ING GROEP NV

ING Group’s activities involve transactions with various structured entities (SE) in the normal course of its business.

A structured entity is an entity that has been designed so that voting or similar rights are not the dominant factor

in deciding who controls the entity, such as when any voting rights relate to administrative tasks only and the

relevant activities are directed by means of contractual arrangements. ING Group’s involvement in these entities

varies and includes both debt financing and equity financing of these entities as well as other relationships. Based

on its accounting policies, ING establishes whether these involvements result in no significant influence, significant

influence, joint control or control over the structured entity.

The structured entities over which ING can exercise control are consolidated. ING may provide support to these

consolidated structured entities as and when appropriate. However, this is fully reflected in the consolidated

financial statements of ING Group as all assets and liabilities of these entities are included and off-balance sheet

commitments are disclosed.

ING’s activities involving structured entities are explained below in the following categories:

1. Consolidated ING originated securitisation programmes;

2. Consolidated ING originated Covered bond programme (CBC);

3. Consolidated ING sponsored Securitisation programme (Mont Blanc);

4. Unconsolidated Securitisation programme; and

5. Other structured entities.

6. Consolidated ING originated securitisation programmes

ING Group enters into liquidity management securitisation programmes in order to obtain funding and improve

liquidity. Within the programme ING Group sells ING-originated assets to a structured entity. The underlying

exposures include residential mortgages and SME loans in the Netherlands, Belgium, Spain, Italy, Australia and

Germany.

The structured entity issues securitised notes (traditional securitisations) which are eligible collateral for central

bank liquidity purposes. In most programmes ING Group acts as investor of the securitised notes. ING Group

continues to consolidate these structured entities if it is deemed to control the entities.

The structured entity issues securitisation notes in two or more tranches, of which the senior tranche obtains a

high rating (AAA or AA) by a rating agency. The retained tranche can subsequently be used by ING Group as

collateral in the money market for secured borrowings.

ING Group originated various securitisations, and as at 31 December 2025, these consisted of EUR 76 billion (2024:

EUR 74 billion) of senior and subordinated notes, of which EUR 4 billion (2024: EUR 4 billion) were issued externally.

The underlying exposures are residential mortgages and SME loans. Apart from the third party funding, these

securitisations did not impact ING Group’s Consolidated statement of financial position and profit or loss.

In 2025, there are no non-controlling interests as part of the securitisation structured entities that are significant

to ING Group.

2. Consolidated ING originated covered bond programme (CBC)

ING Group has entered into a covered bond programme. Under the covered bond programme, ING issues bonds.

The payment of interest and principal is guaranteed by the ING administered structured entities presented in table

below. In order for these entities to fulfil their guarantee, ING legally transfers mainly mortgage loans originated

by ING. Furthermore, ING offers protection against deterioration of the mortgage loans. The entities are

consolidated by ING Group.

For the covered bond programme, third-party investors in securities issued by the structured entity have recourse

to the assets of the entity and to the assets of ING Group.

3. Consolidated ING sponsored Securitisation programme (Mont Blanc)

In the normal course of business, ING Group structures financing transactions for its clients by assisting them in

obtaining sources of liquidity by selling the clients’ receivables or other financial assets to a Special Purpose Vehicle

(SPV). The senior positions in these transactions may be funded by the ING administered multi-seller Asset Backed

Commercial Paper (ABCP) conduit Mont Blanc Capital Corp. (rated A-1/P-1). Mont Blanc Capital Corp. funds itself

externally in the ABCP markets.

ING Group facilitates these transactions by acting as administrative agent, swap counterparty and liquidity

provider to Mont Blanc Capital Corp. ING Group also provides support facilities (i.e. liquidity) backing the

transactions funded by the conduit. The types of asset currently in the Mont Blanc conduit include trade

receivables, consumer finance receivables, car leases.

ING Group supports the ABCP programmes by providing Mont Blanc Capital Corp. with short-term liquidity facilities.

Once drawn these facilities bear normal credit risk.

The liquidity facilities provided to Mont Blanc are EUR 4,800 million (2024: EUR 3,119 million). The drawn liquidity

amount isnil as at 31 December 2025 (2024: nil).

The standby liquidity facilities are reported under irrevocable facilities. All facilities, which vary in risk profile, are

granted to the Mont Blanc Capital Corp. subject to normal ING Group credit and liquidity risk analysis procedures.

The fees received for services provided and for facilities are charged subject to market conditions.

4. Unconsolidated Securitisation programmes

In 2013 ING transferred financial assets (mortgage loans) for an amount of EUR 2 billion to a special purpose

vehicle (SPV). The transaction resulted in full derecognition of the financial assets from ING’s statement of financial

position. Following this transfer ING continues to have two types of ongoing involvement in the transferred assets:

as counterparty to the SPE of a non-standard interest rate swap, which is recognised as a non-trading derivative,

and as servicer of the transferred assets. Service fee income recognised, for the role as administrative agent, in the

statement of profit or loss in 2025 amounted to EUR 1 million (2024: EUR 1 million). The cumulative income

recognised in profit or loss since derecognition amounts to EUR 21 million (2024: EUR 20 million).

In 2025, ING established two SPVs, which are Designated Activity Companies incorporated in Ireland, for the

purpose of significant risk transfer securitizations. ING transferred the credit risk on the selected diversified

portfolios of corporate loans without transferring the assets to the SPVs. Each SPV has issued a series of credit

linked notes varying in seniority of the referenced loans to the investors. Subsequently, SPVs provide a financial

guarantee to ING in respect of the referenced loans and, in return for a fee, are liable to make protection

payments to ING upon the occurrence of a credit event in relation to any of the referenced loans. As of 31

December 2025, credit linked notes held by third parties amounted to EUR 676 million (2024: nil) and funds raised

by the sale of the credit linked notes are deposited within ING as collateral for the credit protection. The associated

corporate loans were EUR 10 billion (2024: nil). The SPVs are not consolidated by ING because the third-party

investors have the exposure, or rights to all variability of returns of the entities. No assets are transferred to, or

income received from these entities and the credit linked notes are fully cash collateralized.

5. Other structured entities

In the normal course of business, ING Group enters into transactions with structured entities as counterparty.

Predominantly in its structured finance operations, ING can be instrumental in facilitating the creation of these

structured entity counterparties. These entities are generally not included in the consolidated financial statements

of ING Group, as ING facilitates these transactions as administrative agent by providing structuring, accounting,

funding, lending, and operation services.

ING Group offers various investment fund products to its clients. ING Group does not invest in these investment

funds for its own account nor acts as the fund manager.

45 Related parties