The following table presents the adjustments in fair value for financial assets and liabilities.


Adjustments in fair value on financial assets and liabilities
in EUR million	2025	2024
Deferred Day One Profit or Loss	-91	-94
Own Credit Adjustments	-57	-17
Bid/Offer	-130	-130
Model Risk	-48	-33
CVA	-88	-123
DVA	43	50
CollVA	-11	-3
FVA	-82	-64
Other Valuation Adjustments	3	2
Total Valuation Adjustments	-462	-412

Own Credit Adjustment

Own issued debt and structured notes that are designated at fair value through profit or loss are adjusted for ING’s

own credit risk by means of DVA.

Bid-Offer Adjustment

For positions priced based upon mid-market input parameters, Bid-Offer adjustments are required in order to

reflect the valuation of that position based on bid price or offer price. In practice this adjustment accounts for the

difference in valuation from ‘mid to bid’ and ‘mid to offer’ for long and short exposures respectively. In principle,

assets are valued at the bid prices and liabilities are valued at the offer price. For certain assets or liabilities, where

a market-quoted price is not available, the price used is the fair value that is most representative within the bid-

offer spread.

Model Risk Adjustment

Financial instruments that are valued using a valuation model can be subject to model risk. Model risk is the risk of

possible financial loss resulting from a pricing model or model-based parameter deficiencies and/or uncertainties.

Bilateral Valuation Adjustments (Credit and Debit Valuation Adjustments)

Bilateral Valuation Adjustment is the valuation adjustment reflecting the counterparty credit risk of derivative

contracts. It has a bilateral nature, where both the counterparty’s credit risk (i.e. Credit Valuation Adjustment or

CVA) and ING’s own credit risk (Debit Valuation Adjustment or DVA) are taken into account:

§CVA is the fair value adjustment applicable to derivative instruments to account for the possibility that the

counterparty defaults (i.e. it is the market value of the counterparty’s credit risk).

§DVA is the fair value adjustment applicable to derivative instruments to account for the possibility that ING

defaults (i.e. it is the market value of ING’s credit risk).

The calculation of CVA and DVA on derivatives is based on their expected exposures, and the counterparties’ and

ING’s risk of default, taking into account the collateral agreements as well as netting agreements. The

counterparties’ risk of default is measured by probability of default and expected loss given default, which is based

on market information including credit default swap (CDS) spreads. Where counterparty CDS spreads are not

available, relevant proxy spreads are used. Additionally, wrong-way risk (which occurs when the probability of

default by the counterparty increases or decreases when ING’s exposure to the counterparty increases

(decreases)) and right-way risk (which occurs when the probability of default by the counterparty increases

(decreases) when ING’s exposure to the counterparty decreases (increases)) are included in the adjustment.

Collateral Valuation Adjustment (CollVA)

Collateral Valuation Adjustment is a fair valuation adjustment applied on derivative instruments to capture specific

features of CSA (Credit Support Annex) with a counterparty that the regular OIS discounting framework does not

capture. Non-standard CSA features may include deviations in relation to the currencies in which ING posts or

receives collateral, deviations in the remuneration rate on collateral which may pay lower or higher rate than the

overnight rate or even no interest at all; other deviations can be posting securities rather than cash as collateral.

Funding Valuation Adjustment (FVA)

Funding Valuation Adjustment (FVA) is a fair valuation adjustment applied on derivative instruments to address

the asymmetry in funding costs or funding benefits between collateralised and uncollateralised derivative

portfolios. This adjustment is based on the expected exposure profiles of the uncollateralised or partially

collateralised OTC derivatives and market-based funding spreads.

Other Valuation Adjustments

This pertains to other valuation adjustments that are immaterial to ING. Most of the balance consists of the Market

Price Uncertainty (MPU) adjustment in fair value, which accounts for the price uncertainty risk inherent in the

valuation inputs to fair value.

d) Fair value hierarchy

ING Group has categorised its financial instruments that are either measured in the statement of financial position

at fair value or of which the fair value is disclosed, into a three level hierarchy based on the observability of the

valuation inputs. Highest priority is retained to unadjusted quoted prices in active markets for identical assets or

liabilities and the lowest priority to valuation techniques supported by unobservable inputs.

Transfers into and transfers out of fair value hierarchy levels are made on a quarterly basis at the end of the

reporting period.

Level 1 – (Unadjusted) quoted prices in active markets

This category includes financial instruments whose fair value is determined directly by reference to (unadjusted)

quoted prices in an active market. A financial instrument is regarded as quoted in an active market if quoted prices

are readily and regularly available from an exchange, dealer markets, brokered markets, or principal to principal

markets. Those prices represent actual and regularly occurring market transactions with sufficient frequency and

volume to provide pricing information on an ongoing basis. Transfers out of Level 1 into Level 2 or Level 3 occur

when ING Group establishes that markets are no longer active and therefore (unadjusted) quoted prices no longer

provide reliable pricing information.

Level 2 – Valuation technique supported by observable inputs

This category includes financial instruments whose fair value is based on market observable inputs, either directly

or indirectly, other than quoted prices included within Level 1. The fair value for financial instruments in this

category can be determined by reference to quoted prices for similar instruments in active markets, quoted prices

for identical or similar instruments in markets that are not active, inputs other than quoted prices that are

observable or market-corroborated inputs. ING analyses how the prices are derived and determines whether the

prices are liquid tradable prices or model-based consensus prices taking various data as inputs.

For financial instruments that do not have a reference price available, fair value is determined using a valuation

technique (e.g., a model), where inputs in the model are taken from an active market or are observable, such as

interest rates and yield curves observable at commonly quoted intervals, implied volatilities, and credit spreads.

Instruments where inputs are unobservable are classified in this category, provided that the impact of those

unobservable inputs on the overall valuation is insignificant. The notion of significant is particularly relevant for the

distinction between Level 2 and Level 3 assets and liabilities, as the significance assessment of the valuation input

on the entire fair value measurement will determine whether the instrument should be classified as Level 2 or

Level 3. Expert judgement is required on the significance assessment approach.

Level 3 – Valuation technique supported by unobservable inputs

This category includes financial instruments whose fair value is determined using a valuation technique for which

a significant part of the overall valuation is driven by unobservable valuation inputs. Where valuation inputs are

unobservable, the Group must use the best information available to value the instruments. This may require

internally derived inputs taking into account market participants' assumptions that are reasonably available,

including assumptions on the risk inherent in a particular valuation technique used to measure fair value and the

risk inherent in the inputs to the valuation technique. Unobservable inputs may include, among others, volatility,

correlation, spreads to discount rates, default rates, recovery rates, prepayment rates, and certain credit spreads.

Financial instruments at fair value

The fair values of the financial instruments were determined as follows:


Methods applied in determining fair values of financial assets and liabilities (carried at fair value)
	Level 1		Level 2		Level 3		Total
in EUR million	2025	2024	2025	2024	2025	2024	2025	2024
Financial Assets
Financial assets at fair value through profit or loss
- Equity securities	21,392	20,789	4	15	187	141	21,583	20,945
- Debt securities	6,492	7,485	2,793	4,596	1,934	3,505	11,219	15,586
- Derivatives	52	1	25,178	31,792	773	475	26,003	32,268
- Loans and receivables	0	0	65,811	62,168	8,542	6,614	74,352	68,782
	27,937	28,275	93,785	98,571	11,435	10,734	133,157	137,580
Financial assets at fair value through other comprehensive income
- Equity securities	2,301	2,292	0	0	307	270	2,607	2,562
- Debt securities	49,529	39,859	1,288	2,360	0	0	50,817	42,219
- Loans and receivables	0	0	3,238	1,608	0	0	3,238	1,608
	51,829	42,151	4,526	3,967	307	270	56,662	46,389
Financial liabilities
Financial liabilities at fair value through profit or loss
– Debt securities	1,540	1,455	7,284	8,445	15	67	8,839	9,966
– Deposits	0	0	47,120	45,014	0	0	47,120	45,014
– Trading securities	2,534	3,631	11	12	9	10	2,554	3,653
– Derivatives	152	45	21,090	27,528	777	694	22,019	28,267
	4,226	5,131	75,505	80,998	802	770	80,532	86,900

The following methods and assumptions were used by ING Group to estimate the fair value of the financial

instruments:

Equity securities

Instrument description: Equity securities include stocks and shares, corporate investments and private equity

investments.

Valuation: If available, the fair values of publicly traded equity securities and private equity securities are based on

quoted market prices. In the absence of active markets, fair values are estimated by analysing the investee’s

financial position, result, risk profile, prospect, price, earnings comparisons and revenue multiples. Additionally,

reference is made to valuations of peer entities where quoted prices in active markets are available. For equity

securities, best market practice will be applied using the most relevant valuation method. All non-listed equity

investments, including investments in private equity funds, are subject to a standard review framework which

ensures that valuations reflect the fair values.

Fair value hierarchy: The majority of equity securities are publicly traded, and quoted prices are readily and

regularly available. Hence, these securities are classified as Level 1. Equity securities which are not traded in active

markets mainly include corporate investments, fund investments and other equity securities and are classified as

Level 3.

Debt securities

Instrument description: Debt securities include government bonds, financial institutions bonds and Asset-backed

securities (ABS).

Valuation: Where available, fair values for debt securities are generally based on quoted market prices. Quoted

market prices are obtained from an exchange market, dealer, broker, industry group, pricing service, or regulatory

service. The quoted prices from non-exchange sources are reviewed on their tradability of market prices. If quoted

prices in an active market are not available, fair value is based on an analysis of available market inputs, which

include consensus prices obtained from one or more pricing services. Furthermore, fair values are determined by

valuation techniques discounting expected future cash flows using market interest rate curves, referenced credit

spreads, maturity of the investment, and estimated prepayment rates where applicable.

Fair value hierarchy: Government bonds and financial institution bonds are generally traded in active markets.

Where quoted prices are readily and regularly available, they are classified as Level 1. The remaining positions are

classified as Level 2 or Level 3 depending on the trading activity and observability of prices. Asset backed securities

for which no active market is available and a wide discrepancy in quoted prices exists, are classified as Level 3.

Derivatives

Instrument description: Derivative contracts can either be exchange-traded or over the counter (OTC). Derivatives

include interest rate derivatives, FX derivatives, credit derivatives, equity derivatives and commodity derivatives.

Valuation: The fair value of exchange-traded derivatives is determined using quoted market prices in an active

market and are classified as Level 1 of the fair value hierarchy. For instruments that are not actively traded, fair

values are estimated based on valuation techniques. OTC derivatives and derivatives trading in an inactive market

are valued using valuation techniques. The valuation techniques and inputs depend on the type of derivatives and

the nature of the underlying instruments. The principal techniques used to value these instruments are based on,

among others, discounted cash flows, option pricing models and Monte Carlo simulations. These valuation models

calculate the present value of expected future cash flows, based on ‘no-arbitrage’ principles. The models are

commonly used in the financial industry and inputs to the validation models are determined from observable

market data where possible. Certain inputs may not be observable in the market, but can be determined from

observable prices via valuation model calibration procedures. These inputs include prices available from

exchanges, dealers, brokers or providers of pricing, yield curves, credit spreads, default rates, recovery rates,

dividend rates, volatility of underlying interest rates, equity prices, and foreign currency exchange rates and

reference is made to quoted prices, recently executed trades, independent market quotes and consensus data,

where available. For uncollateralised OTC derivatives, ING applies Credit Valuation Adjustment to correctly reflect

the counterparty credit risk in the valuation and Debit Valuation Adjustments to reflect the credit risk of ING for its

counterparty. In addition, for these derivatives ING applies Funding Valuation Adjustment. See sections CVA/DVA

and FVA in section c) Valuation Adjustments for more details regarding the calculation.

Fair value hierarchy: The majority of the derivatives are priced using observable inputs and are classified as Level

2. Derivatives for which the input cannot be implied from observable market data are classified as Level 3.

Loans and receivables

Instrument description: Loans and receivables are non-derivative financial assets with fixed or determinable

payments that are not quoted in an active market. Loans and receivables carried at fair value include trading

loans, being securities lending and similar agreement comparable to collateralised lending, syndicated loans, loans

expected to be sold and receivables with regards to reverse repurchase transactions.

Valuation: The fair value of loans and receivables is generally estimated by discounting expected future cash flows

using a discount rate that reflects credit risk, liquidity, and other current market conditions. The fair value of

mortgage loans is estimated by taking into account prepayment behaviour.

Fair value hierarchy: Loans and receivables are predominantly classified as Level 2. Loans and receivables for

which current market information about similar assets to use as observable, corroborated data for all significant

inputs into a valuation model is not available, are classified as Level 3.

Financial liabilities at fair value through profit and loss

Instrument description: Financial liabilities at fair value through profit and loss include debt securities and debt

instruments, primarily comprised of structured notes, which are held at fair value under the fair value option.

Besides that, they include derivative contracts and repurchase agreements.

Valuation: The fair values of securities in the trading portfolio and other liabilities at fair value through profit or loss

are based on quoted market prices, where available. For those securities not actively traded, fair values are

estimated based on internal discounted cash flow valuation techniques using interest rates and credit spreads that

apply to similar instruments.

Fair value hierarchy: The majority of the derivatives and debt instruments are classified as Level 2. Derivatives and

debt instruments for which the input cannot be derived from observable market data are classified as Level 3.

e) Transfers between Level 1 and 2

As a consequence of change in observable inputs, ING recorded for financial assets measured at fair value through

profit or loss a EUR 0.3 billion (2024: nil) transfer from Level 1 to Level 2 and a EUR 0.4 billion (2024: EUR 0.8 billion)

transfer from Level 2 to Level 1 within debt securities. For financial liabilities measured at fair value through profit

or loss, EUR 0.2 billion (2024: nil) of trading securities were transferred from Level 2 to Level 1. No other significant

transfers between Level 1 and Level 2 were recorded during the 2025 reporting period (2024: nil).

f) Level 3: Valuation techniques and inputs used

Financial assets and liabilities in Level 3 include both assets and liabilities for which the fair value was determined

using (i) valuation techniques that incorporate unobservable inputs as well as (ii) quoted prices which have been

adjusted to reflect that the market was not actively trading at or around the balance sheet date. Unobservable

inputs are inputs which are based on ING’s own assumptions about the factors that market participants would use

in pricing an asset or liability, developed based on the best information available in the circumstances.

Unobservable inputs may include volatility, correlation, spreads to discount rates, default rates and recovery rates,

prepayment rates, and certain credit spreads. Valuation techniques that incorporate unobservable inputs are

sensitive to the inputs used.

Of the total amount of financial assets classified as Level 3 as at 31 December 2025 of EUR 11.7 billion (2024: EUR

11.0 billion), an amount of EUR 10.1 billion (86.2%) (2024: EUR 9.6 billion, being 87.2%) is based on unadjusted

quoted prices in inactive markets. As ING does not generally adjust quoted prices using its own inputs, there is no

significant sensitivity to ING’s own unobservable inputs.

Furthermore, Level 3 financial assets include EUR 0.1 billion (2024: EUR 0.1 billion) which relates to financial assets

that are part of structures that are designed to be fully neutral in terms of market risk. Such structures include

various financial assets and liabilities for which the overall sensitivity to market risk is insignificant. Whereas the

fair value of individual components of these structures may be determined using different techniques and the fair

value of each of the components of these structures may be sensitive to unobservable inputs, the overall

sensitivity is by design not significant.

The remaining EUR 1.5 billion (2024: EUR 1.3 billion) of the fair value classified in Level 3 financial assets is

established using valuation techniques that incorporate certain inputs that are unobservable.

Of the total amount of financial liabilities classified as Level 3 as at 31 December 2025 of EUR 0.8 billion (2024: EUR

0.8 billion), an amount of EUR 0.6 billion (72.7%) (2024: EUR 0.6 billion, being 75.7%) is based on unadjusted quoted

prices in inactive markets. As ING does not generally adjust quoted prices using its own inputs, there is no

significant sensitivity to ING’s own unobservable inputs.

Furthermore, Level 3 financial liabilities include EUR 0.1 billion (2024: EUR 0.1 billion) which relates to financial

liabilities that are part of structures that are designed to be fully neutral in terms of market risk. As explained

above, the fair value of each of the components of these structures may be sensitive to unobservable inputs, but

the overall sensitivity is by design not significant.

The remaining EUR 0.1 billion (2024: EUR 0.1 billion) of the fair value classified in Level 3 financial liabilities is

established using valuation techniques that incorporates certain inputs that are unobservable.

The table below provides a summary of the valuation techniques, key unobservable inputs and the lower and

upper range of such unobservable inputs, by type of Level 3 asset/liability. The lower and upper range mentioned

in the overview represent the lowest and highest variance of the respective valuation input as actually used in the

valuation of the different financial instruments. Amounts and percentages stated are unweighted. The range can

vary from period to period subject to market movements and change in Level 3 position. Lower and upper bounds

reflect the variability of Level 3 positions and their underlying valuation inputs in the portfolio, but do not

adequately reflect their level of valuation uncertainty. For valuation uncertainty assessment, reference is made to

section Sensitivity analysis of unobservable inputs (Level 3).


Valuation techniques and range of unobservable inputs (Level 3)
	Assets		Liabilities		Valuation techniques	Significant unobservable inputs	Lower range		Upper range
In EUR million	2025	2024	2025	2024			2025	2024	2025	2024
At fair value through profit or loss
Debt securities	1,934	3,504	9	10	Price based	Price (%)	0%	0%	103%	120%
						Price (price per share)	201	327	412	520
					Present value techniques	Price (%)	n.a.	95.85%	n.a.	100%
Equity securities	187	141			Price based	Price (price per share)	0	0	5,475	5,475
Loans and advances	1,978	1,565	0	0	Price based	Price (%)	0%	0%	109%	107%
					Present value techniques	Credit spread (bps)	120	576	709	629
						Prepayment rate (%)	2%	2%	2%	100%
(Reverse) repos	6,563	5,050			Present value techniques	Interest rate (%)	n.a.	2%	n.a.	2%
Structured notes			15	67	Price based	Price (%)	96%	93%	103%	104%
					Option pricing model	Equity volatility (%)	18%	n.a.	22%	n.a.
						Equity/Equity correlation	0.7	0.7	0.8	0.7
						Equity/FX correlation	-0.6	n.a.	0.2	n.a.
						Dividend yield (%)	0.4%	n.a.	1.9%	n.a.
					Present value techniques	Prepayment rate (%)	n.a.	99.59%	n.a.	100.09%
Derivatives
– Rates	628	413	670	389	Option pricing model	Interest rate volatility (bps)	45	n.a.	91	n.a.
					Present value techniques	Reset spread (%)	1%	2%	1%	2%
– FX	2	6	4	8	Option pricing model	Implied volatility (%)	1.7%	2%	42%	15%
– Credit	134	39	48	241	Present value techniques	Credit spread (bps)	10	0	88	91
					Price based	Price (%)	0%	0%	100%	100%
– Equity	7	10	46	47	Option pricing model	Equity volatility (%)	13%	7%	75%	81%
						Equity/Equity correlation	0.0	0.0	1.0	1.0
						Equity/FX correlation	-0.7	-0.6	0.5	0.6
						Dividend yield (%)	0%	0%	51%	33%
– Other	2	6	10	9	Option pricing model	Commodity volatility (%)	20%	13.1%	76%	61%
						Com/FX correlation	-0.25	-0.40	-0.25	-0.25
					Price based	Price (commodity)	66	68	66	68
At fair value through other comprehensive income
– Equity	307	270			Present value techniques	Credit spread (bps)	5.15	5.67	5.15	5.76
						Interest rate (%)	2.5%	1.5%	2.5%	3.5%
						Payout ratio (%)	70%	70%	90%	90%
					Price based	Price (%)	n.a.	122%	n.a.	122%
						Price (price per share)	126	n.a	126	n.a
Total	11,742	11,005	802	770

1The abbreviation n.a. stands for not applicable or not available.

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.

Level 3: Changes during the period


Changes in Level 3 Financial assets
	Trading assets		Non-trading derivatives		Financial assets mandatorily at FVPL		Financial assets designated at FVPL		Financial assets at FVOCI		Total
	Trading assets		Non-trading derivatives		Financial assets mandatorily at FVPL		Financial assets designated at FVPL		Financial assets at FVOCI		Total
In EUR million	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024
Opening balance as at 1 January	824	848	68	286	5,721	3,499	4,121	3,547	270	938	11,005	9,118
Realised gain/loss recognised in the statement of profit or loss during the period 1	247	-175	63	-38	211	294	-798	-54			-278	28
Revaluation recognised in other comprehensive income during the period 2									8	-3	8	-3
Purchase of assets	953	486	0	198	5,177	4,424	1,208	1,600	182	154	7,520	6,862
Sale of assets	-109	-111	0	-257	-1,765	-1,605	-1,160	-10	-163	-418	-3,197	-2,402
Maturity/settlement	-128	-140	0	-7	-166	-294	-763	-988	0	-20	-1,057	-1,449
Reclassifications	0	0	-1	0	18	0	0	0	10	0	28	0
Transfers into Level 3	316	370	0	0	824	615	0	30	0	0	1,139	1,014
Transfers out of Level 3	-974	-454	-9	-114	-2,389	-1,214	0	-3	0	-384	-3,372	-2,169
Exchange rate differences	-14	0	0	0	-6	5	-33	-2	0	9	-53	12
Changes in the composition of the group and other changes	0	0	0	0	0	-1	0	0	0	-5	0	-6
Closing balance	1,114	824	121	68	7,625	5,721	2,576	4,121	307	270	11,742	11,005

1Net gains/losses were recorded as ‘Valuation results and net trading income’ in the statement of profit or loss. The total amounts includes EUR 280 million (2024: EUR -41 million) of unrealised gains and losses recognised in the statement of profit or loss.

2Revaluation recognised in other comprehensive income is included on the line ‘Net change in fair value of debt instruments at fair value through other comprehensive income’.

In 2025, transfers out of Level 3 within trading assets relate mainly to securities, as their valuations were no longer

significantly influenced by unobservable inputs. In 2024, transfers out of Level 3 in trading assets primarily

involved derivative instruments, as their valuations were no longer significantly impacted by unobservable inputs.

In 2025 and 2024, the transfer into Level 3 trading assets consisted of cross currency swap trades, which were

transferred to Level 3 as a result of the valuation being significantly impacted by unobservable inputs. In 2024, the

transfer out of Level 3 in non-trading derivatives primarily involved derivative instruments, as their valuations were

no longer significantly impacted by unobservable inputs.

In 2025 and 2024, transfers into and out of Level 3 of financial assets mandatorily at fair value mainly relate to

(long- term) reverse repurchase transactions for which the valuation being significantly impacted by unobservable

inputs and no longer significantly impacted by unobservable inputs, respectively.

In 2024, the transfer out of Level 3 of financial assets at FVOCI relates to Hold-to-Collect and Sell portfolio

transferred to Level 2 resulting from change in methodology.


Changes in Level 3 Financial liabilities
	Trading liabilities		Non-trading derivatives		Financial liabilities designated as at fair value through profit or loss		Total
	Trading liabilities		Non-trading derivatives				Total
in EUR million	2025	2024	2025	2024	2025	2024	2025	2024
Opening balance as at 1 January	637	382	67	301	67	47	770	729
Realised gain/loss recognised in the statement of profit or loss during the period1	81	-104	82	-98	-6	-5	157	-206
Additions	205	55	3	190	11	29	219	274
Redemptions	-74	-12	0	-209	0	0	-74	-222
Maturity/settlement	-160	-15	0	-7	-64	-4	-225	-26
Transfers into Level 3	19	364	0	0	19	34	38	399
Transfers out of Level 3	-72	-33	0	-111	-12	-34	-84	-179
Exchange rate differences	-1	0	0	0	0	0	-1	0
Closing balance	636	637	151	67	15	67	802	770

1Net gains/losses were recorded as ‘Valuation results and net trading income’ in the statement of profit or loss. The total amount includes EUR 158

million (2024: EUR -206 million) of unrealised gains and losses recognised in the statement of profit or loss.

In 2025, the transfers out of Level 3 mainly consisted of trading liabilities related to securities transferred out of

Level 3 as a result of the valuation being no longer impacted by significantly unobservable inputs.

In 2024, the transfers into Level 3 mainly consisted of trading liabilities attributed to cross currency swap trades

transferred into Level 3 as a result of the valuation being significantly impacted by unobservable inputs. The

transfers out of Level 3 for non-trading derivatives are driven by interest rate swap trades, which were reclassified

out of Level 3 as their valuations were no longer influenced by significantly unobservable inputs.

g) Recognition of unrealised gains and losses in Level 3

Amounts recognised in the statement of profit or loss relating to unrealised gains and losses during the year that

relate to Level 3 assets and liabilities are included in the line item ‘Valuation results and net trading income’ in the

statement of profit or loss.

h) Level 3: Sensitivity analysis of unobservable inputs

Where the fair value of a financial instrument is determined using inputs which are unobservable and which have

a more than insignificant impact on the fair value of the instrument, the actual value of those inputs at the

balance date may be drawn from a range of reasonably possible alternatives. In line with market practice, the

upper and lower bounds of the range of alternative input values reflect a level of valuation certainty. The actual

levels chosen for the unobservable inputs in preparing the financial statements are consistent with the valuation

methodology used for fair valued financial instruments.

In practice, valuation uncertainty is measured and managed per exposure to individual valuation inputs (i.e. risk

factors) at portfolio-level across different product categories. Where the disclosure looks at individual Level 3

inputs, the actual valuation adjustments may also reflect the benefits of portfolio offsets.

This disclosure does not attempt to indicate or predict future fair value movement. The numbers in isolation give

limited information as in most cases these Level 3 assets and liabilities should be seen in combination with other

instruments (for example as a hedge) that are classified as Level 2.

The valuation uncertainty in the table below is broken down by related risk class rather than by product. The

possible impact of a change of unobservable inputs in the fair value of financial instruments where unobservable

inputs are significant to the valuation is as follows:


Sensitivity analysis of Level 3 instruments
	Positive fair value movements from using reasonable possible alternatives		Negative fair value movements from using reasonable possible alternatives
in EUR million	2025	2024	2025	2024
Equity (equity derivatives, structured notes)	20	21	-12	-20
Interest rates (Rates derivatives, FX derivatives)	1	5	0	0
Credit (Debt securities, Loans, structured notes, credit derivatives)	12	2	-14	-27
Loans and advances	0	0	0	0
	33	28	-26	-47

i) Financial instruments not measured at fair value

The following table presents the estimated fair values of the financial instruments not measured at fair value in

the statement of financial position.


Methods applied in determining fair values of financial assets and liabilities (carried at amortised cost)
	Carrying Amount		Carrying amount presented as fair value1		Level 1		Level 2		Level 3		Total fair value
in EUR million	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024	2025	2024
Financial Assets
Loans and advances to banks	21,204	21,770	3,053	3,195			14,722	15,614	3,366	2,957	21,141	21,766
Loans and advances to customers	727,733	683,611	18,231	18,291			12,782	18,626	678,392	630,493	709,405	667,410
Securities at amortised cost	53,867	50,273			47,722	42,871	2,381	2,908	2,692	2,523	52,796	48,303
	802,804	755,655	21,284	21,486	47,723	42,871	29,885	37,149	684,450	635,973	783,342	737,479

Financial liabilities
Deposits from banks	18,517	16,723	5,401	4,348			9,162	8,208	3,745	3,943	18,308	16,499
Customer deposits	721,373	691,661	620,999	582,387			82,665	61,916	17,433	46,984	721,097	691,287
Debt securities in issue	151,231	142,367			84,506	79,254	64,028	61,651	3,857	2,000	152,391	142,905
Subordinated loans	18,100	17,878			18,368	17,968	354	389			18,722	18,357
	909,221	868,630	626,401	586,735	102,874	97,221	156,208	132,164	25,035	52,927	910,519	869,048

1In accordance with IFRS and for the purpose of this disclosure, the carrying amount of financial instruments with an immediate on demand feature is presented as fair value.

The aggregation of the fair values presented above does not represent, and should not be construed as

representing, the underlying value of ING Group. These fair values were calculated for disclosure purposes only.

The carrying amount of financial instruments presented in the above table includes, when applicable, the fair value

hedge adjustment.

Loans and advances to banks

For short-term receivables from banks, carrying amounts represent a reasonable estimate of the fair value. The

fair value of long-term receivables from banks is estimated by discounting expected future cash flows using a

discount rate based on specific available market data, such as interest rates and appropriate spreads, that reflects

current credit risk or quoted bonds.

Loans and advances to customers

For short-term loans, carrying amounts represent a reasonable estimate of the fair value. The fair value of long-

term loans is estimated by discounting expected future cash flows using a discount rate that reflects current credit

risk, current interest rates, and other current market conditions where applicable. The fair value of mortgage loans

is estimated by taking into account prepayment behaviour. Loans with similar characteristics are aggregated for

calculation purposes.

Securities at amortised cost

Where available, fair values for debt securities are generally based on quoted market prices. Quoted market prices

are obtained from an exchange market, dealer, broker, industry group, pricing service, or regulatory service. The

quoted prices from non-exchange sources are reviewed on their tradability of market prices. If quoted prices in an

active market are not available, fair value is based on an analysis of available market inputs, which include

consensus prices obtained from one or more pricing services. Furthermore, fair values are determined by valuation

techniques discounting expected future cash flows using market interest rate curves, referenced credit spreads,

maturity of the investment, and estimated prepayment rates where applicable.

Deposits from banks

For short-term payables to banks, carrying amounts represent a reasonable estimate of the fair value. The fair

value of long-term payables to banks is estimated by discounting expected future cash flows using a discount rate

based on available market interest rates and appropriate spreads that reflect ING’s own credit risk.

Customer deposits

There is an embedded value in our on-demand deposits. However, for the purpose of this disclosure, and in

accordance with IFRS, the fair value of deposits with an immediate on demand feature approximates the carrying

amount.