Summary
- The paid unit is a digital bank account with app access and payment continuity: customers buy the ability to receive salary or revenue, hold deposits, initiate transfers, use cards and payment requests, pass fraud and compliance checks, obtain help when self-service fails, and keep those capabilities available when the first screen on the phone does not work.
- ING's own 2025 disclosures make the account look less like a static deposit product and more like an uptime business: the bank reported more than 15 million mobile primary customers, combined retail digital-channel availability of 99.89 percent for Belgium, Germany and the Netherlands, 99.97 percent availability for InsideBusiness Payments, and 99.99 percent for InsideBusiness Connect in the ING Bank N.V. annual report at https://ing.com/binaries/content/assets/documents/annual-reports/2025-ing-bank-nv-annual-report.pdf.
- The value case is strongest when digital access, daily banking fees, deposits, KYC work, fraud controls, and treasury connectivity are priced together; it is weakest where public evidence cannot show incident-level losses, customer-level retention, or the true cost of maintaining fallback capacity across a large European banking group.
- The substitutes are real but incomplete: a neobank account, a local bank account, a multi-bank treasury setup, a card wallet, cash, or delayed payment can reduce dependence on ING, yet each substitute gives up some mix of balance-sheet scale, local rails, cross-border corporate banking, compliance acceptance, relationship history, or operational fallback.
The paid unit starts when money cannot move
The digital-banking incident is a simple scene. A customer has money in an account but cannot get the app to load. A treasurer has approvals ready but cannot release a supplier payment before a cut-off. A parent is at a checkout and cannot see whether a card transaction has posted. In late 2024, public reporting on ING Australia described customers locked out of the app and website, unable to make payments and transfers during morning disruptions, with Downdetector reports peaking in the thousands and ING later saying most services were returning to normal. One report is at https://www.news.com.au/finance/business/banking/major-outage-hits-ing-australia-customers-just-weeks-after-last-disaster/news-story/7044a955eb22c22b436cf17226feebef, and another on the earlier October incident is at https://www.news.com.au/finance/money/ing-australia-website-app-offline-and-payments-delayed-amid-outage/news-story/6d935d4cee30fc7c5177f3b3be4a3a9f.
Those reports do not prove the root cause of any Dutch system, and they should not be stretched into a claim about ING Bank N.V.'s internal architecture. They do show why the account is the right economic unit. A customer does not experience a bank as a legal entity, a balance-sheet line, or a technology strategy. The customer experiences a paid account as the bundle that either lets money move or does not. That bundle contains the app, authentication, card and transfer rails, fraud checks, sanctions screening, customer records, contact channels, branch or remote-advice fallback, merchant-facing payment links, and the operational muscle to restore service under stress.
This matters for ING Bank N.V. because the group has intentionally made banking digital, mobile-first and cross-border. ING's public description of itself says more than 60,000 employees offer retail and wholesale banking services in more than 100 countries, with savings, payments, investments, loans, mortgages, payments and cash management, and trade and treasury services listed among the customer propositions at https://ing.com/about-us/ing-at-a-glance. That breadth is not a decorative fact. It means the same paid account promise has to be honoured across individual salary accounts, SME payment packages, private-banking relationships and wholesale portals. When digital access fails, the account is not merely inconvenient; the product loses the use for which the customer pays.
The bank's 2025 annual report gives the hard comparative anchor. ING defines a primary retail relationship as an active payment account with recurrent income plus at least one other active product. It reported that its mobile primary customer base grew by more than one million in 2025 and exceeded 15 million. For the Netherlands, Belgium and Germany, it reported combined retail digital-channel availability of 99.89 percent, up from 99.86 percent in 2024. For wholesale clients worldwide, it reported 99.97 percent availability for InsideBusiness Payments and 99.99 percent for InsideBusiness Connect. These are high numbers, but they also convert the account into an uptime problem. At 99.89 percent availability, the remaining fraction of time is the space in which a rent payment, salary file, supplier run or fraud review can become an operational incident for the customer.
The rest of the account price is hidden in the work needed to make the screen credible. ING says its ING Banking App lets private individuals open accounts, manage investments and receive spending insights; it says Mijn ING Zakelijk helps SMEs manage payments and link accounting packages; and it says InsideBusiness gives larger corporates self-service access to trade finance and cash management globally. Those claims sit in the same annual report as a discussion of private cloud infrastructure, a scalable technology platform, DDoS incidents reported to supervisors, operational resilience, cybersecurity, KYC, fraud controls and third-party risk. A useful account is therefore not cheap because it has a nice screen. It is expensive because the screen is the visible edge of payment rails, regulated controls, staff, data, vendors, recovery exercises and customer-service capacity.
What the customer is really buying
For a Dutch retail customer, a digital account starts with the basics: incoming salary or benefits, card payments, savings transfers, iDEAL-style online checkout, payment requests, balance visibility, identity verification, and a channel for help. For a small business, it adds salary payments, tax payments, supplier transfers, accounting links, direct debit handling and documentation that counterparties accept. For a wholesale client, it can become a treasury operating layer: account structures, cash management, trade finance, file transfer, multi-country service and access to a relationship bank in Amsterdam. ING's wholesale banking page for the Netherlands says it serves clients from medium-sized businesses to global corporations and provides international banking products in more than 35 countries from Amsterdam, at https://www.ingwb.com/en/network/emea/netherlands.
The account is paid for in more ways than a monthly package fee. Customers pay directly through daily-banking fees, card fees, transfer fees, account-service charges, payment-acceptance costs and sometimes subscription packages. They also pay indirectly by leaving deposits with the bank, taking mortgages or consumer loans, buying investment products, accepting foreign-exchange spreads, paying for lending commitments, and giving the bank more share of wallet as the relationship deepens. ING's annual report says retail daily-banking fees increased in 2025, supported by growth in primary customers and updated pricing for payment packages. It also says total group fee and commission income rose 15 percent in 2025, and Retail Banking fee and commission income rose 18 percent.
The paid unit is therefore a combined account-and-access product. The account is worth more when the app becomes the primary branch, when the customer's income and other products make the bank the main financial relationship, and when the customer would face friction moving direct debits, cards, salary instructions, payment requests, business invoices, accounting integrations, mortgage relationships or treasury mandates elsewhere. ING's strategy language is explicit about the value of primary relationships: it says primary relationships lead to deeper loyalty, higher engagement, greater satisfaction and ultimately higher value. The economic question is not whether digital banking is convenient. It is whether the customer receives enough continuity, control, recovery capacity and compliance acceptance to justify the direct fees, deposit relationship and switching cost.
The paid account also includes negative work the customer rarely wants to notice. A bank has to refuse some payments, delay some onboarding, ask for documents, block suspicious transactions, screen names, monitor transaction patterns, and close accounts when information is missing or risk is too high. ING's KYC page says financial-crime prevention is a key responsibility, that customer due diligence and transaction monitoring aim to stop misuse of the financial system, and that ING has around 4,000 people working on KYC-related activities globally. That page is at https://ing.com/about-us/compliance/kyc-and-anti-money-laundering-measures. This labour makes the account slower and more expensive than a simple wallet, but it also makes it acceptable to payroll departments, regulators, counterparties and larger customers that need a bank-grade relationship.
The customer also buys fallback. If self-service fails, somebody must pick up the phone, open a chat, handle a complaint, maintain a branch or adviser path, reset an authentication method, investigate a disputed payment, or tell a corporate client whether a file has been received. ING's annual report says it reduced inbound contacts to contact centres by 43 percent in 2025 as digital services expanded and self-service improved. That is a sign of efficiency, but it also raises the bar for resilience: the more routine work migrates into apps and chatbots, the more severe the customer impact when digital channels are degraded. The account is no longer a product that can quietly fall back to paper without cost.
The best way to price this paid unit is to break it into six components. First is deposit funding: the balances that customers keep at ING because the account is useful. Second is app and channel uptime: the availability and recovery capacity that let those balances remain spendable. Third is payment continuity: the rails and operational processes that move money when a customer needs it. Fourth is fraud and compliance labour: the screening, monitoring and evidence work that keeps the account usable in a regulated system. Fifth is infrastructure dependency: cloud, core-banking, vendor and file-transfer layers that can improve scale but increase third-party risk. Sixth is switching cost: the practical difficulty of moving salary, direct debits, merchant flows, accounting links, payment habits and advisory relationships to substitutes.
Why the unit is expensive
The first cost is scale. ING's 2025 report says it serves nearly 41 million private individual customers across ten retail markets: the Netherlands, Belgium, Luxembourg, Germany, Spain, Italy, Türkiye, Poland, Romania and Australia. It also says wholesale banking ran an NPS programme across 32 markets in 2025, with a 74 percent response rate and an NPS score of 77, while clients rated product offering, relationship management and client support highly. These numbers create operating leverage, but they also create a large surface over which technology failure, fraud, payment delay or compliance error can travel quickly.
The second cost is a channel mix in which digital is no longer optional. ING says it aims to serve customers through "always-on" channels, data-enabled personalised experiences and end-to-end digital processes with human intervention where needed or desired. It reports a digi index score of 81.8 percent in 2025, up from 77.2 percent in 2024, and says about 81 percent of customer logins used Touchpoint, compared with about 75 percent in 2024. These metrics imply a bank that is trying to reduce friction and cost-to-serve through self-service. They also imply a bank whose account value is increasingly exposed to log-in reliability, authentication stability, mobile-release quality, fraud-model false positives and the ability to route exceptions to human service without overwhelming staff.
The third cost is infrastructure. ING's annual report describes a "Scalable Tech Platform" made of modular components used across countries and business lines. It says its scalable technology includes ING's private cloud infrastructure, OnePipeline and a banking technology platform. It also says 68 percent of physical cores in ING data centres globally were on its private cloud infrastructure by the end of 2025, up slightly from 67 percent in 2024, and that the objective is to evolve toward a structural hybrid cloud set-up using private and public cloud solutions. The customer does not buy a cloud strategy. The customer buys the account staying available while the bank modernises, migrates, tests, patches, automates and integrates.
The fourth cost is regulatory resilience. DORA, the EU Digital Operational Resilience Act, applies from 17 January 2025 and treats ICT risk, incident reporting, resilience testing and third-party risk as core financial-sector obligations. The legal text is available at https://eur-lex.europa.eu/eli/reg/2022/2554/oj. DORA is relevant to ING's account economics because it makes technology resilience a regulated operating requirement rather than a marketing promise. The EBA's ICT and security risk guidelines, at https://www.eba.europa.eu/activities/single-rulebook/regulatory-activities/internal-governance/guidelines-ict-and-security-risk-management, similarly frame ICT risk management for credit institutions, investment firms and payment service providers. These rules increase the compliance cost of running an account, but they also make uptime and recovery part of the product customers are paying for.
The fifth cost is supervision. ING's own legal-structure page says ING Group is the parent of one main legal entity, ING Bank N.V.; that ING Bank is directly supervised by the European Central Bank as part of the Single Supervisory Mechanism; and that De Nederlandsche Bank remains responsible for areas not conferred to the ECB, including payment systems and financial-crime supervision. That page is at https://ing.com/about-us/corporate-governance/legal-structure-and-regulators. In practice, the account is sold under multiple layers of scrutiny. A bank can try to improve customer experience, but it cannot treat onboarding, payments, data, outsourcing or recovery as a lightly governed consumer app.
The sixth cost is systemic status. The Financial Stability Board's 2025 G-SIB list, at https://www.fsb.org/2025/11/2025-list-of-global-systemically-important-banks-g-sibs/, says the list includes 29 global systemically important banks and describes higher capital buffers, TLAC, resolvability and higher supervisory expectations for G-SIBs. ING appears in the G-SIB list. For account economics, that means customers are dealing with a bank whose scale can lower unit costs and broaden service, but whose governance and resilience obligations are heavier than those of a small local provider. The account price includes some of the cost of being a bank that regulators expect to survive severe stress.
The revenue side is not just spread income
ING still looks like a bank. Deposits, lending, net interest income, capital and credit risk matter. But the assigned account unit cannot be understood only through deposit funding or lending spread. ING's 2025 annual report says Retail Banking delivered result before tax of €6.554 billion and a 21.7 percent return on equity. It says net core lending growth was €38.6 billion and net core deposits growth was €30.1 billion. Those figures show why primary accounts are economically powerful: a customer who uses ING as the main account can bring deposit balances, borrowing, investment assets and fee events into the same relationship.
The Netherlands is especially important because it is the home market and a dense digital-banking market. Retail Netherlands posted result before tax of €2.773 billion in 2025, with net core lending growth of €16.2 billion and net core deposits growth of €11.5 billion, primarily driven by private individuals. Net fee and commission income in Retail Netherlands rose 7.5 percent, with growth across product categories and especially investment products. Those figures do not isolate the standalone margin on a Dutch digital account, but they show the account's role as a gateway into broader balances and products.
Retail Germany adds another signal. ING reported a double-digit increase in mobile primary customers in Germany in 2025, €6.6 billion of net core deposit growth and a 46 percent jump in net fee and commission income to €632 million, driven by a growing customer base, more investment accounts, increased trading activity and higher daily-banking fees. This is not Dutch evidence, but it is useful comparative evidence inside the same banking group. It shows how a digital direct-banking model can convert mobile-primary relationships into deposit inflows and fee growth when the proposition is working.
For wholesale clients, the economics are more connected to payment and treasury activity. ING's 2025 wholesale segment reported €7.009 billion of total income, €1.433 billion of net fee and commission income, and €1.887 billion of income from Daily Banking & Trade Finance. It said Payments & Cash Management faced margin compression, while net core deposits grew €8.0 billion, reflecting inflows in Payments & Cash Management and Financial Markets. A treasurer does not choose a bank account only for an app. The treasurer chooses whether a bank can move files, confirm cash positions, connect with internal treasury systems, support cross-border operations, manage cut-offs and provide help when a payment rail or portal has a problem.
The account's revenue case is therefore a layered case. Direct account fees matter, but they are only the visible price. Deposit margins, payment volumes, investment conversions, mortgage relationships, lending commitments, foreign exchange and advisory products make the account more valuable to the bank. The same layering makes outages costly. When an app is inaccessible, the bank may not immediately lose a monthly fee, but it can lose the customer's next product decision, the treasurer's willingness to route more volume through the bank, or the merchant's confidence that account-to-account payments will work under pressure.
This is where "trust" becomes a measurable business variable rather than a slogan. It decomposes into failure cost, compliance cost, switching cost, capacity constraint and renewal risk. Failure cost is the customer loss caused by a payment that cannot be sent, a card that cannot be checked, or a salary file that misses a deadline. Compliance cost is the friction and staff required to keep accounts acceptable to regulators and counterparties. Switching cost is the effort of moving the financial life elsewhere. Capacity constraint is the limit of contact centres, branches, engineers and recovery teams when digital self-service fails. Renewal risk is the chance that a corporate client or retail customer will keep balances but move the next important product to a substitute.
Reliability is measurable, but not fully explained
ING's 2025 availability figures are useful because they put a number on the digital account promise. Combined digital-channel availability of 99.89 percent for Belgium, Germany and the Netherlands means the service was available for nearly all measured time. It is materially better than many consumer digital services can guarantee publicly, and it sits beside 99.97 percent for InsideBusiness Payments. At the same time, the residual non-available time matters because banking incidents are time-sensitive. A ten-minute outage at a random hour is not the same as a ten-minute outage near payroll cut-off, tax deadline, settlement window or an urgent fraud call.
The public record also shows that incidents are not hypothetical. ING's annual report says two DDoS incidents were reported to supervisors in 2025: one affected availability for individuals in Belgium, Italy and the Netherlands, and another caused temporary interruptions in third-party service availability within the Polish mobile payment system. The report says the CISO organisation maintains 24/7 vigilance and monitors the environment, investigates threats and acts to protect customers and essential services. This is a valuable disclosure because it ties digital-channel availability to actual threat events, not just to abstract risk language.
Downdetector-style public data should be used carefully. The Netherlands ING status page at https://allestoringen.nl/en/status/ing/ is a market-signal source, not a formal incident log. It can show what users are reporting and which functions appear in complaint categories, such as mobile banking login, funds transfer, payment requests or iDEAL payment. It cannot prove root cause, severity, whether the bank was at fault, or the number of financially harmed customers. The right use is to treat it as an early reader of customer pain and a way to understand which account functions customers notice when something feels broken.
The Australian reports are similar. They are public accounts of customer interruption in an ING-branded retail market, not proof of ING Bank N.V.'s Dutch operational quality. They do, however, make the paid unit vivid. If a customer cannot access the app and website, "account balance" becomes a theoretical asset until another channel works. If scheduled payments or cards keep working while login is impaired, the incident is different from a full payment outage. If the bank warns about scammers exploiting the outage, the reliability issue immediately becomes a fraud-control and communications issue. A digital account incident does not remain inside engineering; it moves into customer service, social media, scam prevention and complaints.
For a treasurer, the reliability problem is more formal. Corporate payment work has time windows, approval chains, dual controls, audit trails and cut-offs. ING's InsideBusiness Payments and InsideBusiness Connect availability metrics are therefore central evidence. A payments portal that is available 99.97 percent of the time still has to prove that the remaining 0.03 percent does not cluster around the wrong moments, that recovery is fast, that file transfer alternatives exist, that customer support can identify which files are affected, and that bank statements and confirmations remain reconcilable after the incident. Public disclosures rarely provide that detail.
The fallback layer is also part of reliability. ING's local customer-service pages for individuals and business users, at https://www.ing.nl/particulier/klantenservice and https://www.ing.nl/zakelijk/klantenservice, show the public expectation that customers can seek help outside the main app flow. But fallback is not free. It requires trained staff, authentication procedures, complaint handling, technical escalation, fraud-aware messaging and enough capacity to handle surges. If a bank reduces inbound contact-centre volume by moving routine work to self-service, it has to preserve enough skilled capacity for the abnormal day.
The difficult point for customers is that high average availability does not reveal distribution. A customer cares about the payment moment, not the annual percentage. A business cares about the payroll file, not the mean uptime. A regulator cares about critical business services, recovery time and operational impact, not only the app home screen. ING's own risk language recognises this: the annual report says information-technology risk includes business disruption, reputational damage, unavailability of systems and inability to change technology at reasonable cost, and that operational-resilience risk includes failure to deliver critical business services within impact tolerance levels and recover within predefined time frames, service levels and capacity.
Compliance labour is part of the account price
The digital account would be cheaper if ING could ignore KYC, sanctions, AML and fraud. It cannot. ING's public financial-economic-crime statement says the bank has a corporate policy to prevent businesses from involvement in money laundering and terrorist financing, based on international laws and regulations, and that local management is responsible for implementation and compliance. The statement is at https://ing.com/about-us/compliance/financial-economic-crime-statement. For customers, that means the account includes a gatekeeping function whether or not they asked to buy it.
Compliance labour has two economic effects. First, it raises the bank's cost to serve. Staff, screening systems, case-management tools, monitoring scenarios, adverse-media checks, document refreshes and suspicious-activity reporting all cost money. ING says it has around 4,000 people working on KYC-related activities globally; that alone makes clear that compliance is not a small back-office appendage. Second, it can create customer friction. Customers may be asked for documents, blocked from certain transactions, delayed in onboarding, or closed if they do not respond to information requests. A cheap account that cannot pass these checks is not a bank account of comparable quality.
This is particularly important for SMEs and treasurers. A business account must be accepted by tax authorities, suppliers, payroll systems, card processors and auditors. If the bank's compliance process is weak, the customer may face delayed payments, account review, reputational questions or forced migration later. If the bank's compliance process is too blunt, the customer may face unnecessary account freezes, repeated document requests or onboarding delays. The paid unit sits between those two failures. ING is selling not only access to payments but also a regulated identity and monitoring layer that counterparties can accept.
The historical record shows why this is not optional. ING's KYC page says efforts to improve compliance risk management were stepped up in 2018 following a settlement with Dutch authorities after serious shortcomings in customer due diligence and transaction monitoring requirements. It also notes Banca d'Italia actions around AML process shortcomings in Italy. This history should not dominate an article about current account economics, but it explains why compliance labour is part of the price. The customer is paying for a bank that has to prove it has learned how to operate gatekeeping controls at scale.
Fraud controls add another layer. ING's annual report says the bank strengthened fraud-prevention capabilities, uses innovative technologies to reduce fraud-related harm, and in 2025 focused on early detection, smarter prevention and stronger governance. It mentions tools such as the "check the call" feature and a global fraud target operating model. These controls are not simply protective extras. A digital account without credible fraud controls becomes unusable for customers who cannot distinguish bank contact from scams during service stress.
This is why outages and scams interact. During the October 2024 ING Australia incident, public reporting said ING warned that scammers were calling customers or posting on social media claiming they could help restore app access. The account failure cost was not limited to login. It included the need to communicate clearly, prevent impersonation, route customers to safe help, and avoid turning service recovery into a fraud opportunity. That pattern is not unique to ING. It is a structural feature of digital banking: when access is disrupted, customers seek help, and attackers exploit urgency.
Cloud and core dependencies are part of the bargain
The digital account depends on infrastructure customers cannot see. ING's annual report says the bank's technology vision is anchored in a unified scalable technology platform and that the platform hosts modular components reused across countries and business lines. It says ING's private cloud infrastructure stores and manages applications and data such as channel applications, core banking systems and other banking applications. It also says the bank is moving toward a hybrid cloud set-up using private and public cloud solutions where each is most suitable.
That is economically attractive. Shared components can reduce duplication, speed product development, improve security expertise and help smaller markets use capabilities funded by the group. ING can open accounts in minutes, add insights, automate KYC tasks, link business accounts to accounting packages, and give wholesale clients self-service access because it has invested in common platforms. The mobile account is cheap to distribute only because the bank has already paid for this technology base.
But shared technology also creates dependency concentration. If a common component fails, the effect can cross product lines or countries. If a vendor or third-party service degrades, the bank may have to recover a customer-facing service it does not fully control end to end. ING's own risk discussion says DORA reshaped expectations for ICT risk management, incident reporting and third-party oversight; it also says reliance on cloud and third-party vendors amplifies operational-resilience challenges, and disruptions in IT systems or third-party services can lead to service outages, transaction delays, data breaches and financial or reputational losses.
That disclosure is more useful than public network speculation. Public web records can show that ING operates public web properties, country sites, developer surfaces, customer-service pages, wholesale portals and status-reporting ecosystems. They cannot reveal where customer data is stored, how core banking is segmented, which failover mechanisms apply, whether one vendor is critical to a specific payment path, or how an incident was contained. The responsible use of network-resource evidence is to map public surface and dependency boundaries, then stop. Operational claims must rest on filings, regulator texts, official pages, customer notices and credible incident reports.
For customers, the important point is that infrastructure modernization is not a separate story from account value. If ING can use shared cloud and modular banking technology to increase availability, reduce contact-centre volume, improve fraud detection and release better account features, customers receive value. If modernization creates new failure modes, customers bear part of the cost through outages, authentication problems, delayed payments or compliance friction. The account price includes both the upside and the risk of a bank that is trying to operate at digital scale.
The regulatory environment makes that bargain more explicit. DORA requires financial entities to manage ICT risk, classify and report incidents, test resilience and manage third-party ICT risk. EBA guidance narrows and clarifies ICT risk expectations in the context of DORA. These rules do not guarantee a customer can always pay at the exact moment needed. They do mean that a large bank's technology promises are now part of a supervised control environment. A customer paying for a bank account is buying a regulated resilience process, not just access to a commercial app.
Substitutes discipline the account, but they do not replace all of it
ING's account competes with named substitutes: neobank accounts, local bank accounts, multi-bank treasury setups, card wallets, cash and delayed payment. Each substitute attacks a different part of the paid unit. A neobank can be cheaper or more elegant in a mobile app. A local bank can offer local knowledge or a nearby branch. A multi-bank treasury setup can reduce dependence on any one bank. A card wallet can keep point-of-sale spending alive when a bank app is unavailable. Cash can handle small offline payments. Delayed payment can preserve liquidity when urgency is low.
Neobank pricing makes the comparison concrete. Revolut Business publishes plan prices beginning with Basic from GBP 10 per month, Grow from GBP 30 per month and Scale from GBP 90 per month, with multi-currency accounts, transfer allowances, card controls, expense tools and 24/7 English support described at https://www.revolut.com/business/business-account-plans/. The point is not that Revolut is a perfect substitute for ING. It is that customers can now compare a bank account against a visible software-style subscription with payments, cards, permissions and integrations. That comparison pressures ING to prove why a large regulated bank account is worth more than a lighter digital tool.
Bunq is another relevant substitute in the Dutch and European market because it sells app-first personal and business banking plans and publishes a pricing sheet at https://www.bunq.com/pricing. Wise Business, whose pricing page is at https://wise.com/business/pricing, is relevant for international money movement and multi-currency use, even though it should not be treated as a full equivalent of a universal bank. Together these alternatives make the customer's practical question sharper: when is ING's account worth the added relationship depth, regulated bank status, balance-sheet breadth and wholesale network, and when is a lighter substitute enough?
For a retail customer, the answer depends on how complex the financial life is. A customer with salary, rent, direct debits, savings, mortgage, investment account and family payment habits may not switch because one outage occurs. The switching cost is high, and the substitute may not replicate all products. A customer using ING mainly as a spending account may be more willing to add a card wallet, keep a second account elsewhere, or move discretionary payments to a neobank. The account's retention value is therefore not simply satisfaction with the app; it is the density of linked financial routines.
For an SME, the substitute set is more demanding. A business can use a local bank account, a neobank business account, a card wallet for expenses, and a separate international transfer provider. But payroll, tax, direct debit, accounting links, credit, fraud disputes and documentation can make fragmentation costly. The multi-bank setup is a resilience tool, not just a price comparison. It can keep money moving when one bank has an incident, but it requires staff to reconcile multiple accounts, manage authorisations, maintain payment templates and monitor fraud controls across providers.
For a corporate treasurer, the substitute is often multi-bank treasury architecture. The point is not to abandon ING. It is to decide how much volume, cash concentration, file transfer and payment approval should depend on ING alone. A treasurer may keep ING as a core bank in the Netherlands while maintaining alternative banking relationships for payroll, supplier payments, liquidity placement or emergency funding. This is the clearest way reliability becomes renewal risk: the client may not close the account, but it may route the next mandate, geography or payment volume to another bank if ING cannot prove operational resilience.
Cash and delayed payment remain substitutes only at the edges. Cash can solve a small point-of-sale problem, but it does not pay a cross-border supplier, settle payroll, support an online merchant, or satisfy treasury controls. Delayed payment works only when the counterparty is flexible. A digital account is valuable precisely because customers do not want every outage to become a negotiation with landlords, employees, tax authorities, vendors or merchants. The substitute set disciplines ING, but it also shows why a bank-grade account remains hard to replace fully.
The account's control surface is bigger than the app
It is tempting to make the mobile app the whole story. That would miss the point. The app is the control surface customers touch most often, but the account includes payment rails, card schemes, identity systems, transaction monitoring, sanctions lists, fraud analytics, contact centres, bank branches or advisers, developer and file-transfer interfaces, public websites, complaint handling and regulatory reporting. A failure in any one layer can produce the same customer feeling: money is stuck.
ING's public account language covers several of these layers. Its personal and business customer-service pages are public entry points. Its wholesale page describes daily banking and market-leader positioning in the Netherlands. Its annual report describes InsideBusiness Payments and Connect as critical digital channels for wholesale clients. Its KYC pages describe customer due diligence and transaction monitoring. Its legal-structure page describes ECB and DNB supervision. Its annual-report risk section describes DORA, cloud and third-party risk. The article's account unit is the intersection of these public facts.
This wider surface explains why the same incident has different severity for different customers. If only the mobile app login fails, card payments and scheduled direct debits may continue, but customers cannot see balances or initiate ad hoc transfers. If payment initiation fails, the customer may see the account but cannot move money. If transaction data is delayed, reconciliation and fraud monitoring suffer. If customer service is overloaded, a small technical fault becomes a complaints issue. If a KYC process falsely blocks an account, the app may be available but the money still cannot move.
For ING, the business challenge is to measure account value across that whole surface. The bank already reports high-level availability metrics, NPS, customer balances, fee income, primary customers, KYC staffing and risk topics. What public evidence does not show is whether the availability metric maps to the customer journeys that matter most: salary receipt, urgent supplier payment, card controls, authentication reset, fraud dispute, payment-file cut-off, direct debit reversal or account closure. That is why the account should be analysed as payment continuity, not only as a digital channel.
The same wide surface also explains why public URLs matter for market analysis. Official reports at https://ing.com/investors/financial-performance/annual-reports/2025 and quarterly materials at https://ing.com/investors/financial-performance/quarterly-results show financial and channel metrics. Customer-facing pages show what public help paths exist. Regulatory pages show who supervises which risk. Outage-reporting pages show market pain, even when they do not prove root cause. Competitor pricing pages show the visible substitutes customers can compare. None of these sources alone prices the account. Together they make the paid unit visible.
How far the evidence proves the account is worth paying for
The strongest proof is scale plus measured availability. More than 15 million mobile primary customers indicates that many customers choose ING as a primary digital account relationship. Retail deposit growth of €30.1 billion in 2025 and Retail Netherlands deposit growth of €11.5 billion show that balances were not fleeing the account proposition during the year. Digital-channel availability of 99.89 percent across Belgium, Germany and the Netherlands, and 99.97 percent for InsideBusiness Payments, show that ING is measuring account access in terms customers can understand. Fee-income growth from daily banking and investment products shows that customers are paying directly and indirectly for the relationship.
The second proof is breadth. ING's account can sit beside mortgages, savings, investment accounts, business banking, private banking, wholesale cash management, trade finance and treasury services. A substitute can beat one feature and still lose the relationship. This is why primary-account growth matters so much. The more products and routines attached to the account, the stronger the bank's ability to earn deposits and fees, and the higher the customer's switching cost. A neobank may offer a lower monthly price; a multi-bank treasury tool may offer resilience; a card wallet may keep checkout alive; but none automatically reproduces the full bank relationship.
The third proof is regulated operating capacity. ING is directly supervised by the ECB as part of the SSM, with DNB retaining areas including payment systems and financial-crime supervision. It is subject to DORA and EBA ICT expectations. It is a G-SIB subject to higher capital, TLAC, resolvability and supervisory expectations. It has a large KYC workforce and public financial-crime policies. This does not make the account perfect. It does make the account different from a lightweight payment app. Customers buying a bank account are buying into a system of controls that can be frustrating, costly and valuable at the same time.
The weakest proof is incident-level customer value. Public materials do not tell us how many ING customers missed a deadline because of any specific outage, how much money they lost, how quickly each journey recovered, whether compensation was paid, or how customer behaviour changed afterward. News reports and Downdetector comments make pain visible, but they cannot quantify churn or lifetime value. Annual availability metrics show high performance, but not which minutes mattered most. NPS shows relationship sentiment, but not whether a treasurer moved backup volume to another bank after a bad morning.
This uncertainty should not lead to a vague conclusion. It should lead to a stricter account test. The account is worth paying for when it reduces failure cost by keeping payments and access available; when it absorbs compliance cost without making legitimate customers unable to operate; when it lowers switching cost by bundling useful products rather than trapping customers through friction; when it has enough service capacity to handle digital incidents; and when its renewal risk is low because customers believe future incidents will be communicated, contained and repaired. That is the digital-bank-account business.
For ING Bank N.V., the 2025 evidence supports a cautiously positive answer. The account has scale, deposits, fee growth, high reported availability, a wholesale payments channel with strong public availability, a KYC operation large enough to be credible, and a regulatory frame that forces operational resilience into management attention. The negatives are equally concrete: DDoS incidents occurred, third-party and cloud dependencies are acknowledged, public outage signals show customer pain, and substitutes make it easier for customers to route some activity away from the bank without fully switching.
The result is not a simple buy-or-leave verdict. ING's paid account is valuable because it turns deposits, app access, payments, fraud controls, compliance work, cloud and core-banking dependencies, fallback service and switching cost into one operating proposition. It is risky for the same reason. The more customers use ING as a primary digital account, the more the bank's competitive advantage depends on uptime, recovery, communications and the ability to make compliance feel like protection rather than obstruction. In a digital account business, the balance is not enough. The customer has to be able to move it.
What customers should demand from the paid unit
The customer-side test should begin with use cases, not brand preference. A household should ask whether the account keeps ordinary life running when the app is unavailable: card spending, scheduled payments, direct debits, salary receipt, savings transfer, fraud reporting and authentication reset. A sole trader should add tax payments, invoice settlement, payment requests, bookkeeping exports and the ability to prove transaction history. A treasurer should add payment-file acceptance, approval controls, cut-off visibility, balance reporting, emergency escalation and multi-bank routing. The same account can pass one test and fail another.
The first demand is clear continuity information. An annual availability percentage is helpful, but a customer also needs plain communication about which functions are affected, what still works, what the safe fallback is and when the next update will arrive. During a digital incident, a vague "we are investigating" message does not let a treasurer decide whether to reroute payments, delay suppliers or trigger an emergency bank procedure. Nor does it help a retail customer decide whether to use a card wallet, cash or a second account. The value of the account rises when ING can translate technical status into customer decisions quickly.
The second demand is separation between account access and payment continuity. A banking app can be down while scheduled payments, cards or direct debits still operate. The opposite can also happen: the customer can see balances while a payment path is delayed or under review. The distinction matters because the failure cost differs. Inability to view a balance creates anxiety and customer-service demand; inability to move money creates missed obligations. ING's public availability metrics are useful, but the strongest customer evidence would show journey-level resilience: login, balance, internal transfer, external transfer, payment request, card control, direct debit, business payment file and help escalation.
The third demand is a credible fallback that does not create new fraud exposure. A customer told to call a help desk must know the safe number. A customer contacted during an outage must know whether the message is authentic. A treasurer using emergency escalation must know how approvals will be verified. ING's scam-warning context during the Australian incident shows why this matters: the moment customers are anxious about account access is the moment impersonators can become more persuasive. Fraud controls are therefore not separate from resilience. They are part of the recovery path.
The fourth demand is proportionate compliance friction. Customers can accept document requests and transaction reviews when the purpose is clear and the process is bounded. They become less tolerant when requests are repeated, unexplained or impossible to resolve through a usable channel. For ING, the KYC workforce and enhancement programme are evidence of seriousness, but account value depends on execution. A bank that screens well but cannot explain or resolve a legitimate customer's blocked transaction turns compliance cost into renewal risk. A bank that screens poorly may preserve short-term convenience while increasing long-term regulatory and counterparty risk.
The fifth demand is resilience against concentration. Retail customers can create a simple version by keeping a second account, a card wallet and some cash for short incidents. SMEs can hold an alternate business account and document who can authorise payments there. Corporate treasurers can maintain multi-bank arrangements, test emergency payment routes and avoid routing every critical payment through one bank and one portal. ING can still be the primary bank in that world. In fact, a bank that accepts and supports sensible redundancy may become more credible with sophisticated customers because it acknowledges how payment operations actually work.
The sixth demand is evidence after the incident. Customers do not need internal architecture diagrams, but they do need enough public explanation to judge whether a failure was isolated, recurring, vendor-related, cyber-related, customer-specific or a broader operational issue. They also need to know whether disputed fees, missed payments, duplicate charges or scam losses will be handled consistently. If an incident disappears into silence after the app returns, the customer cannot price future failure cost. If the bank communicates clearly, resolves complaints and shows whether controls changed, the account can retain value even after a bad day.
For ING, these demands point to a practical scorecard. The bank already publishes the foundation: digital availability, DDoS disclosure, resilience risk language, KYC staffing, customer growth, deposit growth and fee growth. The next layer of public proof would be customer-journey resilience, not more general digital ambition. How often can a Dutch retail customer complete the top ten account actions? How quickly does a business customer reach a trained human during a payment problem? How does InsideBusiness behave when a file transfer fails near cut-off? How many incidents required compensation or customer remediation? How often did customers with an outage complaint later reduce balances or product usage?
This is also how substitutes should be judged. A neobank with elegant app access may be a strong spending-account substitute but a weak treasury substitute. A local bank may provide branch reassurance but less cross-border reach. A multi-bank treasury setup may reduce single-bank risk but increase reconciliation and control complexity. A card wallet may protect checkout but not rent, payroll or supplier settlement. Cash may work for a taxi or a small shop but not for digital commerce. Delayed payment may be acceptable for a friendly counterparty but unacceptable for tax, salary or market settlement. The account is worth paying for when it beats this substitute mix on the customer's actual failure scenarios, not when it wins a generic banking comparison.
The paid unit therefore becomes a renewal conversation. ING does not need every customer to believe outages will never happen. That is not a credible promise for any large digital bank. It needs customers to believe the bank has enough availability, fallback, fraud resistance, compliance competence and recovery transparency that the expected cost of staying is lower than the cost of moving or fragmenting the relationship. That is a harder proposition than selling a free or cheap account. It is also the proposition that a large European bank is best placed to make if its evidence keeps improving.
Proof gaps
Economics: Public filings prove deposit growth, fee-income growth, primary-customer growth, daily-banking fee momentum, KYC staffing and technology expense categories, but they do not isolate the profit contribution of one digital account, the cost per account of DORA compliance, the cost of maintaining fallback service capacity, or the customer-level economics of account bundles versus substitutes.
Reliability: ING reports high availability for retail digital channels and wholesale payment/connectivity channels, and it discloses DDoS incidents and operational-resilience risks, but public evidence does not show incident-by-incident duration, affected journey mix, payment-file impact, customer loss, compensation, root cause, vendor involvement, or whether outages cluster around high-value payment windows.
Retention: ING reports mobile primary customer growth, NPS and deposit growth, and public substitute pages show credible alternatives such as Revolut Business, bunq, Wise, local banks, multi-bank treasury setups, card wallets, cash and delayed payment, but public evidence does not show how many customers reduce balances, add backup accounts, shift treasury volumes, or move future product mandates after digital-banking incidents.