ING GROEP NV

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

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

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

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

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

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

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

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

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

the European Economic and Monetary Union. Unless otherwise specified or

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

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

ING prepares financial information in accordance with International

Financial Reporting Standards as issued by the International Accounting

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

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

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

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

described under Note '1.2 Basis of preparation of the Consolidated

financial statements’ in the consolidated financial statements. In this

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

ING Group.

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

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

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

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

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

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

‘Financial Instruments: Recognition and Measurement’ regarding hedge

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

Group applies fair value hedge accounting for portfolio hedges of interest

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

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

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

hedge ineffectiveness is only recognised when the revised estimate of the

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

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

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

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

macro hedges cannot be applied to core deposits and hedge

ineffectiveness arises whenever the revised estimate of the amount of

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

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

is prepared by reversing the hedge accounting impacts that are applied

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

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

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

have applied alternative hedge strategies where those alternative hedge

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

These decisions could have resulted in different shareholders’ equity and

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

Form 20-F.

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

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

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

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

information’ to the consolidated financial statements.

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

alternative performance measures, including resilient net profit,

commercial net interest income and net core lending and net core

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

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

commercial net interest income, and the derived commercial net interest

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

products that are mainly interest driven and excludes the interest on

products where performance measurement is primarily done based on fee

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

Treasury). Commercial net interest income also excludes significant

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

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

core deposits growth measures the development of ING’s customer

lending and deposits adjusted for currency impacts and changes in the

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

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

growth in customer balances.

For reconciliation of these alternative performance measures to the

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

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

Alternative performance measures.

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

to rounding.