |
– Floating rate lending | 70 | 72 | -68 |  |
– Floating rate borrowing |  |  |  |  |
– Other |  |  |  |  |
– Discontinued hedges |  |  |  |  |
Total combined interest and FX risk | 70 | 72 | -68 | -3 | -2
Total cash flow hedge | -550 | -2,614 | -209 | 743 | 35

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 ineffectivenes s 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 2 | Change in value of hedging instrument recognised in OCI for the period | Hedge ineffectivenes s recognised in the statement of profit or loss, gain (+) / loss (-)
As at 31 December 2023 |  |  |  |  |
Interest rate risk on: |  |  |  |  |
– Floating rate lending | -2,694 | -3,545 | 590 |  |
– Floating rate borrowing | 933 | 151 | -497 |  |
– Other |  |  |  |  |
– Discontinued hedges |  | 194 | -150 |  |
Total interest rate risk | -1,760 | -3,200 | -57 | 1,654 | 58
FX rate risk on: |  |  |  |  |
– Floating rate lending | 27 | -42 | -185 |  |
– Floating rate borrowing | -25 | 1 | -33 |  |
– Other |  |  |  |  |
– Discontinued hedges |  | 7 | -5 |  |
Total FX risk | 2 | -35 | -223 | 200 | -12
Combined interest and FX rate risk on: |  |  |  |  |
– Floating rate lending | -20 | 78 | -46 |  |
– Floating rate borrowing |  |  | 1 |  |
– Other |  |  |  |  |
– Discontinued hedges |  |  | -1 |  |
Total combined interest and FX risk | -20 | 78 | -46 | 68 | 2
Total cash flow hedge | -1,778 | -3,157 | -325 | 1,922 | 48

1 The carrying amount is the gross amount, excluding tax adjustments.
2 The amounts are reclassified to Net interest income - interest income and/or expense on non-trading derivatives (hedge accounting).
ING Bank Annual Report 2024 184

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> Additional notes to the Consolidated financial statements
In 2024 and 2023 there are no amounts reclassified from CFH reserve to profit or loss for cash flows that are
no longer expected to occur.
The increase in the carrying amount of the cash flow hedge reserve is driven by the interest rate
movements. No material hedging relationship was discontinued as a result of the interest rate movements
in 2024.
The main sources of ineffectiveness for cash flow hedges are:
• differences in timing of cash flows of the hedged item(s) and hedging instrument(s);
• mismatches in reset frequency between hedged item and hedging instrument.
The following table shows the movement of the cash flow hedge reserve:

Movement cash flow hedge reserve
in EUR million | 2024 | 2023
Opening balance | -2,058 | -3,055
Value changes recognised in OCI | 743 | 1,922
Amounts recycled to profit or loss | -209 | -325
Income tax | -140 | -381
Exchange rate and other changes | -14 | -103
Adjustment for non controlling interest | -14 | -116
Movement for the year | 365 | 997
Ending balance | -1,693 | -2,058

Hedges of net investments in foreign operations
A foreign currency exposure arises from a net investment in subsidiaries that have a different functional
currency from the presentation currency of ING. The risk arises from the fluctuation in spot exchange rates
between the functional currency of the subsidiaries and ING’s presentation currency, which causes the
amount of the net investment to vary in the consolidated financial statements of ING. This risk may have a
significant impact on ING’s financial statements. ING’s policy is to hedge these exposures only when these
are expected to have a significant impact on the regulatory capital ratios of ING and its subsidiaries.
ING’s net investment hedges principally consist of derivatives (including currency forwards and swaps) and
non-derivative financial instruments such as foreign currency denominated funding. When the hedging
instrument is foreign currency-denominated debt, ING assesses effectiveness by comparing past changes in
the carrying amount of the debt that are attributable to a change in the spot rate with past changes in the
investment in the foreign operation due to movement in the spot rate (the offset method).
Gains and losses on the effective portions of derivatives designated under net investment hedge accounting
are recognised in Other Comprehensive Income. The balance in equity is recognised in the statement of
profit or loss when the related foreign subsidiary is disposed. 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 | 2024 | 2024 | 2023 | 2023
As at 31 December |  |  |  |
– FX forwards and Cross currency swaps | 82 | 117 | 100 | 92

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 82 million (2023:
EUR 100 million) respectively ‘Financial liabilities at fair value through profit or loss – Non trading derivatives’
EUR 117 million (2023: EUR 92 million).
For ING’s main currencies the average exchange rates used in net investment hedge accounting for 2024 are EUR/
USD 1.08 (2023: 1.08), EUR/PLN 4.31 (2023: 4.54), EUR/AUD 1.64 (2023: 1.63) and EUR/THB 38.00 (2023: 37.65).
The following table shows the notional amount of derivatives designated in net investment hedging split into
the maturity of the instruments:
ING Bank Annual Report 2024 185

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> Additional notes to the Consolidated financial statements

Maturity derivatives designated in net investment hedging
in EUR million |  |  |  |  |  |  |  |  |
As at 31 December 2024 | Less than 1 month | 1 to 3 months | 3 to 12 months | 1 to 2 years | 2 to 3 years | 3 to 4 years | 4 to 5 years | >5 years | Total
– FX forwards and cross currency swaps | -8,681 | -4,158 | -76 |  |  |  |  |  | -12,916
As at 31 December 2023 |  |  |  |  |  |  |  |  |
– FX forwards and Cross currency swaps | -6,009 | -4,576 | -87 |  |  |  |  |  | -10,672

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 2024 | Change in value of hedged item used for calculating hedge ineffectiveness for the period | Carrying amount net investment hedge reserve at the end of the reporting 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 | 295 | -95 |  | -295 | 0
Discontinued hedges |  | 302 |  |  |
As at 31 December 2023 |  |  |  |  |
Investment in foreign operations | -183 | 123 |  | 183 |
Discontinued hedges |  | 263 |  |  |

1 The carrying amount is the gross amount, excluding tax adjustments.
ING Bank Annual Report 2024 186

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> Additional notes to the Consolidated financial statements
34 Assets by contractual maturity
Amounts presented by contractual maturity are the amounts as presented in the statement of financial position and are discounted cash flows. Reference is made to ‘Risk Management – Funding and liquidity risk’.

Assets by contractual maturity
in EUR million |  |  |  |  |  |  |
2024 | 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 | 70,353 |  |  |  |  |  | 70,353
Loans and advances to banks | 16,825 | 1,254 | 1,322 | 1,759 | 610 |  | 21,769
Financial assets at fair value through profit or loss |  |  |  |  |  |  |
– Trading assets | 22,154 | 8,044 | 14,501 | 16,006 | 12,202 |  | 72,906
– Non-trading derivatives | 602 | 368 | 465 | 356 | 672 |  | 2,463
– Mandatorily at fair value through profit or loss | 30,002 | 11,263 | 7,222 | 5,931 | 1,835 | 228 | 56,481
– Designated as at fair value through profit or loss | 145 | 198 | 1,070 | 2,110 | 2,217 |  | 5,740
Financial assets at fair value through other comprehensive income |  |  |  |  |  |  |
– Equity securities |  |  |  |  |  | 2,562 | 2,562
– Debt securities | 365 | 456 | 2,027 | 18,064 | 21,307 |  | 42,219
– Loans and advances | 2 | 4 | 94 | 871 | 637 |  | 1,608
Securities at amortised cost | 2,075 | 2,646 | 5,729 | 22,838 | 16,985 |  | 50,273
Loans and advances to customers | 53,738 | 26,456 | 61,544 | 216,035 | 322,526 |  | 680,299
Other assets 2 | 5,600 | 590 | 1,048 | 698 | 1,107 | 5,006 | 14,050
Total assets | 201,860 | 51,279 | 95,021 | 284,668 | 380,098 | 7,796 | 1,020,724
2023 |  |  |  |  |  |  |
Cash and balances with central banks | 90,214 |  |  |  |  |  | 90,214
Loans and advances to banks | 11,985 | 1,021 | 1,744 | 1,527 | 431 |  | 16,708
Financial assets at fair value through profit or loss |  |  |  |  |  |  |
– Trading assets | 17,000 | 7,363 | 11,448 | 13,216 | 11,213 |  | 60,240
– Non-trading derivatives | 138 | 80 | 297 | 613 | 900 |  | 2,028
– Mandatorily at fair value through profit or loss | 32,835 | 12,040 | 5,303 | 3,587 | 1,040 | 179 | 54,983
– Designated as at fair value through profit or loss | 550 | 200 | 792 | 2,092 | 2,141 |  | 5,775
Financial assets at fair value through other comprehensive income |  |  |  |  |  |  |
– Equity securities |  |  |  |  |  | 1,885 | 1,885
– Debt securities | 579 | 232 | 2,021 | 13,686 | 21,763 |  | 38,281
– Loans and advances |  | 3 | 41 | 619 | 287 |  | 951
Securities at amortised cost | 2,220 | 1,142 | 6,667 | 22,540 | 15,744 |  | 48,313
Loans and advances to customers | 49,683 | 21,298 | 57,516 | 206,438 | 307,517 |  | 642,453
Other assets 2 | 5,649 | 257 | 1,088 | 1,147 | 1,020 | 4,645 | 13,805
Total assets | 210,852 | 43,636 | 86,917 | 265,466 | 362,056 | 6,709 | 975,636

1 Includes assets on demand.
2 Includes assets such as current and deferred tax assets as presented in the consolidated statement of the financial position. Additionally, assets are included in that position where maturities are not applicable such as property and equipment and investments in associates and
joint ventures. Due to their nature, non-financial assets consist mainly of assets expected to be recovered after more than 12 mont hs.
ING Bank Annual Report 2024 187

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> Additional notes to the Consolidated financial statements
35 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.
ING Bank Annual Report 2024 188

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> Additional notes to the Consolidated financial statements

Liabilities and off-balance sheet commitments by maturity
in EUR million |  |  |  |  |  |  |  |
2024 | 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 | 9,104 | 1,367 | 2,085 | 1,637 | 2,484 |  | 46 | 16,722
Customer deposits | 610,590 | 23,479 | 50,034 | 11,141 | 2,081 |  | 2,399 | 699,725
Financial liabilities at fair value through profit or loss |  |  |  |  |  |  |  |
– Other trading liabilities | 5,790 | 230 | 313 | 1,325 | 1,465 |  | -34 | 9,089
– Trading derivatives | 2,631 | 2,367 | 3,730 | 7,641 | 5,499 |  | 4,298 | 26,166
– Non-trading derivatives | 419 | 57 | -36 | 711 | 149 |  | 801 | 2,101
– Designated at fair value through profit or loss | 32,644 | 5,842 | 1,798 | 5,095 | 4,365 | 34 | -239 | 49,539
Debt securities in issue | 1,949 | 17,635 | 33,037 | 26,600 | 15,704 |  | -466 | 94,459
Senior non preferred debt |  | 975 |  | 30,121 | 19,153 |  | -856 | 49,393
Subordinated loans |  |  |  |  | 9,962 | 8,415 | -498 | 17,879
Lease liabilities | 20 | 44 | 162 | 607 | 328 |  | -45 | 1,116
Financial liabilities | 663,148 | 51,995 | 91,125 | 84,879 | 61,190 | 8,448 | 5,405 | 966,190
Other liabilities 3 | 7,294 | 456 | 2,073 | 502 | 470 |  |  | 10,795
Total liabilities | 670,442 | 52,451 | 93,198 | 85,381 | 61,660 | 8,448 | 5,405 | 976,986
Coupon interest due on financial liabilities | 2,278 | 1,600 | 5,981 | 10,388 | 8,065 | 516 |  | 28,829
Contingent liabilities in respect of |  |  |  |  |  |  |  |
– Discounted bills |  |  |  |  |  |  |  |
– Guarantees | 26,355 |  |  | 3 | 550 |  |  | 26,908
– Irrevocable letters of credit | 16,388 |  |  |  |  |  |  | 16,388
Irrevocable facilities | 175,000 | 9 | 15 | 143 | 56 |  |  | 175,222
| 217,743 | 9 | 15 | 146 | 606 |  |  | 218,518

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.
ING Bank Annual Report 2024 189

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> Additional notes to the Consolidated financial statements

Liabilities and off-balance sheet commitments by maturity
in EUR million |  |  |  |  |  |  |  |
2023 | Less than 1 month 1 | 1–3 month | 3–12 months | 1–5 years | Over 5 years | Maturity not applicable | Adjustment 2 | Total
Deposits from banks | 9,294 | 7,800 | 2,074 | 1,898 | 2,002 |  | 189 | 23,257
Customer deposits 4 | 584,874 | 21,522 | 45,099 | 7,394 | 1,816 |  | 1,299 | 662,004
Financial liabilities at fair value through profit or loss |  |  |  |  |  |  |  |
– Other trading liabilities | 10,981 | 697 | 545 | 1,003 | 897 |  | -36 | 14,087
– Trading derivatives | 2,292 | 2,243 | 5,148 | 10,204 | 7,110 |  | -3,865 | 23,132
– Non-trading derivatives | 505 | 96 | 139 | 1,002 | 355 |  | -78 | 2,019
– Designated at fair value through profit or loss | 29,857 | 12,754 | 5,442 | 3,832 | 3,544 | 25 | -56 | 55,399
Debt securities in issue | 3,442 | 10,233 | 33,986 | 22,206 | 15,820 |  | -1,264 | 84,423
Senior non preferred debt 4 |  | 570 | 903 | 25,119 | 15,492 |  | -1,871 | 40,213
Subordinated loans |  |  |  |  | 9,104 | 6,988 | -689 | 15,404
Lease liabilities | 17 | 45 | 175 | 627 | 359 |  | -61 | 1,162
Financial liabilities | 641,263 | 55,959 | 93,511 | 73,285 | 56,500 | 7,013 | -6,432 | 921,099
Other liabilities 3 | 9,696 | 619 | 2,269 | 399 | 420 |  |  | 13,402
Total liabilities | 650,959 | 56,579 | 95,779 | 73,684 | 56,920 | 7,013 | -6,432 | 934,501
Coupon interest due on financial liabilities | 1,057 | 1,703 | 6,103 | 10,178 | 4,998 | 404 |  | 24,442
Contingent liabilities in respect of |  |  |  |  |  |  |  |
– Discounted bills | 2 |  |  |  |  |  |  | 2
– Guarantees | 27,340 |  |  | 4 | 550 |  |  | 27,894
– Irrevocable letters of credit | 14,925 |  |  |  |  |  |  | 14,925
– other |  |  |  |  |  |  |  |
Irrevocable facilities | 166,361 | 12 | 63 | 314 | 60 |  |  | 166,810
| 208,628 | 12 | 63 | 318 | 610 | 0 | 0 | 209,631

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.
4 The presentation on senior non-preferred debt change has led to adjustments in the comparative figures for customer deposits and senior non-preferred debt.
ING Bank Annual Report 2024 190

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> Additional notes to the Consolidated financial statements
36 Transfer of financial assets, assets pledged and received as collateral
Financial assets pledged as collateral
The financial assets pledged as collateral consist primarily of mortgages pledged to secure covered bonds
and securitisations, deposits from the Dutch Central Bank and other banks, as well as debt and equity
securities used in securities lending or sale and repurchase transactions. They serve to secure margin
accounts and are used for other purposes required by law. Pledges are generally conducted under terms
that are usual and customary for collateralised transactions including standard sale and repurchase
agreements, securities lending and borrowing and derivatives margining. The financial assets pledged are as
follows:

Financial assets pledged as collateral |  |
in EUR million | 2024 | 2023
Banks |  |
– Cash and balances with central banks | 397 | 322
– Loans and advances to banks | 2,211 | 3,305
Financial assets at fair value through profit or loss | 28,905 | 23,641
Financial assets at fair value through OCI | 3,037 | 1,896
Securities at amortised cost | 3,184 | 2,672
Loans and advances to customers | 67,706 | 73,860
Other assets | 503 | 357
| 105,944 | 106,052

In some jurisdictions ING Bank N.V. has an obligation to maintain a reserve with central banks. As at
31 December 2024 , the minimum mandatory reserve deposits with various central banks amount to EUR
11,648 million (2023: EUR 11,653 million).
Financial assets received as collateral
The financial assets received as collateral that can be sold or repledged in absence of default by the owner of
the collateral consists of securities obtained through reverse repurchase transactions and securities
borrowing transactions.
These transactions are generally conducted under standard market terms for most repurchase transactions
and the recipient of the collateral has an unrestricted right to sell or repledge it, provided that the collateral
(or equivalent collateral) is returned to the counterparty at term.

Financial assets received as collateral
in EUR million | 2024 | 2023
Total received collateral available for sale or repledge at fair value |  |
– equity securities | 22,815 | 33,234
– debt securities | 140,285 | 119,908
of which sold or repledged at fair value |  |
– equity securities | 12,024 | 20,526
– debt securities | 90,708 | 86,448

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

Transfer of financial assets not qualifying for derecognition
| Securities lending | Sale and repurchase
| Equity | Debt | Equity | Debt
in EUR million | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Transferred assets at carrying amount |  |  |  |  |  |  |  |
Financial assets at fair value through profit or loss | 4,141 | 3,894 | 3 |  | 7,273 | 7,357 | 16,929 | 11,780
Financial assets at fair value through other comprehensive income |  |  | 603 | 328 |  |  | 1,956 | 470
Loans and advances to customers |  |  |  |  |  |  |  | 2,396
Securities at amortised cost |  |  | 635 | 431 |  |  | 819 | 465
Associated liabilities at carrying amount 1 |  |  |  |  |  |  |  |
Financial liabilities at fair value through profit or loss | n/a | n/a | n/a | n/a | 7,005 | 11,010 | 11,901 | 9,467

1 The table includes the associated liabilities which are reported after offsetting, compared to the gross positions of the encumbered
assets.
The table above does not include assets transferred to consolidated securitisation entities as the related
assets remain recognised in the consolidated statement of financial position. Transferred financial assets
that are derecognised in their entirety are mentioned in Note 42 'Structured entities'.
ING Bank Annual Report 2024 191

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> Additional notes to the Consolidated financial statements
37 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 offset in the statement of financial position include transactions where:
• The counterparty has an offsetting exposure and a master netting or similar arrangement is in place with
a right to offset only in the event of default, insolvency or bankruptcy, or the offsetting criteria are
otherwise not satisfied; and
• In the case of derivatives and securities lending or sale and repurchase agreements, cash and non-cash
collateral has been received or pledged to cover net exposure in the event of a default or other
predetermined events. The effect of Over-collateralization is excluded.
The net amounts resulting after offsetting are not intended to represent ING’s actual exposure to
counterparty risk, as risk management employs a number of credit risk mitigation strategies in addition to
netting and collateral arrangements. Reference is made to the Risk Management Credit risk’ section ‘Credit
risk mitigation'.
ING Bank Annual Report 2024 192

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> Additional notes to the Consolidated financial statements

Financial assets subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million 2024 |  | Gross amounts of recognised financial assets | Gross amounts of recognised financial liabilities offset in the statement of financial position | Net amounts of financial assets presented in the statement of financial position | Related amounts not offset in the statement of financial position | Net amount | Amounts not subject to enforceable netting arrangements | Statement of financial position total ¹
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 | 3,752 | -31 | 3,721 |  | 3,683 | 38 | 7,057 | 10,777
| Other |  |  |  |  |  |  |  |
|  | 3,752 | -31 | 3,721 |  | 3,683 | 38 | 7,057 | 10,777
Financial assets at fair value through profit or loss |  |  |  |  |  |  |  |  |
Trading and Non-trading | Reverse repurchase, securities borrowing and similar agreements | 98,679 | -49,365 | 49,315 | 219 | 48,676 | 420 | 16,112 | 65,426
| Derivatives 3 | 93,034 | -66,877 | 26,157 | 17,598 | 3,643 | 4,916 | 6,111 | 32,268
|  | 191,713 | -116,241 | 75,472 | 17,818 | 52,319 | 5,336 | 22,222 | 97,694
Loans and advances to customers 4 | Reverse repurchase, securities borrowing and similar agreements | 4,444 | -1,216 | 3,228 |  | 3,191 | 37 | 243 | 3,471
| Cash pools | 237,248 | -234,838 | 2,410 | 65 | 1,730 | 615 |  | 2,410
|  | 241,691 | -236,053 | 5,638 | 65 | 4,921 | 652 | 243 | 5,881
Other items where offsetting is applied in the statement of financial position 5 |  | 6,666 | -6,284 | 382 | 79 |  | 303 |  | 382
Total financial assets |  | 443,822 | -358,609 | 85,213 | 17,962 | 60,922 | 6,329 | 29,522 | 114,735

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 2024, the total amount of ‘Loans and advances to banks’ excluding repurchase agreements is EUR 10,992 million which is not subject to offsetting.
3 Derivative assets and derivative liabilities include certain exchange traded future and option positions with the same underlying.
4 At 31 December 2024 , the total amount of ‘Loans and advances to customers’ excluding repurchase agreements is EUR 676,828 million of which the net cash pool position of EUR 2,410 million is subject to offsetting.
5 Other items include amounts to be settled with Central Clearing Counterparties regarding securities and derivatives transactions and is included in ‘Other Assets – Amounts to be settled’ for EUR 3,548 million in the statement of financial position of which EUR 382 million is
subject to offsetting as at 31 December 2024.
ING Bank Annual Report 2024 193

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> Additional notes to the Consolidated financial statements

Financial assets subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million 2023 |  | 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 | 1,840 | -29 | 1,811 |  | 1,811 |  | 3,440 | 5,251
| Other |  |  |  |  |  |  |  |
|  | 1,840 | -29 | 1,811 |  | 1,811 |  | 3,440 | 5,251
Financial assets at fair value through profit or loss |  |  |  |  |  |  |  |  |
Trading and Non-trading | Reverse repurchase, securities borrowing and similar agreements | 76,304 | -34,738 | 41,566 | 235 | 41,063 | 268 | 22,091 | 63,657
| Derivatives | 105,928 | -83,312 | 22,617 | 14,868 | 2,915 | 4,834 | 5,091 | 27,708
|  | 182,232 | -118,049 | 64,183 | 15,103 | 43,977 | 5,102 | 27,182 | 91,365
Loans and advances to customers 3 | Reverse repurchase, securities borrowing and similar agreements |  |  |  |  |  |  | 499 | 499
| Cash pools | 236,233 | -234,617 | 1,616 | 41 | 1,217 | 358 |  | 1,616
|  | 236,233 | -234,617 | 1,616 | 41 | 1,217 | 358 | 499 | 2,115
Other items where offsetting is applied in the statement of financial position 4 |  | 7,124 | -6,428 | 695 | 21 |  | 675 |  | 695
Total financial assets |  | 427,428 | -359,124 | 68,305 | 15,165 | 47,005 | 6,135 | 31,121 | 99,425

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 2023, the total amount of ‘Loans and advances to banks’ excluding repurchase agreements is EUR 11,458 million which is not subject to offsetting.
3 At 31 December 2023, the total amount of ‘Loans and advances to customers’ excluding repurchase agreements is EUR 641,954 million of which the net cash pool position of EUR 1,616 million is subject to offsetting.
4 Other items include amounts to be settled with Central Clearing Counterparties regarding securities and derivatives transactions and is included in ‘Other Assets – Amounts to be settled’ for EUR 3,869 million in the statement of financial position of which EUR 695 million is
subject to offsetting as at 31 December 2023.
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> Additional notes to the Consolidated financial statements

Financial liabilities subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million 2024 |  |  |  |  | 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 | 64 | -31 | 33 |  | 33 |  |  | 33
| Other | 62 | -62 |  |  |  |  |  |
|  | 126 | -93 | 33 |  | 33 |  |  | 33
Customer deposits 4 | Repurchase, securities lending and similar agreements | 1,214 | -1,214 |  |  |  |  | 1 | 1
| Cash pools | 251,655 | -234,838 | 16,817 | 21 |  | 16,796 |  | 16,817
|  | 252,868 | -236,052 | 16,817 | 21 |  | 16,796 | 1 | 16,818
Financial liabilities at fair value through profit or loss |  |  |  |  |  |  |  |  |
Trading and Non-trading | Repurchase, securities lending and similar agreements | 81,384 | -49,365 | 32,019 | 219 | 31,669 | 130 | 11,670 | 43,689
| Derivatives 3 | 89,386 | -67,731 | 21,655 | 17,639 | 2,745 | 1,272 | 6,612 | 28,267
|  | 170,769 | -117,095 | 53,674 | 17,858 | 34,414 | 1,402 | 18,282 | 71,956
Other items where offsetting is applied in the statement of financial position 5 |  | 5,609 | -5,368 | 242 | 83 |  | 159 |  | 242
Total financial liabilities |  | 429,373 | -358,608 | 70,765 | 17,962 | 34,447 | 18,357 | 18,283 | 89,049

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 2024, the total amount of ‘Deposits from banks’ excluding repurchase agreements is EUR 16,689 million of which EUR 0 million is subject to offsetting.
3 Derivative assets and derivative liabilities include certain exchange traded future and option positions with the same underlying.
4 At 31 December 2024, the total amount of ‘Customers deposits’ excluding repurchase agreements is EUR 699,724 million of which the net cash pool position of EUR 16,817 million is subject to offsetting.
5 Other items include amounts to be settled with Central Clearing Counterparties regarding securities and derivatives transactions and is included in ‘Other Liabilities – Amounts to be settled’ for EUR 4,290 million in the statement of financial position of which EUR 242 million is
subject to offsetting as at 31 December 2024.
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> Additional notes to the Consolidated financial statements

Financial liabilities subject to offsetting, enforceable master netting arrangements and similar agreements
in EUR million 2023 |  |  |  |  | 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 | 29 | -29 |  |  |  |  | 2,064 | 2,064
| Other | 290 | -290 |  |  |  |  |  |
|  | 319 | -319 |  |  |  |  | 2,064 | 2,064
Customer deposits 3 | Repurchase, securities lending and similar agreements |  |  |  |  |  |  |  |
| Cash pools | 249,734 | -234,617 | 15,116 | 13 |  | 15,103 |  | 15,116
|  | 249,734 | -234,617 | 15,116 | 13 |  | 15,103 |  | 15,116
Financial liabilities at fair value through profit or loss |  |  |  |  |  |  |  |  |
Trading and Non-trading | Repurchase, securities lending and similar agreements | 76,581 | -34,738 | 41,844 | 235 | 41,653 | -44 | 14,222 | 56,065
| Derivatives | 101,218 | -82,677 | 18,541 | 14,881 | 3,455 | 204 | 6,607 | 25,148
|  | 177,799 | -117,415 | 60,384 | 15,117 | 45,108 | 160 | 20,829 | 81,213
Other items where offsetting is applied in the statement of financial position 4 |  | 7,285 | -6,773 | 512 | 35 |  | 477 |  | 512
Total financial liabilities |  | 435,137 | -359,124 | 76,013 | 15,165 | 45,108 | 15,740 | 22,892 | 98,905

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 2023, the total amount of ‘Deposits from banks’ excluding repurchase agreements is EUR 21,193 million of which EUR 0 million is subject to offsetting.
3 At 31 December 2023, the total amount of ‘Customers deposits’ excluding repurchase agreements is EUR 702,120 million of which the net cash pool position of EUR 15,116 million is subject to offsetting.
4 Other items include amounts to be settled with Central Clearing Counterparties regarding securities and derivatives transactions and is included in ‘Other Liabilities – Amounts to be settled’ for EUR 6,509 million in the statement of financial position of which EUR 512 million is
subject to offsetting as at 31 December 2023.
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> Additional notes to the Consolidated financial statements
38 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 | 2024 | 2023
Contingent liabilities in respect of |  |
– Discounted Bills |  | 2
– Guarantees | 26,908 | 27,894
– Irrevocable letters of credit | 16,388 | 14,925
| 43,296 | 42,821
Irrevocable facilities | 175,222 | 166,810
| 218,518 | 209,631

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.
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.
ING uses Irrevocable Payment Commitments (IPCs) for a part of its contributions to the Single Resolution
Fund (SRF). ING Bank has EUR 346 million of IPCs outstanding to the SRF as at 31 December 2024 (31
December 2023: EUR 346 million). No IPCs were provided to the SRF during 2024 (2023: EUR 63 million). No
IPCs were called by the SRF in 2024 (2023: nil). Cash collateral provided to the SRF is equal to the outstanding
amount of IPCs.
ING also uses IPCs for a part of its contributions to the Deposit Guarantee Scheme in Germany. Contingent
liabilities for such outstanding IPCs amount to EUR 309 million as at 31 December 2024 (31 December 2023:
EUR 273 million). Of these, EUR 35 million of IPCs were provided to the DGS during 2024 (2023: EUR 36
million). No IPCs were called by the DGS in 2024 (2023: nil). ING posted government bonds as collateral for
the total nominal amount of EUR 336 million as at 31 December 2024 (31 December 2023: EUR 319 million).
Furthermore we refer to Note 39 'Legal proceedings' for any contingent liabilities in respect of legal
proceedings.
39 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 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.
ING Bank Annual Report 2024 197

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> Additional notes to the Consolidated financial statements
Settlement agreement : On 4 September 2018, ING announced that it had entered into a settlement
agreement with the Dutch Public Prosecution Service relating to previously disclosed investigations regarding
various requirements for client on-boarding and the prevention of money laundering and corrupt practices.
Following the entry into the settlement agreement, ING has experienced heightened scrutiny from
authorities in various countries. ING is also aware, including as a result of media reports, that other parties
may, among other things, seek to commence legal proceedings against ING in connection with the subject
matter of the settlement. Certain parties filed requests with the Court of Appeal in The Netherlands to
reconsider the prosecutor’s decision to enter into the settlement agreement with ING and not to prosecute
ING or (former) ING employees. In December 2020, the Court of Appeal issued its final ruling. In this ruling the
prosecutors' decision to enter into the settlement agreement with ING was upheld, making the settlement
final. However, in a separate ruling, the Court ordered the prosecution of ING’s former CEO. In December
2024, the Dutch Public Prosecution Service announced that they will ask the Court’s approval not to
prosecute ING’s former CEO.
Litigation by investors: In February and March 2024, ING and certain (former) board members were served
with a writ of summons for litigation in The Netherlands on behalf of investors who claim to have suffered
financial losses in connection with ING's disclosures on historic shortcomings in its financial economic crime
policies, related risk management and control systems, the investigation by and settlement with the Dutch
authorities in 2018 and related risks for ING. We do not agree with the allegations and will defend ourselves
against these and the claimed damages of EUR 587 million. In February 2025, ING and the (former) board
members have filed their statement of defense against the allegations. Separately, but relating to the same
matters, in July 2024 another group of investors claiming to have suffered financial losses requested
disclosure of certain ING documents and to question witnesses. ING has subsequently filed its response to
the requests made with the court. We follow IFRS rules for taking legal provisions and would disclose
material amounts in this regard if and when applicable - which currently is not the case.
Findings regarding AML processes: As previously disclosed, after its September 2018 settlement with Dutch
authorities concerning anti-money laundering matters, and in the context of significantly increased
attention on the prevention of financial economic crime, ING has experienced heightened scrutiny by
authorities in various countries. The interactions with such regulatory and judicial authorities have included,
and can be expected to continue to include, onsite visits, information requests, investigations and other
enquiries. Such interactions, as well as ING’s internal assessments in connection with its global enhancement
programme, have in some cases resulted in satisfactory outcomes, and also have resulted in, and may
continue to result in, findings, or other conclusions which may require appropriate remedial actions by ING,
or may have other consequences. ING intends to continue to work in close cooperation with authorities as it
seeks to improve its management of non-financial risks in terms of policies, tooling, monitoring, governance,
knowledge and behaviour.
In January 2022, a Luxembourg investigating judge informed ING Luxembourg that he intends to instruct the
relevant prosecutor to prepare a criminal indictment regarding alleged shortcomings in the AML process at
ING Luxembourg. In November 2024, the Court decided to refer the case to the ‘Tribunal Correctionnel’ for
alleged shortcomings in a limited number of individual client files. ING Luxembourg filed an appeal against
this procedural decision. 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.
ING's subsidiary Payvision was 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 cooperated
with such investigation. In October 2021, the phasing out of Payvision was announced. The phasing out of
activities and the transfer of customers to a new service provider were completed in 2022. At the request of
Payvision, its license has been withdrawn. In April 2024, the Dutch authorities closed the investigation,
without charges against Payvision, but with the issuance of a penalty order against two former directors of
Payvision.
ING continues to take steps to enhance its management of compliance risks and embed stronger awareness
across the whole organisation. These steps are part of the global KYC programme and set of initiatives, which
includes enhancing KYC files and working on various structural improvements in compliance policies, tooling,
monitoring, governance, knowledge and behaviour.
Tax cases: Because of the geographic spread of its business, ING may be subject to tax audits, investigations
and procedures in numerous jurisdictions at any point in time. Although ING believes that it has adequately
provided for all its tax positions, the ultimate resolution of these audits, investigations and procedures is
uncertain and may result in liabilities which are materially different from the amounts recognised.
Claims regarding accounts with predecessors of ING Bank Türkiye: ING Bank Türkiye has received
numerous claims from (former) customers of legal predecessors of ING Bank Türkiye. The claims are based
on offshore accounts held with these banks, which banks were seized by the Savings Deposit Insurance Fund
(“SDIF”) prior to the acquisition of ING Bank Türkiye in 2007 from OYAK. Pursuant to the acquisition contract,
ING Bank Türkiye can claim compensation from SDIF if a court orders ING Bank Türkiye to pay amounts to
the offshore account holders. SDIF has made payments to ING Bank Türkiye pursuant to such compensation
requests, but filed various lawsuits to receive those amounts back. In April 2022 the Turkish Supreme Court
decided that the prescription period for the offshore account holders’ compensation claims starts on the
transfer date of the account holders to the offshore accounts. As of January 2025, three lawsuits have been
finalized in favour of ING Bank Türkiye with the Turkish Supreme Court’s verdict, which are likely to be
precedent decisions for the other ongoing files.
In 2024 SDIF initiated enforcement procedures against ING Bank Türkiye, based on the decision in April 2022
by the Turkish Supreme Court referred to above. SDIF alleges that this decision means that ING Bank Türkiye
ING Bank Annual Report 2024 198

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> Additional notes to the Consolidated financial statements
has to return certain payments made by SDIF regarding the offshore depositors' receivables cases, as the
statute of limitations had already expired.
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: In the past a uniform recovery framework for Dutch SME clients with
interest rate derivatives was established by a committee of independent experts appointed by the Dutch
Ministry of Finance. In the context of this recovery framework most claims have been settled, however ING is
still 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. In one case, the business
client filed an appeal in cassation with the Dutch Supreme Court in January 2024. In December 2024, the
Supreme Court rejected such appeal. As there are only two lawsuits still pending, we do not expect that
these cases will have a significant impact in the future.
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
interest surcharge based upon the essential obligations in the contract. In a relevant case the Dutch
Supreme Court ruled in favour of another Dutch bank, addressing the question whether or not a bank is
allowed to increase interest surcharges unilaterally. The Dutch Supreme Court ruled affirmatively 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 and this ruling has been confirmed by the Dutch Supreme Court in its ruling of 22
December 2023. ING will continue to deal with all claims individually. In the last pending case against ING,
the claimant filed an appeal in cassation with the Dutch Supreme Court in April 2024. The Supreme Court
rejected the appeal in cassation in February 2025. There are no other lawsuits related to client surcharges on
the Euribor rates of so-called Euroflex loans. We therefore do not expect that this issue will have a significant
impact in the future.
Mortgage expenses claims: ING Spain has received claims and is involved in procedures with customers
regarding reimbursement of expenses associated with the formalisation of mortgages. In most first instance
court proceedings the expense clause of the relevant mortgage contract has been declared null and ING
Spain has been ordered to reimburse all or part of the applicable expenses. Since 2018, the Spanish Supreme
Court and the European Court of Justice ("CJEU") have issued rulings setting out which party should bear
notary, registration, agency, and stamp duty costs. In January 2021, the Spanish Supreme Court ruled that
valuation costs of mortgages, signed prior to 16 June 2019, the date the new mortgage law entered into
force, should be borne by the bank. Media attention for the statute of limitations applicable to the right to
claim reimbursement of costs resulted in an increased number of claims at the beginning of 2021. In June
2021, the Spanish Supreme Court published a press release stating its decision to ask the CJEU for a
preliminary ruling regarding the criteria that should be applied to determine the date from which the action
for claiming the reimbursement of mortgage expenses is considered to be expired. In January 2024, the
CJEU ruled that the limitation period for the judicial claim for reimbursement of expenses cannot begin to
run from a Supreme Court decision declaring the clause null and void, nor from the moment of the payment
of the expenses. The CJEU indicated that it is up to national case-law to determine the criterion that should
be applied for the calculation of the limitation period. In April 2024, the CJEU ruled that it was not against
European Union laws that the period of prescription began to be calculated from the moment the clause was
declared null. Following the CJEU approach, on 14 June 2024 the Spanish Supreme Court issued its final
decision stating in short that the 5-year period to claim the reimbursement of costs can only begin from the
date each individual clause is declared null by a judge. The Spanish Supreme Court also leaves a small door
open for banks in case they can demonstrate that a specific individual indeed had knowledge of the
unfairness of the clause before that moment. ING is reviewing the best way to address the latest
developments.
ING Spain was also included, together with other Spanish banks, in three class actions filed by customer
associations. In one of the class actions an agreement was reached with the association. In another class
action the association withdrew from the proceedings. With respect to the third class action, ING filed an
appeal asking the Spanish Court of Appeal to determine that the ruling of the court of first instance is only
applicable to the consumers that were part of the case. The National Court has revoked the ruling and
declared that the consumers will not be able to initiate an action for compensation based on the first
instance ruling, as the claimant association intended. This last decision is not yet final, as it has been
appealed in the Supreme Court.
A provision has been established in the past and has been adjusted where appropriate.
Imtech claims: 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. In March 2018, ING Bank
received another claim on the same subject matter from the Dutch Association of Stockholders (Vereniging
van Effectenbezitters, “VEB”). In 2022, these claimants reiterated and further substantiated their claim in a
letter to ING. Each of the claimants allege inter alia that shareholders they represent were misled by the
prospectus of the rights issues of Imtech in July 2013 and October 2014. Underwriters, including ING are held
liable by these claimants for the damages that shareholders would have suffered. ING responded to these
claimants denying any and all responsibility in relation to the allegations made in the relevant letters. In
March 2024, Imtech trustees, VEB and other parties entered into a settlement agreement that contained a
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> Additional notes to the Consolidated financial statements
release for claims regarding this subject matter. This release, by way of third-party clause, applies to ING as
well. The other claimants (one of which is now dissolved) are not party to this agreement and at this
moment it is not possible to assess whether the remaining claims would lead to any court case and what the
outcome of such court cases would be.
Claims regarding mortgage loans i n Swiss franc in Poland: ING Poland is a defendant in several lawsuits
with retail customers who took out mortgage loans indexed to the Swiss franc. Such customers have alleged
that the mortgage loan contract contains abusive clauses. One element that the court is expected to
consider in determining whether such contracts contain abusive clauses is whether the rules to determine
the exchange rate used for the conversion of the loan from Polish zloty to Swiss franc are unambiguous and
verifiable. In December 2020, the Polish Financial Supervision Authority (PFSA) proposed that lenders offer
borrowers voluntary out-of-court settlements on foreign-currency mortgage disputes, with mortgages
indexed to Swiss franc serving as a reference point. In February 2021, ING Poland announced its support for
this initiative and in October 2021 began offering the settlements to the borrowers following the PFSA’s
proposal. In October 2022, a hearing of the 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.
In June 2023, the CJEU issued a ruling. It ruled that under EU law when a loan agreement indexed to the
Swiss franc is declared null and void, banks cannot claim any remuneration (i.e. interest) for the duration the
principal amount was available to the customer. The customer, however, may assert claims against banks in
addition to reimbursement of interest and instalments previously paid to the bank. In September and
December 2023, the CJEU issued rulings providing further clarity on the limitation period and about the
question of when a contract clause can be considered unfair. In April 2024, the Polish Supreme Court issued a
ruling stating that if it is impossible to establish a binding foreign currency exchange rate for the parties in
the indexed or denominated loan agreement, the agreement is also not binding in other respects. ING has
recorded a portfolio provision. In October and November 2024, seven new preliminary questions were
referred to the CJEU which focus on the claims of banks in a situation of annulment of a credit agreement.
Certain Consumer Credit Products: In October 2021, ING announced that it would offer compensation to its
Dutch retail customers in connection with certain revolving consumer loans with variable interest rates that
allegedly did not sufficiently follow market rates. This announcement was made in response to several
rulings by the Dutch Institute for Financial Disputes (Kifid) regarding similar products at other banks. ING has
recognized a provision of EUR 180 million in 2021 for compensation and costs in connection with this matter.
On 22 December 2021, ING announced that it reached an agreement with the Dutch Consumers’ Association
(Consumentenbond) on the compensation methodology for revolving credits. Based on a Kifid ruling
regarding similar products, ING has amended its previously announced compensation scheme by also
compensating interest on interest. In the third quarter of 2022, ING increased its provision for this matter by
EUR 75 million. In the fourth quarter of 2022, ING and the Dutch Consumers’ Association reached an
agreement on the compensation of customers who have had an overdraft facility or a revolving credit card
with a variable interest rate. ING has started compensating such customers in line with Kifid rulings about
revolving credits including ‘interest-on-interest’-effect in these cases. Timelines for compensation vary
depending on customer and product segmentation and are dependent on the availability of data. In 2024
the compensation process was expedited. The compensation process is still ongoing.
Climate litigation: In January 2024, Friends of the Earth Netherlands (Milieudefensie) announced that it
holds ING liable for alleged contribution to climate change and threatens to initiate legal proceedings against
ING. In January 2025, Milieudefensie sent a new letter in which it reiterated its threat to initiate legal
proceedings against ING, but revised its demands. If necessary, ING will defend its science-based climate
approach in court.
Russian claims: Several ING entities have received claims from, and are involved in litigation with, certain
Russia-linked entities. They claim the payment of principal or interest or other amounts that they have not
received pursuant to sanctions. Claims are also made related to the settlement of contracts that have been
terminated after sanctions were imposed. In at least one case, the claimant seized assets in Russia of ING
entities. We do not agree with these claims, as they do not comply with the underlying contracts or
applicable laws, including sanctions. We follow IFRS rules for taking legal provisions and would disclose
material amounts in that regard if and when applicable which currently is not the case.
40 Consolidated companies and businesses acquired and divested
Acquisitions and divestments
There were no significant acquisitions in 2024, 2023 or 2022, and there was no significant divestment in
2024 and 2023.
Divestments 2022
ING announced at 13 December 2022 that it had sold its interest ( 80%) in Intersoftware Holding BV to the
Sky Group/ DIAS and realised a transaction result of EUR 11.0 million which consisted 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.
41 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.
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> Additional notes to the Consolidated financial statements
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
|  |  | 2024 | 2023
Subsidiary | Statutory place of Incorporation | Country of operation |  |
Bank Mendes Gans N.V.3 | Amsterdam | the Netherlands |  | 100%
ING Belgium S.A./N.V. | Brussels | Belgium | 100% | 100%
ING Luxembourg S.A. | Luxembourg City | Luxembourg | 100% | 100%
ING-DiBa AG | Frankfurt am Main | Germany | 100% | 100%
ING Bank Slaski S.A.1 | Katowice | Poland | 75% | 75%
ING Financial Holdings Corporation | Delaware | United States of America | 100% | 100%
ING Bank A.S. | Istanbul | Türkiye | 100% | 100%
ING Bank (Australia) Ltd | Sydney | Australia | 100% | 100%
ING Commercial Finance B.V. | Amsterdam | the Netherlands | 100% | 100%
ING Groenbank N.V.3 | Amsterdam | the Netherlands |  | 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 29 'Information on geographical areas'
2 Reference is made to Note 8 'Investment in associates and joint ventures'.
3 In 2024, Bank Mendes Gans N.V. and ING Groenbank N.V merged with ING Bank N.V.
42 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 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 retained 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 2024, these consisted of EUR 74 billion (2023:
EUR 67 billion) of senior and subordinated notes, of which EUR 4 billion (2023: EUR 2 billion) were issued
externally. The underlying exposures are residential mortgages and SME loans. Apart from the third party
ING Bank Annual Report 2024 201

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> Additional notes to the Consolidated financial statements
funding, these securitisations did not impact ING Bank’s Consolidated statement of financial position and
profit or loss.
In 2024, there are no non-controlling interests as part of the securitisation structured entities that are
significant to ING Bank.
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., ING SB Covered Bond Company B.V. and ING SB2 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 | 2024 | 2023
Dutch Covered Bond programmes | 27,172 | 27,148
Diba Mortgage Pfandbriefe | 15,050 | 18,276
ING Belgium Residential Pandbrieven Programme | 9,024 | 7,347
IBAL Covered Bond | 3,676 | 3,781
ING Bank Hipoteczny CBP | 602 | 544
| 55,524 | 57,096

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
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 ABCP programmes by providing Mont Blanc Capital Corp. with short-term liquidity
facilities. Once drawn these facilities bear normal credit risk.
The liquidity facilities provided to Mont Blanc are EUR 3,119 million (2023: EUR 2,268 million). The drawn
liquidity amount is nil as at 31 December 2024 (2023: 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 EUR 2 billion to a special purpose
vehicle (SPV). The transaction resulted in full derecognition of the financial assets from ING’s statement of
financial position. Following this transfer ING continues to have two types of ongoing involvement in the
transferred assets: as counterparty to the SPE of a non-standard interest rate swap, which is recognised as a
non-trading derivative, and as servicer of the transferred assets. 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 2024 amounted to EUR -11 million (2023: EUR -26 million); fair value changes on this
swap recognised in the statement of profit or loss in 2024 were EUR 14 million (2023: EUR 14 million). Service
fee income recognised, for the role as administrative agent, in the statement of profit or loss in 2024
amounted to EUR 1 million (2023: EUR 1 million). The cumulative income recognised in profit or loss since
derecognition amounts to EUR 20 million (2023: EUR 19 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.
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> Additional notes to the Consolidated financial statements
43 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 30 '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 | 2024 | 2023
Assets | 72 | 56
Liabilities | 77,739 | 70,524
Income received | 0 | 1
Expenses paid | 2,507 | 2,026

Liabilities to ING Groep N.V. mainly comprise long-term funding.
Associates and joint ventures

Transactions with ING Bank’s main associates and joint ventures
| Associates | Joint ventures
in EUR million | 2024 | 2023 | 2024 | 2023
Assets | 142 | 121 |  |
Liabilities | 263 | 424 | 10 | 1
Off-balance sheet commitments | 23 | 20 |  |
Income received | 16 | 10 |  |
Expenses paid | 2 | 3 |  |

Assets, liabilities, commitments, and income related to Associates and joint ventures result from
transactions which are executed as part of the normal Banking business. Dividends received by associates
and joint ventures are included in Note 8 'Investment in associates and joint ventures'.
Key management personnel compensation
The Executive Board of ING Groep N.V., the Management Board Banking and the Supervisory Board are
considered Key Management personnel of ING. In 2024, 2023 and 2022, 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)
2024 in EUR thousands | Executive Board of ING Groep N.V. | Management Board Banking 1 | Total
Fixed Compensation |  |  |
– Base salary | 4,388 | 3,598 | 7,987
– Collective fixed allowances 2 | 1,033 | 790 | 1,823
– Pension costs | 84 | 95 | 179
– Severance benefits |  |  |
Variable compensation |  |  |
– Upfront cash | 0 | 609 | 609
– Upfront shares | 302 | 609 | 911
– Deferred cash | 0 | 914 | 914
– Deferred shares | 453 | 914 | 1,367
– Other emoluments 3 | 306 | 418 | 724
Total compensation | 6,566 | 7,948 | 14,513

1 E xcluding 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 the loss of pension benefits with respect to salary in excess
of EUR 137,800.
3 T his includes expatriate allowances (such as housing, school/tuition fees and international health insurances, if applicable); banking
and insurance benefits from ING (on the same terms as for other employees of ING in the Netherlands); tax and financial planning
services to ensure compliance with the relevant legislative requirements; and the use of a company car or driver service.
ING Bank Annual Report 2024 203

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> Additional notes to the Consolidated financial statements

Key management personnel compensation (Executive Board and Management Board Banking)
2023 in EUR thousands | Executive Board of ING Groep N.V. | Management Board Banking 1 | Total
Fixed Compensation |  |  |
– Base salary | 4,220 | 4,200 | 8,420
– Collective fixed allowances 2 | 1,002 | 887 | 1,889
– Pension costs | 78 | 107 | 185
– Severance benefits |  | 734 | 734
Variable compensation |  |  |
– Upfront cash |  | 598 | 598
– Upfront shares | 293 | 598 | 891
– Deferred cash |  | 897 | 897
– Deferred shares | 439 | 897 | 1,336
– Other emoluments 3 | 344 | 487 | 832
Total compensation | 6,376 | 9,405 | 15,782

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 the loss of pension benefits with respect to salary in excess
of EUR 128,810.
3 T his includes expatriate allowances (such as housing, school/tuition fees and international health insurances, if applicable); banking
and insurance benefits from ING (on the same terms as for other employees of ING in the Netherlands); tax and financial planning
services to ensure compliance with the relevant legislative requirements; reimbursement of costs under the Directors & Officers
indemnity provided by ING; and the use of a company car or driver service.

Key management personnel compensation (Executive Board and Management Board Banking)
2022 | Executive Board of ING Groep N.V. | Management Board Banking 1 | Total
in EUR thousands
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.
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 2024 relating to the fixed expenses of 2024 and the vesting of variable
remuneration of earlier performance years, is EUR 12 million in 2024 (2023: EUR 14 million; 2022: EUR 14
million).
ING Bank Annual Report 2024 204

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> Additional notes to the Consolidated financial statements
The table below shows the total of fixed remuneration, expense allowances and attendance fees for the
Supervisory Board in 2024, 2023 and 2022.

Key management personnel compensation (Supervisory Board) |
in EUR thousands | 2024 | 2023 | 2022
Total compensation | 1,191 | 1,152 | 1,048

Loans and advances to key management personnel
As at 31 December 2024 Loans and advances outstanding to key management personnel amounted to EUR
1.1 million (2023: EUR 1.7 million) with an average interest rate of 2.1% (2023: 2.1%) and loan commitments
to key management personnel amounted to EUR 145 thousand (2023: EUR 138 thousand). Total interest
received in 2024 on these loans and advances amounted to EUR 28 thousand (2023: EUR 30 thousand).
These loans and advances and loan commitments (1) were made in the ordinary course of business, (2) were
granted on conditions that are comparable to those of loans and advances granted to all employees and (3)
did not involve more than the normal risk of collectability or present other unfavourable features.
Deposits outstanding to key management personnel
As at 31 December 2024 Deposits outstanding from key management personnel amounted to EUR 15.8
million (2023: EUR 13.9 million). Total interest paid in 2024 on these deposits amounted to EUR 324 thousand
(2023: EUR 197 thousand).
ING shares held by key management personnel

Number of ING Groep N.V. shares to key management personnel
| ING Groep N.V. shares
in numbers | 2024 | 2023
Executive Board members | 152,652 | 128,241
Management Board Banking | 343,055 | 262,507
Supervisory Board members | 5,295 | 5,295

ING Bank Annual Report 2024 205

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> Additional notes to the Consolidated financial statements
44 Capital management
Capital management strategy
Group Treasury (GT) 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 executing
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 takes into account both regulatory and internal, economic-based
metrics and requirements as well as the interests of key stakeholders, such as customers, shareholders and
rating agencies.
ING 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.
• ING's fully loaded CET1 ratio target is built on the CET1 requirements specified for ING, potential increase
in the regulatory requirement of the countercyclical buffer, the potential impact of a standardised and
pre-determined stress scenario and available mitigating actions, and general uncertainties.
• Leverage ratio (LR) is defined as Tier 1 capital divided by the leverage exposure.
• Minimum Required Eligible Liabilities (MREL)/ Total Loss Absorbing Capacity (TLAC) is Total capital plus
senior unsecured bonds and amortisations. MREL/ TLAC ratios are based on both risk-weighted assets and
leverage exposure .
Capital position as per 31 December 2024

ING Bank capital position according to CRR II / CRD V
in EUR million | 2024 | 2023
Shareholders’ equity 1 | 42,743 | 40,191
- Interim profits not included in CET 1 capital | 0 | -766
- Other adjustments | -2,146 | -1,029
Regulatory adjustments | -2,146 | -1,795
Available common equity Tier 1 capital | 40,597 | 38,396
Additional Tier 1 securities | 7,967 | 6,962
Regulatory adjustments additional Tier 1 | 106 | 86
Available Tier 1 capital | 48,671 | 45,444
Supplementary capital Tier 2 bonds 2 | 9,853 | 9,115
Regulatory adjustments Tier 2 | 81 | 54
Available Total capital | 58,604 | 54,613
Risk weighted assets | 334,770 | 321,358
Common equity Tier 1 ratio | 12.1% | 11.9%
Tier 1 ratio | 14.5% | 14.1%
Total capital ratio | 17.5% | 17.0%

1 Shareholders' equity is determined in accordance with IFRS-EU.
2 All T2 securities are CRR/CRD V-compliant for 2024.
In accordance with the applicable regulation, credit and operational risk models used in the capital ratios
calculations are not audited.
Regulatory requirements
Capital adequacy and 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.
ING Bank Annual Report 2024 206

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> Additional notes to the Consolidated financial statements
The overall SREP CET1 requirement (including buffer requirements) for ING Bank N.V. at a consolidated level
was 9.83% at the end of 2024. This requirement is the sum of a 4.5% Pillar I requirement, a 2.5% capital
conservation buffer (CCB), a 0.83% countercyclical buffer (CCyB) and a 2.0% O-SII (Other Systemically
Important Institutions) buffer (based on December 2024 positions).
45 Subsequent events
On January 28, 2025 ING announced that it has reached an agreement on the sale of its business in Russia
to Global Development JSC, a Russian company owned by a Moscow-based financial investor with a
background in factoring services. This transaction will effectively end ING’s activities in the Russian market.
Under the terms of the agreement, Global Development will acquire all shares of ING Bank (Eurasia) JSC,
taking over all Russian onshore activities and staff. Global Development intends to continue to serve
customers in Russia under a new brand. The transaction, which has been preceded by extensive due
diligence, is subject to various regulatory approvals and is expected to be closed in the third quarter of 2025.
ING has taken on no new business with Russian companies, has scaled down operations and has taken
actions to separate the business from ING’s networks and systems.
ING estimates a negative impact to the Result on disposal of Group companies of EUR 0.7 billion post tax.
This includes an estimated book loss of EUR 0.4 billion, representing the expected difference between the
sale price and the book value of the business. It also includes an estimated negative impact of EUR 0.3 billion
from recycling the currency translation adjustment net of the Net Investment hedge reserve through P&L,
that is currently booked in equity for past changes of the value of ING Bank (Eurasia) JSC as a result of
changes in exchange rates.
On 2 March 2025, ING agreed with a minority shareholder to acquire their 17.6% stake in Van Lanschot
Kempen N.V. Per the agreement, ING has directly acquired 7.2% with the remainder of the transaction
subject to regulatory approval. Together with ING’s existing stake of 2.7%, ING is expected to hold a total of
20.3% after completion of the transaction.
There are no other subsequent events to report other than those already disclosed in Note 39 'Legal
proceedings' of the consolidated financial statements.
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Authorisation of Consolidated Financial Statements
Amsterdam, 3 March 2025
The Supervisory Board
K.K. (Karl) Guha, chairperson
A.M.G. (Mike) Rees, vice-chairperson
J. (Juan) Colombás
M. (Margarete) Haase
L.J. (Lodewijk) Hijmans van den Bergh
H.A.H. (Herman) Hulst
H.H.J.G. (Harold) Naus
A. (Alexandra) Reich
H.W.P.M.A. (Herna) Verhagen
The Management Board Banking
S.J.A. (Steven) van Rijswijk, CEO and chairperson
T. (Tanate) Phutrakul, CFO
L. (Ljiljana) Čortan, CRO
P. (Pinar) Abay, head of Retail, Market Leaders and Challengers & Growth Markets
A.J.M. (Andrew) Bester, head of Wholesale Banking
M.A. (Marnix) van Stiphout, Chief operations officer
D. (Daniele) Tonella, Chief technology officer
Parent company
Financial statements
ING Bank Annual Report 2024 209

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Parent company statement of financial position
as at 31 December before appropriation of result

in EUR million | 2024 | 2023 |  | in EUR million | 2024 | 2023
Assets |  |  |  | Liabilities |  |
Cash and balances with central banks 2 | 34,633 | 51,484 |  | Deposits from banks 13 | 39,625 | 38,569
Short-dated government paper 3 | 270 | 253 |  | Customer deposits 14 | 368,903 | 357,248
Loans and advances to banks 4 | 78,966 | 71,930 |  | Debt securities in issue 15 | 61,656 | 61,355
Loans and advances to customers 5 | 367,179 | 346,104 |  | Other liabilities 16 | 63,651 | 68,865
Debt securities 6 | 55,059 | 48,671 |  | Provisions 17 | 691 | 782
Equity securities 7 | 9,925 | 6,279 |  | Senior non-preferred debt 18 | 49,393 | 40,213
Investments in group companies 8 | 31,753 | 31,040 |  | Subordinated loans 19 | 17,861 | 15,494
Investments in associates and joint ventures 9 | 1,378 | 1,243 |  | Total liabilities | 601,778 | 582,525
Intangible assets 10 | 634 | 582 |  |  |  |
Property and equipment 11 | 856 | 783 |  | Equity 20 |  |
Other assets 12 | 63,385 | 63,845 |  | Share capital | 525 | 525
Accrued assets | 485 | 501 |  | Share premium | 16,542 | 16,542
|  |  |  | Revaluation reserves | 717 | -181
|  |  |  | Legal and statutory reserves | -639 | -557
|  |  |  | Other reserves | 21,256 | 22,398
|  |  |  | Unappropriated result | 4,342 | 1,465
|  |  |  | Total equity | 42,743 | 40,191
Total assets | 644,521 | 622,716 |  | Total liabilities and equity | 644,521 | 622,716

The comparative balances 2023 have been adjusted due to legal mergers using the 'pooling of interests' method. Reference is made to Note 1 'Basis of presentation'.
References relate to the accompanying notes. These form an integral part of the Parent company financial statements.
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Parent company statement of profit or loss
for the years ended 31 December

in EUR million | 2024 | 2023
Interest income | 31,518 | 33,286
Interest expense | -26,466 | -27,387
Net interest income 21 | 5,052 | 5,899
Investment income and results from participating interests 22 | 4,389 | 4,697
Fee and commission income | 2,720 | 2,528
Fee and commission expense | -660 | -596
Net fee and commission income 23 | 2,060 | 1,932
Results from financial transactions 24 | 2,022 | 1,563
Other income | 13 | 75
Total income | 13,536 | 14,167
Staff expenses 25 | 3,657 | 3,492
Depreciation, amortisation and impairments 26 | 331 | 324
Other expenses 27 | 2,176 | 2,154
Addition to loan loss provisions | 399 | 52
Total expenses | 6,563 | 6,022
Result before tax | 6,972 | 8,144
Taxation 28 | 785 | 987
Result after tax | 6,187 | 7,157

The comparative balances 2023 have been adjusted due to legal mergers using the 'pooling of interests'
method. Reference is made to Note 1 'Basis of presentation'
References relate to the accompanying notes. These form an integral part of the Parent company financial
statements.
ING Bank Annual Report 2024 211

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

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 2022 | 525 | 16,542 | -862 | 361 | 25,067 | 913 | 42,546
Net result |  |  |  | 336 |  | 6,821 | 7,157
Amounts net of tax recognised directly in equity |  |  | 680 | 97 |  |  | 777
Dividends and other cash distributions |  |  |  |  | -4,000 | -6,269 | -10,269
Transfers |  |  |  | -1,351 | 1,351 | 0 | 0
Other changes |  |  |  |  | -20 |  | -20
Balance as at 31 December 2023 | 525 | 16,542 | -181 | -557 | 22,398 | 1,465 | 40,191
Net result |  |  |  | 125 |  | 6,062 | 6,187
Amounts net of tax recognised directly in equity |  |  | 898 | 409 |  |  | 1,307
Dividends and other cash distributions |  |  |  |  | -2,500 | -2,486 | -4,986
Transfers |  |  |  | -615 | 1,315 | -699 | 0
Other changes |  |  |  |  | 44 |  | 44
Balance as at 31 December 2024 | 525 | 16,542 | 717 | -639 | 21,256 | 4,342 | 42,743

Changes in individual Reserve components are presented in Note 20 'Equity'.
ING Bank Annual Report 2024 212

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

Notes to the parent company financial statements
1 Basis of presentation
ING Bank N.V. ( Naamloze Vennootschap) is registered at Bijlmerdreef 106, 1102 CT Amsterdam, the
Netherlands (Commercial Register of Amsterdam under number 33031431). ING Bank N.V. is a wholly-
owned subsidiary of ING Groep N.V. domiciled in Amsterdam, the Netherlands. ING Bank is a global
financial institution with a strong European base, offering a wide range of retail and wholesale banking
services to customers. These Parent financial statements, as at and for the year ended 31 December 2024,
comprise ING Bank N.V. also referred to as ING Bank. The Parent company financial statements of ING Bank
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
'Basis of preparation and material accounting policy information' 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. The ING Bank Parent financial statements, as
at and for the year ended 31 December 2024, were authorised for issue in accordance with a resolution of
the Management Board Banking on 3 March 2025.
In 2024, ING Bank updated the presentation of the statement of changes in equity to simplify its structure
and reduce duplication. Comparative figures have been updated accordingly. Furthermore, ING has
changed the presentation and classification of Senior non-preferred instruments in the statement of
financial position. Comparative figures have been updated accordingly.
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 from 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.
Merger Bank Mendes Gans N.V. and ING Groenbank N.V.
On 1 July 2024 and 1 October 2024, respectively, ING Groenbank N.V. and Bank Mendes Gans N.V. (both
wholly owned subsidiaries of ING Bank N.V.) legally merged into its parent company, ING Bank N.V. The
2024 parent company financial statements of ING Bank N.V. reflect the combined operations of the
merged entities using the 'pooling of interests' method which requires that the parent's financial
statements include the merged businesses as if the mergers were always effective. Accordingly, 2024
results of ING Bank N.V. include the results of ING Groenbank N.V. and Bank Mendes Gans N.V. for the full
year and the comparative figures for prior year have also been updated. The impact on the financial
statements has been limited. Both assets and liabilities of ING Bank N.V. decreased by EUR 1.3 billion in
2023 and liabilities showed a shift from Deposits from banks (EUR -16.5 billion) to Customer deposits (EUR
+15.4 billion) as the previous balances of ING Bank N.V. with its subsidiaries got effectively replaced with
external customer balances of those subsidiaries after the legal merger. There was no impact on Equity
and total Profit or Loss. The merger had no impact on the activities of the bank.
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.
ING Bank Annual Report 2024 213

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

> Notes to the parent company financial statements

Presentation Parent company financial statements versus Consolidated financial statements, Assets
in EUR million | Parent company statement of financial position
Assets as at 31 December 2024 | 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 | Property and equipment | Accrued and other assets | Total
Included in Consolidated statement of financial position: |  |  |  |  |  |  |  |  |  |  |
Cash and balances with central banks | 34,633 |  |  |  |  |  |  |  |  |  | 34,633
Loans and advances to banks |  |  | 55,730 |  |  |  |  |  |  |  | 55,730
Financial assets at fair value through profit or loss |  |  |  |  |  |  |  |  |  |  |
– Trading assets |  | 37 | 1,052 | 10,961 | 9,428 | 7,450 |  |  |  | 45,167 | 74,095
– Non-trading derivatives |  |  |  |  |  |  |  |  |  | 12,836 | 12,836
– Designated as at fair value through profit or loss |  |  | 689 | 272 | 3,690 |  |  |  |  |  | 4,651
– Mandatorily at fair value through profit or loss |  |  | 21,401 | 18,933 | 784 | 31 |  |  |  |  | 41,149
Financial assets at fair value through other comprehensive income |  | 196 | 94 | 755 | 17,655 | 2,444 |  |  |  |  | 21,142
Securities at amortised cost |  | 37 |  |  | 23,501 |  |  |  |  |  | 23,538
Loans and advances to customers |  |  |  | 336,259 |  |  |  |  |  |  | 336,259
Investments in associates and joint ventures |  |  |  |  |  |  | 1,378 |  |  |  | 1,378
Property and equipment |  |  |  |  |  |  |  |  | 854 |  | 854
Intangible assets |  |  |  |  |  |  |  | 634 |  |  | 634
Current tax assets |  |  |  |  |  |  |  |  |  | 356 | 356
Deferred tax assets |  |  |  |  |  |  |  |  |  | 587 | 587
Other assets |  |  |  |  |  |  |  |  | 2 | 4,924 | 4,926
Total assets | 34,633 | 270 | 78,966 | 367,179 | 55,059 | 9,925 | 1,378 | 634 | 856 | 63,869 | 612,768

ING Bank Annual Report 2024 214

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

> Notes to the parent company financial statements

Presentation Parent company financial statements versus Consolidated financial statements, Liabilities
in EUR million | Parent company statement of financial position
Liabilities as at 31 December 2024 | Deposits from banks | Customer deposits | Debt securities in issue | Other liabilities | Provisions | Senior non- preferred debt | Subordinated loans | Total
Included in Consolidated statement of financial position: |  |  |  |  |  |  |  |
Deposits from banks | 26,617 |  |  |  |  |  |  | 26,617
Customer deposits |  | 355,491 |  |  |  |  |  | 355,491
Financial liabilities at fair value through profit or loss |  |  |  |  |  |  |  |
– Trading liabilities | 2,190 | 3,206 |  | 44,151 |  |  |  | 49,547
– Non-trading derivatives |  |  |  | 14,019 |  |  |  | 14,019
– Designated as at fair value through profit or loss | 10,818 | 10,206 | 9,012 |  |  |  | 122 | 30,157
Current tax liabilities |  |  |  | 107 |  |  |  | 107
Deferred tax liabilities |  |  |  |  | 250 |  |  | 250
Provisions |  |  |  |  | 430 |  |  | 430
Other liabilities |  |  |  | 5,374 | 10 |  |  | 5,385
Debt securities in issue |  |  | 52,644 |  |  |  |  | 52,644
Senior non-preferred debt |  |  |  |  |  | 49,393 |  | 49,393
Subordinated loans |  |  |  |  |  |  | 17,739 | 17,739
Total liabilities | 39,625 | 368,903 | 61,656 | 63,651 | 691 | 49,393 | 17,861 | 601,778

ING Bank Annual Report 2024 215

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

Notes to the Parent company statement of financial position
2 Cash and balances with central banks
Amounts held at central banks amount to EUR 33,737 million ( 2023: EUR 50,668 million). In 2024, 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 270
million (2023: EUR 253 million) for the company.
4 Loans and advances to banks

Loans and advances to banks |  |
in EUR million | 2024 | 2023
Non-subordinated receivables from: |  |
Group companies | 34,124 | 36,387
Third parties | 41,328 | 32,588
| 75,453 | 68,975
Subordinated receivables from: |  |
Group companies | 3,513 | 2,955
| 78,966 | 71,930

As at 31 December 2024, Loans and advances to banks includes receivables with regard to securities, which
have been acquired in reverse repurchase transactions amounting to EUR 32,908 million (2023: EUR 23,682
million).
5 Loans and advances to customers

Loans and advances to customers |  |
in EUR million | 2024 | 2023
Non-subordinated receivables from: |  |
ING Groep N.V. | 67 | 51
Group companies | 29,533 | 31,135
Third parties | 336,177 | 313,514
| 365,776 | 344,701
Subordinated receivables from: |  |
Group companies | 1,403 | 1,404
| 367,179 | 346,104

As at 31 December 2024, receivables included in Loans and advances to customers that are part of the
trading portfolio amount to EUR 10,961 million ( 2023: EUR 10,837 million).
Loans and advances to customers includes receivables with regard to securities which have been acquired in
reverse repurchase transactions amounting to EUR 30,682 million (2023: EUR 23,625 million) for the
company.
6 Debt securities

Debt securities by issuer |  |
in EUR million | 2024 | 2023
Public sector | 33,522 | 32,343
Other | 21,537 | 16,328
| 55,059 | 48,671

ING Bank Annual Report 2024 216

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

> Notes to the parent company statement of financial position

Debt securities by listing |  |
in EUR million | 2024 | 2023
Listed | 41,760 | 38,424
Unlisted | 13,299 | 10,247
| 55,059 | 48,671

Debt securities includes the following non subordinated debt securities: |  |
in EUR million | 2024 | 2023
Non-subordinated debt securities issued by: |  |
Third parties | 54,184 | 47,701
| 54,184 | 47,701

Changes in debt securities 1 |  |
in EUR million | 2024 | 2023
Opening balance | 38,072 | 35,934
Additions | 27,616 | 16,605
Amortisation | -60 | -82
Changes in unrealised revaluations | -135 | 187
Disposals and redemptions | -25,275 | -14,655
Exchange rate differences | 891 | 0
Other changes | 46 | 83
Closing balance | 41,156 | 38,072

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

Equity securities by listing |  |
in EUR million | 2024 | 2023
Listed | 9,756 | 6,086
Unlisted | 169 | 193
| 9,925 | 6,279

Changes in equity securities at fair value through OCI |  |
in EUR million | 2024 | 2023
Opening balance | 1,778 | 1,808
Additions | 9 | 26
Changes in unrealised revaluations | 596 | 42
Disposals | -1 | -1
Exchange rate differences | 61 | -101
Other changes | 0 | 5
Closing balance | 2,444 | 1,778

The cost or purchase price of the shares in the trading portfolio of EUR 7,450 million (2023: EUR 4,460 million)
approximates their fair value . As at 31 December 2024 the cost or purchase price of shares excluding trading
portfolio is E UR 1,773 million lower ( 2023: EUR 1,119 million lower) than the carrying amount.
ING Bank Annual Report 2024 217

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

> Notes to the parent company statement of financial position
8 Investments in group companies

Investments in group companies |  |  |  |
in EUR million |  | 2024 |  | 2023
| Interest held (%) | Statement of financial position value | Interest held (%) | Statement of financial position value
ING Holding Deutschland GmbH | 100 | 10,457 | 100 | 10,097
ING Belgium S.A./N.V. | 100 | 9,388 | 100 | 9,069
ING Bank (Australia) Limited | 100 | 3,466 | 100 | 3,722
ING Financial Holdings Corporation | 100 | 3,378 | 100 | 3,064
ING Bank Slaski S.A. | 75 | 2,981 | 75 | 2,865
ING Bank A.S. | 100 | 573 | 100 | 531
ING Bank (Eurasia) JSC | 100 | 390 | 100 | 367
ING Corporate Investments B.V. | 100 | 58 | 100 | 212
ING Lease (Nederland) B.V. | 100 | 135 | 100 | 150
ING Hubs B.V. | 100 | 149 | 100 | 133
Other (including financing companies) |  | 779 |  | 830
|  | 31,753 |  | 31,040

As at 31 December 2024, Investments in group companies includes credit institutions of EUR 16,936 million
(2023: EUR 16,682 million).
As at 31 December 2024 listed investments in group companies amount to EUR 2,981 million (2023: EUR
2,865 million).

Changes in investments in group companies |  |
in EUR million | 2024 | 2023
Opening balance | 31,040 | 29,430
Repayment of capital injection | -33 | -225
Revaluations | -132 | 345
Results from group companies | 4,207 | 4,473
Dividends received | -4,745 | -2,841
Capital contribution 1 | 1,200 |
Mergers and liquidations | 3 | 26
Exchange rate differences | 209 | -157
Other changes | 4 | -10
Closing balance | 31,753 | 31,040

1 Capital contribution includes EUR 1.2 billion additional Tier 1 subordinated loan provided to ING Holding Deutschland GmbH.
9 Investments in associates and joint ventures

Investments in associates and joint ventures |  |
in EUR million |  | 2024 |  | 2023
| Interest held (%) | Statement of financial position value | Interest held (%) | Statement of financial position value
TMBThanachart Bank Public Company | 23 | 1,266 | 23 | 1,128
Other |  | 111 |  | 115
|  | 1,378 |  | 1,243

ING Bank Annual Report 2024 218

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

> Notes to the parent company statement of financial position

Changes in investments in associates and joint ventures |  |
in EUR million | 2024 | 2023
Opening balance | 1,243 | 1,240
Additions | 6 | 26
Share of results | 115 | 122
Dividends received | -70 | -62
Disposals | 0 | -50
Impairments | -3 | -5
Revaluations | 0 | 6
Exchange rate differences | 87 | -35
Other changes | 0 |
Closing balance | 1,378 | 1,243

10 Intangible assets

Changes in intangible assets
|  | Goodwill |  | Software |  | Other |  | Total
in EUR million | 2024 | 2023 | 2024 | 2023 | 2024 | 2023 | 2024 | 2023
Opening balance | 119 | 114 | 461 | 449 | 2 | 2 | 582 | 565
Additions |  |  | 206 | 174 |  |  | 206 | 174
Disposals |  |  | -10 | -6 |  |  | -10 | -6
Amortisation |  |  | -140 | -148 | 0 | 0 | -140 | -148
Impairments |  |  | -6 | -3 |  |  | -6 | -3
Exchange rate differences | 1 | 5 | 0 | 0 | 0 | 0 | 1 | 5
Other changes |  |  | 0 | -5 | 0 |  | 0 | -5
Closing balance | 120 | 119 | 512 | 461 | 1 | 2 | 634 | 582

Goodwill is tested for impairment annually.
11 Property and equipment

Changes in property and equipment |  |
in EUR million | 2024 | 2023
Opening balance | 783 | 828
Additions | 219 | 162
Depreciation | -181 | -170
Disposals | -5 | -36
Impairments | -5 | -2
Reversal of impairments | 1 | 0
Exchange rate differences | 4 | 0
Other changes | 40 | 0
Closing balance | 856 | 783
Gross carrying amount as at 31 December | 2,032 | 1,922
Accumulated depreciation as at 31 December | -1,176 | -1,139
Net carrying value | 856 | 783

Property and equipment includes EUR 5 million (2023: EUR 7 million) cumulative revaluation surplus.
12 Other assets

Other assets |  |
in EUR million | 2024 | 2023
Derivatives | 58,003 | 58,783
Deferred tax assets | 587 | 701
Income tax receivables | 356 | 189
Pension asset | 445 | 454
Other receivables | 3,995 | 3,719
| 63,385 | 63,845

Derivatives includes transactions with group companies of EUR 32,333 million (2023: EUR 36,984 million).
Other receivables includes EUR 2,434 million ( 2023: EUR 2,477 million) related to transactions still to be
settled at balance sheet date. As at 31 December 2024, an amount of EUR 676 million (2023: EUR 589
million) is expected to be settled after more than one year from the balance sheet date.
ING Bank Annual Report 2024 219

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

> Notes to the parent company statement of financial position
13 Deposits from banks

Deposits from banks by counterparty |  |
in EUR million | 2024 | 2023
Group companies | 18,081 | 13,798
Third parties | 21,543 | 24,770
| 39,625 | 38,569

14 Customer deposits

Customer deposits by counterparty |  |
in EUR million | 2024 | 2023
ING Groep N.V. | 8,583 | 12,187
Group companies | 9,088 | 10,596
Third parties | 351,232 | 334,464
| 368,903 | 357,248

Customer deposits by type |  |
in EUR million | 2024 | 2023
Current accounts / Overnight deposits | 126,337 | 122,536
Savings deposits | 161,578 | 152,655
Time deposits | 65,673 | 60,569
Other | 15,314 | 21,487
| 368,903 | 357,248

15 Debt securities in issue

Debt securities in issue by type |  |
in EUR million | 2024 | 2023
Long term bonds | 17,199 | 17,522
Covered bonds | 25,916 | 22,384
Commercial paper | 14,825 | 19,249
Other | 3,716 | 2,199
| 61,656 | 61,355

16 Other liabilities

Other liabilities |  |
in EUR million | 2024 | 2023
Derivatives | 55,325 | 59,855
Trading liabilities | 2,845 | 2,342
Costs payable | 876 | 991
Income tax payable | 107 | 169
Other taxation and social security contribution | 195 | 130
Other amounts payable | 4,303 | 5,378
| 63,651 | 68,865

Derivatives includes transactions with group companies of EUR 32,131 million (2023: EUR 39,372 million).
Other amounts payable includes EUR 2,817 million (2023: EUR 3,752 million) related to transactions still to be
settled at balance sheet date. As at 31 December 2024, an amount of EUR 208 million (2023: EUR 61 million)
is expected to be settled after more than one year from the balance sheet date.
17 Provisions

General provisions |  |
in EUR million | 2024 | 2023
Deferred tax liabilities | 250 | 169
Pension liabilities and other staff-related liabilities | 10 | 15
Reorganisations and relocations | 101 | 124
Other | 329 | 475
| 691 | 782

As at 31 December 2024, an amount of EUR 291 million (2023: EUR 238 million) is expected to be settled
after more than one year from the balance sheet date.
18 Senior non-preferred debt
All senior non-preferred debt instruments are loans from ING Groep N.V. The average interest rate of Senior
non-preferred debt with a maturity of more than 1 year is 3.3% (2023: 2.7%).
ING Bank Annual Report 2024 220

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

> Notes to the parent company statement of financial position
19 Subordinated loans

Subordinated loans by group companies and third parties |  |
in EUR million | 2024 | 2023
ING Groep N.V. | 18,523 | 16,328
Third parties including value changes hedged part loans | -663 | -833
| 17,861 | 15,494

Subordinated loans by type |  |
in EUR million | 2024 | 2023
Capital debentures | 2 | 3
Private loans | 17,858 | 15,492
| 17,861 | 15,494

The subordinated loans rank subordinated to the other liabilities in a winding-up of ING Bank.
The average interest rate of subordinated loans with a maturity of more than 1 year is 4.5% (2023: 4.0%).
20 Equity

Equity |  |
in EUR million | 2024 | 2023
Share capital | 525 | 525
Share premium | 16,542 | 16,542
Revaluation reserves | 717 | -181
Legal and statutory reserves | -639 | -557
Other reserves | 21,256 | 22,398
Unappropriated result | 4,342 | 1,465
Total equity | 42,743 | 40,191

Share capital |  |  |  |
| Ordinary shares (par value EUR 1.13)
| Number x 1,000 | Amount in EUR million
| 2024 | 2023 | 2024 | 2023
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 2024 and 2023.
ING Bank has 50 authorised preference shares with par value of EUR 1.13 per preference share. As at 31
December 2024, 7 preference shares were issued and fully paid (2023: 7 preference shares) amounting to
EUR 8 ( 2023: EUR 8).
ING Bank Annual Report 2024 221

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

> Notes to the parent company statement of financial position

Changes in revaluation reserves |  |  |  |  |  |  |
in EUR million |  |  |  |  |  |  |
2024 | 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 | 27 | 1,119 | -208 | -1,142