Good afternoon, everybody. I wonder, by the way, with the movie what we would have shown you if the Netherlands wouldn't have won yesterday, but luckily we did. Thank you very much for being here today on the Capital Markets Day of ING, and I'm thrilled to take you through the journey of ING going forward. This is a journey about our DNA, about how we deliver with impact, and about growth. But I will not do this alone. I will also do this with my other board members that you see here depicted on the screen. After me, when I speak, Pinar will speak about growth and retail banking, Andrew will then speak about growth and wholesale banking, but also about how we will focus ourselves on our capital to be more efficient on capital, what I like to call the capital diet.
Then Ljiljana will speak about how we kept risks very well under control, how we also will deal with forward-looking risks and emerging risks, at the same time how we in risk will support our strategy so we can grow and where we can grow. Marnix will talk about all the foundations that we have built, the scalability and the digitalization, and the benefits that that gave our customers, and also for our cost to serve, but also going forward how we are building the product foundations, so how we widen these foundations to now also support the growth that we make in retail and wholesale. At the same time, and watch that space, he will talk about four big wins, four must-wins to actually improve further on our cost to serve.
Last but not least, Tanate will wrap it all up in all the financial figures so that you can also see the targets for 2027. I started at ING almost 30 years ago. Yeah, I mean, when I tell it, it's a long, long time. Then I became a board member since 2017, and the CEO since four years. Throughout all that time, I've seen that all successes that we have made in ING come from our DNA, the entrepreneurship, the relentless focus on our customers, putting really the customer first because banking is commoditized, and through our collaboration. As a result of it, we were able to challenge the status quo, challenge the conventions, make banking frictionless, make it easy.
As a result of that, we were able to grow to close to 40 million customers, to have significant market positions, to be very well liked and loved by our customers. We have a large brand, and we are a number one Net Promoter Score in many countries and in wholesale banking, and in the end, to realize very attractive returns for shareholders. That's fantastic. But there's lots more that we can do. When I became the CEO, the team and I got together, and we said we really need to work on the number of foundations and to put these foundations in our bank to then be able to reap the benefits of enormous potential that ING can still have. And so then we have the strategy, and I will talk about these foundations, which is called Making the Difference .
Making the difference by growing and building these foundations, Making the Difference by providing a superior customer experience. And now we are embarking on the next phase of this journey, which is growing the difference, accelerating growth, increasing impact, and deliver value. We delivered value. We promised you a number of things a couple of years ago when we had the previous Capital Markets Days just after or in between Corona, and some of you were not able to make the flight from London to Amsterdam that day. But we made a number of promises, and we kept those promises. We delivered. We delivered on growth of customers. We grow, and we have grown every year with 600,000-800,000 primary customers per annum. We are the most loved bank in many markets in which we operate.
We have a highly engaged workforce and a more diverse workforce that we worked on, and we're still working on, by the way. We put sustainability into the heart of what we do. We are a pioneer. We discussed this already 10 years ago, but we put it in the heart of what we do, which means in our operations with a big target for wholesale banking, and we already mobilized EUR 115 billion in sustainable finance and have now put a number of sustainable products in the market, also in retail banking. Last but not least, we also delivered for our shareholders significant cash distribution, strong ROE, but also strong fee growth. I want you to remember the following. In the period end 2012 to end 2019, we grew our annual fee income with EUR 700 million over that period.
That's approximately a growth of EUR 100 million per annum in that period. From end 2019 to, and I extrapolate, end 2024, that's a five-year period, we grow our fees with EUR 1.1 billion. That's more than EUR 200 million. So we've doubled the fee growth speed over the last five years. For the ones of you who have read the slides, we will again increase the speed of fee growth. I come back to this point. This is all due to our DNA. It comes from our DNA and the entrepreneurship, so the creativity that we have to always find something new and different for our customers, to innovate. The customer focus, because banking is commoditized, and the only way to make impact and be relevant for customers is to have a better experience and make more impact to your customers than the next neighbor does.
And lastly, in our collaborative culture, our what we call Orange Code collaboration. And let me give you a few examples. We, in the Netherlands, had a bank called Postbank, which was a telephone bank, a telephone bank in the 1970s and 1980s, and gradually transformed itself to a digital bank. And that concept we took and we rolled out in many markets, which we then called ING , about 25 years ago. Again, challenging the conventions. And on sustainability, we already spoke to our customers about sustainability in 2013, years before it moved to the heart of society. We were the ones who structured the first sustainable loan for Philips that was issued in 2017, years before sustainable loans and green bonds became popular in the market.
And with that DNA and with the large rent and high Net Promoter Score, we realized a fast-growing retail bank with a digital halo everywhere being seen as digital-only, mobile-first, with a fantastic customer experience. We have a world-class wholesale bank that is very customer-focused rather than product-focused, with three different sharers. One is the network, i.e., the presence of the people on the ground close to the customer. Two, our sector knowledge. We know what we talk about. We know the companies. We know the sectors for decades. And three, the pioneering role that we have in sustainability. And as a result of it, we realized the results that you see on this slide. And then the question is, how did we then do this? And I talked about when I started as CEO and about the team that you will hear about later today.
There are four main things I want you to remember. First of all, we apply focus. We apply focus where we can make impact. In our retail, impact is local because regulation is compartmentalized, and as a result, capital and liquidity and products are compartmentalized. We chose to invest our capital, our people, our costs into these markets where we could really make an impact and differentiate from others. Obviously, if you then also come to the conclusion that in some markets we are unable to do it, you exit those markets. We exited some smaller markets in France where we were smaller, Czech Republic, Austria, and the Philippines.
In wholesale banking, because we are a customer-driven bank based on those three different shares: network, sector knowledge, pioneer sustainability, we want to work with those clients on those three different shares because that's where we can make a long-term impact. If we can't do that, and if we can't make the return, we should not be with those clients, and the clients should not be with us. So we trimmed our network a little bit, largely in South America and Asia, and some of the clients we moved to the Hubs in New York and Singapore. But all in all, we decreased the number of clients with 35%, really focusing on the clients where we could make impact. So the first one is focus and impact.
The second thing I want you to remember from this slide, what we did over the past four years, is that we built foundational capabilities. We built a foundational capability on diversification because we have a lot of upside potential to have been a more diverse bank. Only 20% of our income currently comes from fees. And of course, you will not hear me complain about the higher interest income that we have had over the past years, but still we have that challenge to diversify more. We are diversified geographically. We are diversified from a business point of view, but we need to diversify also from an income point of view. And that's why we put Business Banking in there as a separate pillar next to private individuals. For retail banking, we have now a second pillar in the country, but also functionally.
We built product foundations in wholesale banking, in Financial Markets Transaction Services, as well as in retail banking, in investment products and insurance, to be able to have a broader, more impactful relation with our customers. Further foundational capabilities were about scalability in tech and ops. We built a data lake. We built a cloud environment. We built an engineering pipeline or platform so that people can code in the same way and shape, and that people can consume in the same way. We built a Hubs environment whereby 11,000 people of the 66,000 are now working in HUBS, all to realize scalability, scalability to decrease time to volume, decrease time to market, and in the end, thereby improve the customer experience and decrease the cost to serve. And the third foundation was we enhanced our digital capabilities. And yes, we are a very digital bank.
Yes, we are known to have a digital halo. Yes, we have a great app, but we also can improve that day by day. So we decided to put 350 digital journeys in there whereby we want to make them digital end to end. We call that Straight-Through Processing , and Marnix will talk about that. The second point is we built foundational capabilities. The third one is that we put sustainability really into the heart of our business, not as something on the sideline, but in our daily business. Why? Because sustainability is a big societal challenge. All our clients need to deal with it. We are very good with clients. We are a pioneer in sustainability, so we are the ones that can help our customers to transition.
And we're doing that with the amounts that Andrew will talk about and the products that Pinar is putting into retail now as well. And last but not least, the past couple of years, we spent a lot of time in improving talent development, people development, leader development, skill development, a real focus first with the top 400, now with the top 5,000, really looking at developing our people to be able to attract, develop, and retain our talents. And why do we do that? Of course, it's important for any organization, but especially in our organization where we're such a digital bank, where digital becomes even more important with Hubs, cybersecurity, AI, Gen AI, more technology means more IT people, and where we want to broaden, we want to grow Transaction Services, investment products. We need also to develop new skill sets.
That's why, especially for us, it's so important to further develop the talent in the bank, and we're doing that. That is how we have done it. Then the question, of course, is, so what are you going to do next? We are already embarking on that journey of Growing the Difference . To do that, you first always look at, are there things that are new that we haven't seen before? You first always look at the outside environment. You have seen this slide or a form of this slide before a couple of years ago. Have the trends or external things that are happening, have they changed dramatically over the past two years? Not really.
I mean, all of them are a bit more on steroids than a couple of years ago, but of course, we still need to work on digitalization and on scalability and customer experience and sustainability. We only need to do that, and we will do that. So that muscle is now trained, and we will keep that muscle to work. And yes, there are geopolitical uncertainties quite a bit heavier than, say, two, two and half years ago, but you see that we are dealing with that like we're doing in Russia, and Ljiljana will also talk about that later today. And we need to realize something. We are operating in very attractive markets. We're operating in very high GDP markets with low unemployment. We are operating in markets in Europe whereby half of the economy consists of SMEs, mid-corporates, Mittelstand.
We are operating in markets where there's an enormous wealth transfer happening from the older generation to Gen Z, in markets where there's an enormous need for sustainability finance. To put a number to it, in the 10 retail markets where we operate, the total banking revenue pool per annum is EUR 350 billion. We are the number three bank in the third largest global economy, being Germany. We are present in the third and fourth largest economies in Europe, in Italy and Spain. So there is a lot that we can benefit from, and we need to reap that benefit. And then the question is, well, where do you do that then? There's so much to grow from, and you can do it everywhere. What is then your focus? And our focus will be about relevance, will be about impact, and will be about close adjacencies.
Relevance because we can become much more relevant to our customers. Yes, we have 40 million customers, almost. Yes, of that, we have about 15 million primary customers. That are customers who choose ING as their main bank or non-main bank. But to give you a number, we have 4.5 million investment product accounts on a total of 40 million customers. That means we can be much more relevant to our customers. that also means that we will segment in retail much more precise what journeys and what products we offer to our customers. Pinar will talk about that. What do we offer to Gen Z? What do we offer to mass affluent? What do we offer to expats?
And also in wholesale banking, yes, we work well with our clients on a number of these different shares, but there are many more clients that we only work with one of these different shares, so we can be much more relevant to these customers as well. Then on impact. And sometimes my colleagues of other banks in the market in which we operate call us the biggest neobank, which you can call a compliment, but it also means that we have a lot more to do. We can be much more impactful in the number of societies than we currently are. We're a very successful business bank in the Netherlands and in Belgium and in Poland, but we have hardly built anything in Germany or in Italy or in Australia.
If you really want to be impactful to your people, to the clients, you need to be impactful in the economies in which you operate. You need to be the main bank, the universal bank in the countries in which you operate. We are going to do that. Where we're going to do that is, that was the third word. Words, close adjacencies. We are very good in digital SME or self-employed, so we're not going to suddenly start all kinds of branch networks. We will do that in a digital way. We're very good in creating a very nice app environment for our investment products. So we will use the learnings that we have from one market and bring them to other markets in which we're active, in which we have not been so impactful to date.
So what does that mean in terms of the strategy? We have been working a long time on making the difference, providing that superior customer experience, and that is not going to change. Yeah, this is so beautiful. Tears in my eyes. We'll move to Growing the Difference , and that also changed providing superior value for customers because it's not only about the experience that we give them, but we have to do something with this experience. We have to make sure we help customers to retain more value from that. It also means that we need to become more relevant, more impactful, more segmented, close adjacencies where we need to grow in, by the way, the uniquely ING way, the way that we have dealt with challenging conventions and making banking easy and frictionless. Where is that then? Three main topics. First of all, we diversify.
We diversify in existing customer segments that I just talked about, and we diversify in developing new approaches and services in markets where we don't have them yet, copying them from markets where we have them already. The second one is operational leverage. We spend a lot of time in building our functional capabilities, our scalability in tech and ops in a data environment, in a cloud environment, in an engineering environment so that we can code and everybody can consume everything at the same time.
We will continue to do that, and we will continue to work on digitalization, but we will also now add a number of product foundations on top of it in a scalable manner: consumer Lending engine, investment product engine, insurance engine, all to also reap now the benefits from the diversification that we will have and build them on top of what we built on the functional capabilities, and Marnix will talk about that later. Marnix will also talk about the third element, i.e., existing scalable features. We continue, we grow into product capabilities, into scalability, and we will also have a couple of big wins to do this in an efficient way at a lower cost to serve. The third focus area is capital allocation. We're a very good bank. We can grow a lot, and we have to do that in a capital-efficient manner.
We can use our capital much better than we do so far. So Andrew will speak about capital allocation, but also the capital diet by recycling the capital much more than we have done to date. We already were trained that much over the past two years. It's still small, but there is a lot more that we can do with that. And as a result of that, we built a better relationship with our customers because we can do more with our customers, because we can go back to our customers and say, "Look, we were there. We gave you the Lending. We sold it. We can come back again." At the same time, it means that we can shift the capital allocation from wholesale to retail there, where we also make higher returns. The question is always, and will you then also do M&A?
My answer is always the same. We say, "Look, we are very confident that we can grow organically. If there is an ability to accelerate that growth, we will look at it, but only if we can also drive value and realize synergy benefits from it, largely focused on retail and really subject to stringent criteria." On our capital target, also an often asked question, yes, we reaffirm again that we are moving towards our approximately 12.5 target CET1 by the end of 2025. Back to sustainability, the second pillar of our strategy. The reason why I want to have a slide on this is because it's a very big existential problem for society. Everybody talks about it, and everybody comments on it, but we have a role to play in helping our customers to transition in that existential problem.
The reason why we are so good at it and the best at it is because we started with this a long time ago, and we did this with many sectors in which we operate, and we have the sector knowledge, and that's why you see us appear so much on the league tables, also on sustainable bonds, for example. We made a pledge back then that we would go to EUR 125 billion by 2025, but we will now mobilize sustainable finance per annum by 2027 of EUR 150 billion. At the same time, by that date, we will have rolled out retail products, sustainable retail products in all markets in which we're active. These are our targets, which I'm sure you have seen, and which Tanate will also talk about, and all my colleagues will talk about, but I want you to remember four things.
First of all, the success of this bank comes from our DNA, and that will remain the success of this bank. two, we have delivered. We have delivered what we promised. Number three, we built a number of foundations that have set us up to be able to now move into Growing the Difference . And four, we have a very strong, very collaborative, and very confident team, and we will deliver. Thank you very much. I will now give the floor to Pinar.
Well, thank you very much, Steven, and welcome again, everyone. Today, I will be talking to you about growth, a growth that is about customer growth, but also at the same time, growth about value, the value that we will create with our clients, customer franchise, and also unlocking value of growth for our company, ING.
But before I talk about growth, I want us to step back and look at what is our starting position for growth. Do we have the right to grow? And I strongly believe we have a unique starting position, and I will share a few things why I believe ING has a superior position to start an era of accelerated growth and value generation in retail. The first one is we have proven, as Steven also mentioned, year after year, we have grown our retail franchise organically, and I'll come back to that in more detail. The second thing is we are the bank of reference when it comes to digital. I cannot tell you how many financial institutions we host in Amsterdam to share our digital capabilities, and we still remain humble.
We continue to improve, but when it comes to digital, ING Retail Banking is the bank of reference. The third thing is what I call our superpower, the superpower of brand. For those of you who follow consumer businesses and also as consumers, when you make a purchase decision in a business like retail, you get appeal of the brand first. And at ING, I think we have our brand as our superpower for growth. And finally, we have always delivered value as retail consistently. And if you look at today, retail banking generates two-thirds of our P&L, consuming 50% of our capital. Therefore, it is a logical place to start growth for retail banking. And of course, we can have all these capabilities and the track records, but at the same time, we should look at where we operate. Do we have the right footprint to operate?
If you look at the map from all the way to Australia, coming to Europe's largest retail revenue market, Germany, followed by all other markets with sizable retail revenue pools, as Steven mentioned, we are very fortunate at ING that we operate at a retail revenue footprint of about EUR 350 billion of retail revenues. So therefore, we have potential to further grow our footprint with all the right capabilities. Let's now take a look at a couple of things. We have grown our retail franchise by almost 50% in our client base in the years that are shown here. More importantly, as we were fast growing, we have not stayed as a secondary bank anymore. We are the primary bank of these clients.
So we have shifted our primary bank ownership, meaning we are the first bank of our clients, 40% of our client base, which used to be 30% in the past. So not only do we grow, but we don't anymore grow as a secondary bank. We make these clients also our primary clients. What is equally important, and this is something my retail colleagues would know, we track very obsessively, is what is three+ product ownership of our client base? And when we look at the statistics, our primary clients, who actually has more than three banking products with us, has reached almost 50%. So 50% of our clients whom we have grown and become primary has three and more products with us. So we grow, we make them primary, but we also create quite value. This is, I think, important to explain how we grow.
The second thing is I said we are the bank of reference when it comes to digital, but I also want to remain humble about it. We keep improving this every single day at ING. Just a few facts that I find fascinating. 95% of our interactions in retail banking is pure digital. 95% of our clients globally, 39 million clients, interact with us digitally. When we look at the sales figures, 80% of our sales in retail happens digital. This is not fake digital. This is real digital, meaning they start digital, they end digital, which is very important. When you look at just one example, which is our market and app in the Netherlands, which is actually our very proudly created what we call One App within ING that we also moved to other markets, and I will explain which markets.
Our One App is one of the most popular apps in the country. I'm not talking about just banking apps. This is among all apps in the country. ING's One App is in the top 10, which is very powerful. We think this is a position of strength to further grow at a scale like any digital player would do. The third thing is, and think about how as consumers you yourself make purchases. We get appealed to brands we like. We first consider brands that we like to buy. In a consumer business like retail banking, I call brand as kind of the superhero. Our brand is very powerful. We are the most recognized, but more importantly, one of the most differentiated brands. I want you to remember, in some countries, we are not the biggest. We don't even have the biggest balance sheet.
In some of these countries, our competition has thousands of branch networks. Actually, we have none. So people don't see our brand on every street corner. Yet in those markets, we manage to build brands that are recognized and differentiated. At the same time, our Net Promoter Score in eight out of 10 markets in top three. This is very important for us. I will explain why we are obsessed about our Net Promoter Score in retail banking. Because in a retail business, you grow with your customer's advocacy. Your customer's promoting you, advocating you, is actually the best source of growth. So therefore, we pay a lot of attention to where we stay in NPS. I can tell you, when we look at NPS, we only don't look at the top line NPS.
In every single market, we measure key episodes, journeys, MPS every single month to make sure we stay number one. This is a true metric for us that we track. Again, here, we are remaining humble because we want to improve it further. You see some of the country flags with some examples where over time, we actually continue to improve it. We are very actively monitoring it to make sure we never lose track and we continue to invest in this customer advocacy. Because for growth, we need customer advocacy. Let's take a look at our retail business. I think this is the first time we are disclosing this. I'm actually quite happy we are disclosing it because you can actually see what are the growth engines we have in retail. I call them the engines. Steven introduced them as pillars.
For me, they're engines. And pillars, why I say engines? Because to grow, you need different engines. And our first engine is private individuals. This is a business line that is kind of our core engine. We have been investing and building this engine for many, many years. This is our bread and butter. We have 39 million clients that generate a big part of our income. We are operating with this across all markets. We generate superior value, better than most of our competition. But we have also recently formally defined our second business line, second engine for growth. And that is called Business Banking, which is now reaching to a very sizable revenue number with an extremely strong return on equity. And as you can see, we are not yet leveraging that engine in all markets. And I will explain what we will do going forward.
The third one, which is a relatively recent one that we have been doing private banking actually for many years, but we have recently formalized as a separate business line and therefore to make sure it becomes our third engine for growth. I want to remind that this is nothing new to ING. The way we do private banking in Belgium goes all the way back to the years of BBL. We are in the Netherlands the best private bank selected as the best private bank in 2023. Our brand and MPS positioning in the segment is quite good. We believe with the right investments to the space, and I will explain what we will do, although it's small, with a very lucrative return on equity, it can provide us further opportunity for growth.
The way we will do private banking is based on synergies between private individuals and Business Banking . Now I want to zoom into Business Banking since this is the first time we are explaining it. I want to explain a bit the uniquely ING way of doing Business Banking because then I think you will understand better why we are able to generate such high value in this segment. So within the Business Banking , we serve clients from all the way from self-employed up to clients that are mid-corp clients, EUR 250 million turnover roughly of bigger clients. When we serve our what we call easy, which is our self-employed and micro segment, we do it the ING way, meaning we do it pure digital. We use all of our mobile capabilities, digital capabilities. We tap into our very well-known brand.
Anything you can think of is done digitally without branch networks, without bankers, but our clients are served digitally. As we move up, we use, let's assume, an SME client. Then we basically mix this digital offering with remote advice. If they need to speak to an advisor, we actually give them remote advice capabilities. But it's no different for us or nothing unknown to us because also similar in our PI business, if a PI client or a private individual client needs advice for a mortgage, they can also instantly connect to an advisor with our remote advice centers in mortgages or investments. So we leverage the same technology, but now for SMEs who need advice. As we move up to the chain to mid-corps, then we have our bankers well-trained with expertise.
But at the same time, if our clients need anything more sophisticated, then we tap into our wholesale banking colleagues when it comes to, for instance, financial market products or other types of products. So therefore, we have created a uniquely ING way of leveraging our data, digital, and expert capabilities and managed to create a segment with not only good financial results and growing, but also with very strong recognition, brand, and customer MPS. Let's take now these three engines. I will come back to them, but how they play into our universe of footprint. And again, I think this is the first time we also disclose what we do in each market and what is the return we generate and how we see the potential. So I will take a bit of time to explain this.
So as Steven said, the revenue pool in this footprint. We are very fortunate because I think our destiny is also determined with the footprint. So therefore, we are very fortunate. So when you look at the top, we see markets like Netherlands, Poland, and Romania. In these markets, we are already generating above a 5% level. 5% is not a target we pick. We just wanted to show you relativity. There is significant room for growth in this market as well. They generate strong return on equity. They're on full cylinders. These are very mature, extremely successful organizations with very strong brands, very strong teams. They have all the engines or most of the engines, and they can generate further growth for us. That's what they will do. I will explain one of these countries, Netherlands, in a minute just to deep dive on it.
Let's look a little bit to the bottom. We see Spain, Australia, and Germany. These are all extremely big markets when it comes to retail revenue pools. All three, just to give an example, the Germany retail revenue pool is around EUR 100 billion. It's Europe's largest retail revenue pool. And we are very fortunate to have a fantastic franchise in Germany. I will also deep dive into Germany. But the opportunity here in all three markets is also massive. But in these markets, we don't have all of our growth engines established and not all of our capabilities established.
So the play for us here is to basically take all the proven capabilities, either product or segment, and move these slowly in a very careful way to these markets so that we move them up to capture more top line growth as we move forward so these countries can also move up and bring significant top line growth for retail revenues. Then if you go to the other side and look at, for instance, the countries where we don't yet generate very attractive return on equity in comparison to other countries. And I'm going to pick Italy there. Italy is Europe's second biggest retail revenue pool. And we have basically had some compliance challenges. And therefore, we had an acquisition ban for clients. And we have recently reopened the bank.
We are putting all of our investments into Italy with known technology investments, platform investments, but also our best talents are now in Italy together with an amazing local team. We are building Italy for future growth. So Italy will become one of the biggest contributors to our income growth as we go forward. And we will basically move Italy from that corner to one of the biggest contributors of revenue, both in the private individual segment, but also in the business banking. And we are investing towards this. And I can tell you the last 12 months' results, whether it's customer acquisition or delivery on the tech programs, are, as expected, going extremely well. And we are very confident we will make Italy bigger as we move forward. Then I want to come to Belgium.
I know some of you have already asked us, why did you highlight Belgium more? The reason is Belgium is very important for us. Belgium already delivers sizable revenue for ING. We have been going through a program to improve the return on equity of Belgium. I will also deep dive on Belgium. But our primary goal for Belgium is to improve that ROE further going to the right so that it can bring us higher return because we are very value-focused in retail banking, but also at the same time, top line growth. Netherlands, Germany, and Belgium, I will come back and explain a bit more on exactly what we will do. But as you can see from this map, we are very fortunate.
Almost all countries deliver us significant upside potential with proven capabilities that we can take to different countries to deliver the top line growth that we will show for retail. Now I want to explain, come back to the three engines because these engines will play in these countries. The first one, which is our biggest engine, private individuals. I will not go through every opportunity here, but I'll pick only a few. The first one is something we are extremely passionate and almost addicted, which is make banking frictionless. You will tell me why. Because in retail banking, most of the customers get very frustrated because banks create problems in customer journeys. So things don't go well. They cannot find exactly what they need. For simple inquiries, they need to go to the branch or call the call center.
Frustration in retail banking is a function of friction. The more you create friction, the more you create frustration. What does that do? Your MPS goes down. Your customer advocacy goes down. You increase your churn. Now you cannot acquire as many clients. You know what most banks do? Because they create friction, they start to staff people to solve friction. They put more people to call centers. They then open more branches to solve friction. They put more FDEs all around to handle friction. So it then not only creates a problem for the client advocacy, but at the same time, it creates a very big cost base. At ING, this is something we are extremely addicted to that we measure friction. We manage friction because we want to have number one MPS across all retail countries and want to remain number one in customer advocacy.
But at the same time, and Marnix will explain more, as we solve this friction, we also reduce our cost to serve. We do not want to spend money to solve friction. We want to spend money to grow our business and make our clients' experience much better going forward. This is a big program, and we follow it very systematically across the globe. The second thing I want to highlight, which Steven already mentioned and alluded to, we also think there are adjacent segments in this that we can generate more revenues. I will give you two examples, affluent clients. We, of course, serve affluent clients already in ING, but we also recognize that we are missing out opportunities, perhaps just because we did not tweak our products and services exactly as they wish.
Hence, if we can do it or take some of our good proven examples to other markets, we can actually capture higher value from these segments. Why is this important? Because this is a segment, affluent, where you get more balances, typically more fee income, and therefore it will fuel further growth for us. I will explain this, for instance, in the country example of Germany, how this is important. Gen Z, and you probably think, well, Pinar Gen Z, most of these clients don't have high balances. Why do you talk about Gen Z? Because Gen Z is our future in the footprint we operate. We have more than 30 million Gen Z clients. If we let them acquire by others, they will not be our customers, and we don't want to lose them.
In some markets, like Netherlands, we are extremely strong, market-leading on Gen Z. We will close the gap in all other markets to make sure we also lead on Gen Z, just two examples. The last one I want to mention here is the retrofitting. The retrofitting, there is no better bank than ING with such a large mortgage book that we have to be the leader in retrofitting. I don't know whether any of you have recently tried to renovate your house. I did. It's not an easy process. It's really not an easy process. Imagine millions of clients who need to find partners, who need to find solutions, who need to understand subsidies given by the government. It is not something easy for millions.
Not only do we want to make it simpler for them, take friction out of retrofitting, we are now investing in digital platforms to make it very easy so that millions of clients can access retrofitting. It will help us significantly on our net zero ambitions, but also it will create us a big commercial opportunity for further Lending growth. The first example of it is live soon in the Netherlands and also at the same time in Germany. As we always do in everything, we will carry these examples to other markets to create more opportunity for us. Let me go to Business Banking . You see in the Business Banking , the priorities are quite similar, but targeted because we leverage capabilities across segments. Similarly, we are going to make banking frictionless. Similarly, we are going to be the leading bank.
We already are, by the way, in the markets. We do Business Banking on sustainable Lending. In addition, here, we are going to expand our proven capabilities to Germany, Australia, and Italy. I will show you in Germany the very first results of our launch this year of a digital savings proposition in Germany. I'm very excited. I'm sure as we speak, the numbers on the page also go up. Finally, private banking. Before I explain what we will do, I will tell you what we will not do in private banking. I think it's also equally important. We are not going to target high wealth bands here. We are not going to hire an army of people of private banking to do private banking for high wealth bands.
Of course, we may have clients who may choose to bank with us in private banking in these categories. But what we will do is in the markets we operate. Let's pick Netherlands, Belgium. Our markets where we have a PI business, private individuals business, but also a Business Banking business. It's a natural moment for us because if you look at the wealth generated in these markets, roughly 50% of the wealth generated in these markets comes from entrepreneurs. To give you one fact, in Belgium, our 70% of our wealth inflow, investment inflow comes from our Business Banking clients. So in the markets where we have very strong private individuals business and a Business Bankin g business, or at least one of them, we will look into how we can capture opportunities to serve our clients in private banking wealth much better than before.
We have, as I said, formally organized this. We also have brought in people and colleagues, great colleagues with the right relevant expertise to fully capture the opportunity here. But the way forward here is the ING way. As I said, we will do it in our way as we take this segment further. Now I want to explain three countries. Germany. One of the countries out of the bottom of the chart where these countries are doing great with returns. I said they have also amazing opportunity. Germany is Europe's largest retail revenue pool. I'm not going to be humble on this one. I think there is no better bank, no better bank who has the potential to capture the full retail revenue opportunity in Germany than ING. Why? Because we have done so already historically.
If you look at our numbers and track record, Germany has shown a stellar customer growth. Germany performed better than any competition when it comes to retail banking. We have already done this. You pick any metric. We have improved our primary client base. We have significantly grown our client base. We deliver superior return on equity in comparison, not only within the ING units, but also in comparison to the market. What we will do going forward is our ambition in Germany is to continue that growth. We will continue to grow really large numbers of customers in Germany. We will continue to make them even more primary. We will tap into all adjacent opportunities and increase our segment coverage and increase our three-plus product ownership with now better built-in capabilities, whether it's insurance or investments. At the same time, we have already launched Business Banking .
Only in a couple of months, we launched a digital savings proposition. We did not do the biggest campaign in Germany. We did a campaign, but relatively modest, just to test it. The early results, as you can see, only in a couple of months, we reached EUR 500 million of deposits as we speak. We have reached more than 4,000 clients. That already proves that we actually can do this. In September, we will launch our current account proposition in Germany. In 2025, first quarter, we will also launch digital Lending in Germany. So we will do this so that we can build the second pillar that will contribute to our top line. I'm very confident with an excellent team in Germany, with an extremely strong track record.
We will be the best, fastest-growing digital primary bank of Germany, which is the largest retail revenue pool in Europe. Now I want to explain Belgium and what we have already done in Belgium. Belgium delivers a relatively lower return on equity compared to our portfolio. Still very competitive. But only a couple of years ago, we were talking about very different numbers in Belgium. We did not have a strong digital proposition. We did not have a strong Net Promoter Score. But just look at the results of what happened only in the last couple of years. We have significantly increased our digital sales. We have moved our app ratings. Because our customers actually prefer to bank with us, engage with us, buy from our digital channels, and visit less our branches, we have closed more than 50% of our physical footprint.
And many people will tell you, while doing so, your MPS probably declined. No, we actually, at the same time, managed to increase our Net Promoter Score in Belgium. Going forward, we will continue this. We have performed, by the way, better than our competitors on cost in Belgium. And we will remain very cost-disciplined going forward as well. But at the same time, with all these foundations being established in Belgium, we have an amazing growth opportunity also on the top line. Now we are very well positioned to grow further, especially areas like private banking wealth, because our positioning in the entrepreneur segment in Belgium is excellent. And we will do both the top line growth and also continued optimization on the digitalization. And our guidance for Belgium is to bring the return on equity further.
As I said, remember the metrics to the right, beyond 14% by 2027, which is today 11%. I'm very confident about this because we have done this before. We will do this again. Because we have an excellent team in Belgium who has already delivered this, who will deliver this again. Now coming to our market where we have a very large base. Remember top right side. This is a bank that has superior skills everywhere, whether it's customer metrics, digital metrics, commercial momentum. So if you look at any metric, and again, here, we also outperform on many dimensions compared to our peers in this market. As you can see, many people tell me this is a branch-based model. So I want to factually correct it. We have almost around 8 million clients and less than 35 branches.
So this is a franchise that is becoming increasingly digital. We are growing digital. We, of course, have our experts and bankers and still branches, which is part of our model. But for such a large client base, our digital capabilities are just superior. Going forward, we have an amazing sustainability vision where we believe that vision will give us significant opportunity to further grow both in the retail side, but also at the same time on the Business Banking side. Since these two segments, both private individuals and also our Business Banking segment is so mature with superior capabilities, that the opportunity for private banking will also be fully captured, as I explained to you in the Netherlands. Netherlands will continue to give us significant top line growth and will basically, we are guiding the growth of Netherlands also above 200 clients a year.
So having talked to you about a lot of growth, countries, segments, product capabilities, I'm sure you're all curious about, okay, what is the impact of all of this? So this is basically, I think, the most important page. I'm sure you checked when you received the presentation this morning. With all this hard work across the globe, we will deliver very strong fee income in the range of 5%-10%. We are very confident about that range, very confident about that range. We will increase our share within our ING group with superior return on equity by 27%, about 20%. As Steven explained, we will get a higher share in ING group with this growth story because our aim is to make ING with this strategy a much more valued bank than today. Thank you very much for listening to me.
I'm looking forward to the Q&A for more questions. And I would like to hand over to Andrew, who will explain the wholesale story. Thanks a lot.
Good afternoon, everyone. I thought I would start with maybe a reflection on DNA. Steven talked about nearly 30 years in ING, and I've come up just through three years. And the thing I can say about the DNA of ING is it's very unique. It starts with a strong sort of orange glow to everything we do. And if I articulate it from my perspective, firstly, it's an organization that's passionate about its customers and its clients. Secondly, it has a unique way of collaborating and working together. Thirdly, we are very lucky to have one of the great banking brands of the world to provide the power to support that.
So I can absolutely vouch only three years into my own ING journey, the bank is in a good place. I'm particularly delighted today to be able to share with you the progress that we've been able to make in the wholesale banking business. I'm very proud of all the colleagues right across the bank, but certainly the 15,000 colleagues who help and support the wholesale banking business every single day, be that in our business teams or all the functions that support that. This is a team effort that has been a great opportunity for us to continue to show we can drive value. Steven talked about the ING difference. I wanted to just maybe articulate and just share with you a little bit of why the ING difference is so important. In wholesale banking, it's a highly commoditized industry.
What we want to be clear on is where does ING make a difference for its clients? In particular, we think about our global reach. We operate across 35 markets. We serve as a gateway to large Asian and U.S. multinationals and financial institutions as they think about their banking needs in Europe, as we also support European companies as they deliver their business across Europe. 58% of our income is supporting clients cross-border, delivering the whole bank's capability regardless of boundary. Our cash management capabilities, our Eurozone cash management proposition, and our global world-leading cash pooling capability through Bank Mendes Gans . Our sector expertise was really grounded in the Barings structured finance business that grew out and was acquired by ING at the turn of the century. That creates the bedrock for the deep expertise we bring.
Steven talked about we delight our clients. And I'll talk some more about that later. The other thing to always bear in mind with the wholesale banking business ING is this is a very diversified business, diversified by geography, diversified by product, and diversified by sector. And that means that less than 3% of the group's exposure is sitting in a particular sector in a certain geography. Diversity is our friend. We're also pioneers. And I'll talk some more about that. But I'm particularly delighted to be able to share with investors and other stakeholders that we delivered our 2025 commitments in 2023. Really encouraging to see that we've been able to increase our income to risk weights by 54 basis points. We managed to get the top line income of the wholesale banking business, traveling it over 9% compound.
Our risk costs continue to ride very low through the cycle. Risk costs and those will continue to decline. I'm very happy that we're on track to deliver EUR 125 billion commitments for 2025, EUR 115 billion mobilized so far. And that we must look back was EUR 88 billion only two years ago. The cost-income ratio, we said we would keep it below 50%. We achieved 47% last year. And very important that we continue to focus on running a cost-efficient wholesale banking business. And through that, we derived headline return on equity of some 15% last year. But even we applied it through the cycle risk costs, 12%. And that's against the blueprint that we set to see if we could find a route to a 10% ROE by 2025. So we're very proud of those, but we know there's more to do.
But it's also not just about some financial metrics. I talked about the thousands of colleagues working every day obsessed in what we need to do, focusing on that capital diet that Steven alludes to, thinking about how we become ever more efficient in the deployment of our capital. Very simple math, reducing our client base by some 35% while doubling the income per client. Really good to see that our client portals continue to attract ever more traffic as clients look to us to help them with their daily banking needs. We continue to see 5% compound growth rates in the use of our platforms. Net Promoter Scores, one can gloss over Net Promoter Scores. Our clients are 72 Net Promoter Scores, absolutely world-leading in terms of our clients and how we delight them.
And lots of volume and transactions, almost 800 transactions last year working with clients, thinking about how they support their own transition, a real leader. And now working with 2,000 of the largest companies in the world, thinking and working with them on what their transition plans are and how those plans fit into how we might support them in the future. But this doesn't just happen. There's been relentless and continuous focus on execution. And what has that meant? We defined a number of must-wins after our investor day with all of you two years ago, as I've talked about the financing, the transition, and that focus to make sure that we can support our clients. But also recognizing, as Steven alluded to, where are those adjacencies where we can scale on the product foundations that we have.
Also building on the phenomenal leadership position we have as a digital leader in ING. Steven talked about it, Pinar talked about it. And in the wholesale banking business, we're looking to create ever more leverage of that core skill set we have. And then crucially, that capital diet is continuing that obsessive focus on efficiency. And we believe that we can be the best European wholesale bank. And that wholesale bank will be powered by our global network. Just to be clear, I didn't say the biggest, I said the best. And we think that gets defined by delighting our clients with high Net Promoter Scores, the digital leadership that I just alluded to, what we do to make sure that we're a leading employer.
Steven talked about some of the tools, the way we're thinking about our people, how we develop our people, how we make sure we can build on the very strong orange culture we have, the collaboration spirit that we have to create ever more excellence as we compete in these highly competitive markets. It's also making sure that we understand how to drive returns for our shareholders. Steven has talked about this, but when you get into more detail, and a number of you will know this as you follow us, we have very technical, very sound technical roadmaps around how we think about our transition to net zero. At ING, this isn't about brochureware. This is about a real commitment to continue to drive ING to a sustainable future.
That comes in different guises, be that thought leadership in supporting the shipping industry, thinking through how the shipping industry moves towards a net zero world, how we work with sustainable steel principles, real economic issues, ING providing thought leadership in those transitions. And with that, we decided that we can continue this journey and commit to EUR 150 billion of annual volumes mobilized by 2027. But I get excited. You might say, "Okay, three years in, it's all good. What more could we do?" Actually, there is so much more we can do. We see growth. We see opportunities as we look forward. I'm very proud of the fact that we managed to narrow our income to risk weights relative to our peers over the last few years. But when I think of the capital toolbox that we've used so far, we're a good primary distributor of loans.
We're a good bank selling loans in the secondary markets. We continue to use CPRI to hedge our credit exposures. But we're yet to do our first significant risk transfer trade in the wholesale banking business. The average in Europe at the current is about 3.5% in wholesale banking. Leadership is 10% of the portfolio distributed. These are new ways where we're going to continue to challenge ourselves and build on that capital diet that we've been on. There are other reasons to believe when we think about the adjacencies and where the ING wholesale banking sits relative to our global competitors. An interesting feature of the wholesale banking business of ING. It only runs a wholesale banking loan-to-deposit ratio of 34%. And if you layer in the very strong credit covenants that ING has, large companies, large financial institutions would love to place their money with ING.
And you think our competitors have a loan-to-deposit ratio of some 140%. Today, the deposit base of the wholesale bank is some EUR 75 billion. If you did the simple math, that could be a deposit base of some EUR 250 billion just in the wholesale EUR 50 billion straight away. But there is no doubt, as we continue to build out the capability, that we'll be able to grow the franchise around the opportunities that we see. The other feature that is interesting about the wholesale banking business of ING is 50% of our income comes from Lending. And again, when we look at the number of our competitors, 85% of their income comes from non-Lending. Again, opportunities for us to continue to find those adjacencies that Steven talked about to continue to grow.
But it's about the product foundations that we have and how we make sure that with a very strong client base, we can find those opportunities. And maybe I'll start on the right-hand half of this graphic. If you look at it today and looking at long term, what we would expect is that the Lending income that we earn today would broadly remain stable. The focus there would be on relentless efficiency, continuing to make sure that we get the maximum return, driving ever up the higher value chain, getting higher leader-arranging roles. And then the areas where we can see growth. In Transaction Services business, a great opportunity to continue to build and diversify our product mix, build on the leading capability we have in trade and commodity finance to extend our trade capabilities, our receivable finance capability.
We heard a bit about this from both Steven and Pinar earlier. Opportunities to continue to think about how, where are those adjacencies where we can extend capability. That's whether it's underserved geographies, particularly in Western Europe, where we can extend our cash management capabilities and platforms that we have. Then, as a consequence of that, grow our deposits in a meaningful way over the next coming years. In Financial Markets, it's all about harmonizing the product suite, continuing to focus on how we deliver our service to our clients in ever better ways. There's good innovation already in our Financial Markets business, building out our green product offering. We see more opportunities to continue to do that. Then, crucially, underpenetrated in, for example, sectors like financial institutions.
When we presented two years ago, we talked about operating in the boardroom, helping our clients, but we'd not yet created a single unit to put that together, what we have within capital markets and advisory. Just to bring that to life, just to clarify what is in there, that is our loan syndication operations, our debt capital markets, our equity capital markets capability, our corporate advisory capability, our ratings advisory capability, our corporate investments business. There's a suite of capabilities where we're in the boardroom helping our clients in their most strategic moments. Here's a good example where we can bring in good bankers and enhance the capability set we already have and create more fee-based income from the relationships that we already have.
And again, if you look at that, the opportunity to grow comes from finding good, safe ways with good returns to be able to invest in new capability to drive longer-term growth. But it's not just about investing for income growth. It's also making sure that we become ever more efficient in the way we operate and how we deliver our services. And what you will see here is we will continue in our Lending business, for example, to continue to focus on how we simplify and standardize our Lending capabilities. We're starting to pilot at pace how we use generative AI to help our bankers with their credit packs, how they start to co-pilot their credit packs through the application processes.
Transaction Services, we've done great work over the last two years to bring together all the payments capability of the bank, be that in retail or wholesale under Marnix. And now we have the platform to continue to scale that payments capability in those adjacencies that Steven talked about across our various markets. In Financial Markets, we'll continue to focus on how we enhance the pricing tools we have, how we make sure that we get ever better insight from our clients. The Financial Markets business of ING is a client-led franchise. This is not a trading proprietary shop. This is how we support flow. And the capability that we're building there continues to make sure it's both efficient but supports a strong client-led business. And then KYC has been an area of huge activity.
We know there are opportunities, again, in partnership with Marnix and his operations colleagues and our technology colleagues to find ever better ways to structurally automate what we do to support that and get to a point with a lot of our clients where we can have zero touch from a client experience point of view. That means that we can continue to be a highly efficient wholesale banking business, tracking at a cost-to-income ratio in the 50%-52% range, making sure that we can be efficient from a cost perspective while finding those income opportunities. Back to the capital diet and the progress, but also the more work we need to continue to do. What we can see, like others, that we've had headwinds, be they related to regulatory changes, be they volumes to support our business.
I'm happy to say that we've been able to make good progress in terms of management actions, some EUR 32 billion of reduction as we focused on whether it's optimizing our portfolio. Steven made the comment, using the ING difference to work out, "Are these clients where ING can create value for the client? And does the client get value from ING?" Starting to make those tough choices in prioritizing and focusing our capital, then the capital we deploy in our relationships where we can get a return. Continued work on optimizing our models, continuing to use the various tools to distribute capital. With that, I believe we can repeat again what we said to you two years ago and continue to increase the income-to-risk weights by another 50 basis points as we track to 2027. We do believe that we can be the best European bank.
In the wholesale banking business, that means we're going to be powered by our global network and continuing to strive to be that best European bank. We think we're absolutely at the point, having made the difference over the last three years to now think about how we grow the difference right across the company. Then from a guidance point of view, we'll continue to create a good mix between income growth, staying safe from a risk point of view, continuing our sustainability leadership position we have, keeping that cost efficiency, at the same time keeping that capital efficiency, and crucially, balancing income costs and capital to obsessively focus on how we can drive a wholesale banking business that can sustainably drive a 12% return on equity. With that, I'd like to thank you for your time.
We're going to have a break quickly for about 20 minutes, and then we'll get back and continue the conversation. Thank you very much.
Good afternoon, everyone. I hope you've had a refreshing break and you have experienced energy, if not excitement, in the first part of the presentation, which was all about business strategy. I promise I will not excite you furthermore, because this is not what a good risk manager would do. What I would do is provide you with confidence myself personally and my risk organization has gained while building together with the business our Growing the Difference strategy. I will start with glancing back at what have we done in the last few years, specifically since we last talked to you on the last Capital Markets Day in 2022.
Then I will look forward into how does really the new next phase of our strategy fit with our risk appetite. And lastly, I will talk about what is it from the risk perspective that we need to do to support the, I would say, implementation and success of that strategy. Let me start. And I will start with a proof point that underpins my confidence. And that proof point is that ING has proven throughout the cycle, to whichever time frame you look backwards, that we are able to manage our risks and portfolio in a successful way. We have continuously performed better than our peers when it comes to the different risk metrics. If you look at our risk cost throughout the cycle, they have remained at the very stable and very low level, and they have remained all the time better than our other peers.
This goes as well for our S3 ratio, where we have as well proven once more that we are one of the lowest NP banks in the European zone. Our through the cycle historical average for the last 10 years as of 2023 is at minimal 20 pips. This is a huge success. That means that we have done a good job of, I would say, targeted credit risk strategies that have de-risked our portfolio compared to the previous years. How have we managed that? What are the principles that we use when we manage specific types of the risks? And let me start with the financial risk that has gained, I would say, the most attention in the last years due to the unprecedented environment of strong interest rate hikes and deflation around us. And what have we done there?
Yeah, we have very dynamically, we have sailed through, I would say, the storm by dynamically managing our hedging and risk mitigating strategies. And while doing that, we were very dynamically as well and more often looked into our behavioral models as to understand whether there is anything else we need to adopt in order to make sure that our balance sheet remains stable. And we've done well. When it comes to operational risks, we have focused strongly on further increasing effectiveness and efficiency of our control framework. And why is it important? It is important because strong internal control framework contributes to the operational resilience of our critical business functions. And our strong critical business functions make it less probable for our clients that they would not be able to count on us everywhere and always. And this is what we aim to do.
On top of that, cybersecurity, data privacy is top of our mind. This adds to, I would say, our obsession of making our operations being safe and secure for all of our stakeholders. When we go back to our bread and butter, which is our credit and counterparty risk management, which actually consumes most of our capital, approximately 85% of our RWA, how have we managed to keep the low risk profile of our portfolio throughout the uncertainties that we have witnessed in the last few years? It sounds very simple. If it's so simple, one can ask why the others are not doing it. I think the recipe is applying these fundamental effective rules of risk management, but doing that very consistently and doing that very disciplined. This is where I believe we make the difference.
You know that diversification is one of our major principles, not just when it comes to risk management, also to the business model. But if we look at risk management, you will see and you will know that we have a very granular risk appetite developed. We have caps and limits in place for different perspectives, being it client, being it industry, being it sub-portfolio of assets, being it specific geography. With these limits and caps in place, we manage dynamically throughout the cycle. We are also very much adaptive to our Lending policies. We are looking forward and we try to anticipate the trends and build them in in our Lending policies in order not to have surprises in the future. And that has proven to work very well. At origination, as you know, we are as well very selective.
Once more, our Lending policies help us there, but not just Lending policies. I would say it's our basic focus on primary sources of repayment, cash flows, affordability. We always take a worst-case scenario when assessing those. Clearly, collateral comes on top and it's a luxury that we get on, but it's not the major driver of our business model. If you look at some proof points of what has happened in the last few years with respect to the rules that I've mentioned, you will see that we have further decreased our diversification in the number of the metrics. For example, mortgages present in our largest geography present less than 15% of our total portfolio, where our largest industry sector in corporate in terms of outstanding presents less than 6% of our total portfolio.
Furthermore, we have increased the portion of our balance sheet that is investment grade to above 80%, and 65% of our portfolio remains fully or partially covered. But all of that at origination would not suffice if we would not be as forward-looking, as proactive in monitoring and management on risk that we already have on our balance sheet as we are. Here as well, we need to look forward and to anticipate the trends and to make sure that our credit risk strategies are aligned with those trends and expectations. But this very agile management of our restructuring exposure helps us to be agile in getting out what we want to get out from balance sheet. And we do this very well. If you look at statistics, 70% of our global restructuring cases come out of restructuring with zero losses.
And I would say needless to say, we also build for uncertainties that our models cannot predict. This means that we, in times of uncertainties, be it pandemic, be it Russian invasion, we create overlays. We currently still have in place around EUR 500 million of overlays, which could serve for the eventual rainy days. But as numbers get remembered stronger and longer than the words, I wanted to illustrate a few of the examples where actually you can see that our effective risk management strategies work. And I will start with Russia. As Steven mentioned at the very beginning of his talk, we have found ourselves two years ago in a difficult position like many of our peers. Since then, we have kept our head cold and we have worked diligently for the value of all of our stakeholders to decrease this exposure. We have not undertaken new exposure.
On the contrary, we have continued decreasing it, and we have decreased it by 75%. Our today's offshore exposure to Russia is approximately EUR 1.3 billion, out of which half is ECA or CPRI covered. We will continue doing that. We'll continue to run down. Another example of effective management and risk practices being put in place is our leveraged finance portfolio. After the pandemic, with the additional hike of interest rates, with additional inflationary pressure that we haven't seen for decades, we have decided consciously and targetedly to decrease this part of the book because we thought it's going to be the most vulnerable one once the interest rate continues to grow, once the inflation continues to add to the cost of these businesses. We have done very well. Since 2019, our portfolio is down by approximately one third. We still kept the door open.
The franchise is still there. We still do the leveraged finance, but we are much more selective, and we are clearly making sure that according to the cycle, we build our book up to the limit that we have in a way that we want. So we want to be the owner of the strategies, the owners of our own destiny. Last but not least, and probably the topic that every financial institution is discussing today is commercial real estate book. Yes, we as well have a book which I personally feel very, very comfortable with, as well as my risk organization. I'll tell you why. Because it's well diversified, not just when it comes to the geographies, but when it comes to the specific asset subclasses in that book.
What we've done in the last few years is we haven't increased it because that would be counterindicative. We have even slightly decreased it. But what is important, we have structured the subclasses within that book in a way that it's less prone to the shocks and volatility of the cycle. That means we have decreased the portion of our retail part of that book and part of the office of that book. We have as well, very in an agile way, adopted our origination criteria as to cater for the changes in the environment. This has proven to work, and I do believe we are in absolute and relative position better than our peers. But it's time to look forward. We've done it well, and we know that we are proud about it.
We are confident about it, and we believe we have built a good start for the growth. But let's look forward. We are ready to grow, as you've heard from Pinar and Andrew and Steven. And I fully embrace and wholeheartedly actually embrace that strategy. And why is it that? Because the first question you might ask me is, how is this new strategy going to fit with the risk appetite? The good news, at least for the risk manager, is that there are no material changes of risk appetite needed. There are no U-turns. There are no different routes that we will take. There will be fine-tunings, but we do have plans, and we are ready to support these fine-tunings. And I'll try to explain why.
If you remember what Pinar told you, and I'll try to really simplify it very much, we will continue doing what we do well, but we will do it at a larger scale and with some new opportunities. Example, mortgages. We know how to do it. We do it. We're going to do it even bigger. We're going to add retrofitting as a new opportunity. We're going to diversify our Lending. Mortgage, our largest book, consumer loans, only 3% of our book. And yes, it is probably the more riskier part of the book, but as 3% of our total balance sheet, it has, and it has the right to require a place to grow. And we agree about that. Non-Lending income, absolutely any risk manager would support a strategy which ensures capital-like products, non-Lending income. Why?
Because it consumes low or no RWA, while it enhances return on the other side. Export of the best practices and knowledge, capabilities from one ING geography to another ING geography. Yes, we know we have proven how to do it in one country. Why not going into the market that we know as well and try to do the same success story? So in short, it's not about everything and everywhere. It's a well-thought-through strategy of focusing on existing markets, focusing on existing clients. If we go on to the new clients, we will start first by liabilities, by deposit taking, and this will be specifically for the risk management, an important source and insight of data and customers' behavior that we will later on build in our credit decision models once we decide to deploy our balance sheet. That's the way forward.
That's the way of safe and secure growth. If I go back to Andrew, and again, apologies, I will paraphrase the strategy and try to make it simpler than it is. If we look at what he said, and he said it's not about getting big, it's about getting best. That means it's not the volume hunt, it's the value hunt. Every risk manager would subscribe to that. And why? Because at the RWA that I already have on my book, or I will have on my book, I will enhance the return part. My return to risk ratio will improve. So with the same risk taken, we will extract more value. So it's more about extracting value. Capital efficiency, I couldn't agree more. We'll turn over our balance sheet faster.
That's very much aligned with the risk strategies that I want to apply, how to make sure that for the part of the exposure that we want to sell, we can do this in an effective and efficient way. And last but not least, transition financing. That's something that will create a sustainable balance sheet of the future. The less climate and environmental risks I take nowadays on my balance sheet, the healthier balance sheet I will have in the future. So yes, I and my risk organization wholeheartedly embrace this strategy and are ready to support it. How are we ready to support it? What do we have to do and focus to do that well? Clearly, by continuing doing what we've done well so far, and that's what we promised to do. But as well, and we see it, the world around us is changing.
There is a lot of uncertainties, not just at macroeconomic or geopolitical level, but at the level of regulation, at the level of new, evolving, and emerging risks. So risk organizations stand behind the need to further be obsessed by anticipation of the trends that are happening in the industry and encompassing them into the modes and tools of management of the risks. And I will mention only a few because the list is not exhaustive, clearly, but it's so long and you know them all, but I will mention a few that we believe are extremely important for our business model. And I will start with climate and environmental risks. Why? Because we want to be recognized as a pioneer and as a leader in sustainability. If we want to do that, we need to be recognized as well as excellent on risk management for climate and environment.
You know that we have, in the last few years, developed our ESG risk frameworks, and we have done that by more specifically updating our origination and collateral valuation policies, but also by setting a set of limits in place that will help us reach the external commitments. Not just that. It will help us minimize the risk of eventually stranded assets on our balance sheet, or, for example, physical events that might happen for the parts of our portfolio or for certain geographies in our portfolio. What we promise is as well on that part that we will continue looking forward. We will continue thinking and planning in scenarios and building this in our risk management. Another one that I would pick is cybersecurity and technology risks. Why? Because, yeah, it's the fear of every risk manager, I would say.
It's something that, luckily, we haven't been through, but it's something that we know is extremely important for all of our stakeholders that we protect, detect, and react well. And while saying that, it is extremely important that we continue collaborating within the industry with our peers, but as well as supervisors and regulators to make our business model more resilient to such risks. And specifically, technology risk is extremely important for ING for two reasons. One is because it presents an enabler and our competitive advantage for our business model. While on the other side, if you're more digital, you're more prone and open to adverse security impacts. That's why it's very important on our agenda and remains positioned very high. And having talked about technology risks, but not mentioning GenAI would probably not make sense.
So my third pick on this page will be GenAI risks and how are we going to manage those. GenAI, as we know, presents numerous opportunities for every business model to become more effective and efficient. Clearly, every opportunity in life and business comes with the risks. What we need, and we have already started doing, we have hired a number of specialists, and we continue hiring a number of specialists that will, together with us, bring the knowledge and build the knowledge of what a good AI risk framework needs to look like. Why is it important? Because, yes, we want to leverage the technology, but we want to leverage it in a responsible and ethical way.
We want to be able to scale up the pilots that we are doing in a sandbox broader into the organization so that there really are impacts on effectiveness and on efficiency of that technology. For all of that, we do need a good AI risk framework in place. This is where we are very much focused on. When it comes to regulation, there is a number of regulations knocking on our door. Probably you're mostly interested in Basel IV, but there is also DORA, for example, a huge regulation that will require certain changes in the organization. They're all meant and working in the direction of creating a more operationally resilient organization. That's why we embrace them. Basel IV is knocking on the door. We still do not know in which form.
We still discuss whether fully or FRTB being out or not being out, only for Europe, what the States are going to do, whether the level playing field will be preserved, how will the globally operating banks interact with each other. Complex topic. We've told you already that we do assume the impact of the Basel IV day one on our RWA of around 20 basis points, and we stick with that statement. You may say, what about output floor? It comes later, but it comes definitely because regulation is there. What is still not there is a number of uncertainties about national discretions, whether and where are they going to be put in place. Then secondly, how the mitigating actions are going to impact the overall amounts up to the 2033 when the output floor actually phases out and actually where the national discretion is also phasing out.
As you know, and we already talked about it, and I think it's moreover in the whole industry, the majority of the impact from that part will come from the fact that unrated corporates are going to have different treatment than today. And I do believe the action here, and we are already actually applying it and will apply it even more going forward, is to increase the range of the unrated corporates in order for them to be rated. So increase, I would say, the range of buying the external ratings and making sure that external ratings are available for our clients so that we can rate them internally. The other big portion of impact that might come is coming from the low-risk mortgages. And this is why because we are, as well, as you know, in geographies where we operate, our mortgages are of very low risk density.
Clearly, by move to the standardized, this is changing. However, also there, we are taking a number of mitigating actions in place, and we will also, through the proactive business steering, make sure that the impact until 2033 is mitigated. Let me wrap it up and conclude. We have proven, I believe, that we have been able and we have managed our risks and portfolio in a consistent way and in a successful way. We have kept and maintained our best-in-class position throughout the cycle everywhere where we operate. Going forward, we will continue doing what we do good, and this is the successful management of our financial risks, while we will as well further look into anticipation of trends, as I said, of evolving emerging risks.
Those are primarily non-financial risks and making sure that we are able to manage them and that we are managing specifically the tail risks coming with those. What I should as well say as something that is very close to my heart and close to the heart of ING, we stay and we will stay very much alert to the changes in the environment, whether it comes from the angle of macroeconomic changes or from geopolitical changes. We will be ready with a number of tools and capabilities to manage the bumpy parts of the road in case they come. This is extremely important. Being aware that the situation might change and being alert that your business and risk strategies need to change if the situation changes is something that we as well as risk management promise to stay with.
We will continue, as I said, working and supporting the digital business model, both of retail and of corporate, in order to further simplify and automate our customer journeys for our customers. This means as well on the risk part, we have to do our homework, and we will continue to do that, as I said, with the help of innovative technologies in a responsible and ethical way. Last but not least, we will continue investing in our people. We will continue investing in their capabilities in order to be able to maintain and claim best-in-class risk management positioning as we do today. As I say, wholeheartedly embracing new strategy, we are going to make the difference, and I wish you follow us on that journey. Thank you very much, and I'm happy to answer any of your questions later. Next to Marnix.
Good afternoon.
I think I'm standing between you and the CFO, which is not an easy topic, I guess. But let me take you through how technology and operations at ING will continue to help grow the business. Clearly, this is something that comes naturally to us, right? DNA was floated earlier on by Steven and by others, but also in practice. It's not just in our DNA, also how we practice it every day, how we attract people, how we retain people. It's really what we do and who we are. And if you look back over the last couple of years, before I start talking about the future, we've done a great deal of foundational work over the last couple of years, which we rolled out our consuming across the company. I'll talk about it. We'll continue to do so.
We have put our Hubs together where expertise gets consolidated, where we got deeper knowledge and experience bundled, where we can easier be flexible with our workforce, but also attract other people and really do this ourselves at scale. Important topic, scale clearly. Also important to mention that our clients love it if they use it, right? If you look at our NPS scores, clearly in the retail strategy that Pinar talked about, it comes back very articulately. We keep on always looking when we use technology and operations, does it really also benefit our clients in retail and wholesale? That's an important statement to make.
Then on the other side of the page, it is also paid off, I would say handsomely in terms of the efficiencies that it's created for the bank, in terms of our total FTE over customer balances, but also in terms of our cost over customer balances. I'll come back to those. So basically, the short version of this introduction is we know what we're doing. We've done it before. We continue to do it. We just do it at a higher scale and basically, again, on steroids. I think that's the starting point here. So when I then look back, we were on this stage in 2022 just to go through our commitments when we talked to you in 2022. On those foundational elements in both technology and operations, we're going to certainly get to our targets that we promised that we committed to for 2025.
Some of those are even going to be exceeded. I think in terms of the way we build our private cloud and we put volume on it, but also how we build our client channels, and I'll come back to that in a minute, also what Pinar talked about in terms of the speed by which we are able to go to Italy and also to other places to roll out technology and up our scale in those markets and our client acquisition. Also in operations, if you look at our Digi Index, which has gone up over the last couple of years, which is, as Steven pointed out, the 350 journeys together in an index where we measure meticulously how we make progress on digital, we have really done a tremendous job over the last couple of years.
I think it's important before we continue just to demystify that STP topic a bit. Not that I'm going to talk about it for very long, but first of all, what is it? What it is, is basically we say, let's put the bank into customer journeys, and let's make sure that when we look at it, digital is only when it's really binary. When anyone has to intervene manually or in any other way, it's non-digital. So it's zero. So everything that you see in the story and throughout all the stories at ING, digital means truly digital. Not as Pinar sometimes calls it, calls it false digital. It's truly about being digital. So we're really kind of honest with each other that when we say something is STP, as we call it, Straight-Through Processing , it truly is. Then a bit on the how.
And I think that's where ING, again, is very different from many other companies because it's not just a technology and operation task to look at digital, right? To build something that someone else can use. When we set our targets, when we define our KPIs and our metrics and the way we collaborate, it's with everybody. So the way I need to contribute towards STP and the digital-ness of ING, it's the same for Pinar and the front office teams or the commercial teams in retail. The same thing for the commercial teams in wholesale. We've got their own targets and also work alongside us. The same for risk, the same for finance together with Tech & Ops. So it's truly the whole company. And then you might probably think, okay, that's interesting, Marnix.
You talk about all these beautiful digital efforts that you're putting in and the clients love you and everything else, but what's the payoff? Now, look, this is just a proxy, but a very important proxy. It's about retail, which is, of course, a large part of the bank. And what I put on the page are just a couple of customer journeys or matrices that highlight what we've done over the last couple of years. They come from a stable of those journeys. There's many more, and I just put them in as an example. And all of these, whether it's private individuals onboarding in the Netherlands or whether it's opening accounts in Belgium, they've massively gone up. And that's what we see across the full range of our work that we're doing in STP.
And that has allowed us to grow the business, new clients, more products, more volumes without linearly growing our costs. There's an 8% benefit over the periods that we have banked and that will continue to do so. So again, it's important that we don't do this just to be nice. We don't do this just to look good. We also do it because it really also from a financial perspective gives us something. And the actual client experience, employee experience, and financial benefits come in the same direction and I would say at the same speed. Maybe just to add two things. First of all, Pinar talked about the campaign in Germany for Business Banking for savings. There's 60% of our clients come fully digital. They could all come digital, almost all of them, but we need to bump that up still as close to 100% as we can.
But that's impressive for us because that really gives clients an easier access to ING, clearly. Second thing is that onboarding, whether it's on private individuals and legal entities, Business Banking across the space of ING, across all our markets, in PI, for example, bar one, all of our markets have got digital onboarding in 2024, and the same applies to our Business Banking clients. So that's important towards future growth for sure. Now, let me talk a bit about technology and operations separately. The kind of the high-level takeaway from this page is actually quite simple. We have built the foundations. Steven started to talk about it earlier on, and all my colleagues have spoken about it. We built the foundations. We'll continue to push those foundations. So consumption needs to go up across the franchises.
Secondly, products we've built, product solutions, will add to those product solutions over the next couple of years, and that's also something you heard earlier. And then last but not least, our engineering experience platform where all of our IT colleagues, engineers, software, infrastructure come together, will get expanded, will get improved, and we'll make sure as many of our colleagues can get on it and basically to contribute, foster, share technologies, share solutions, but also add local flavor where local flavor is warranted, right? Because we are still a bank in all these local markets, but not everything is singular. So that's the high-over. And so we need to get our colleagues on board, get new product engines developed, and make sure we consume as much we can.
The only real boundary we've got for consumption is some regulatory requirements or limitations in certain markets, but those are very few and far between. What we will do is to leverage what we already have. If you look at, for example, payments, we have built payments facilities, solutions over the last couple of years, was also mentioned previously. We have 7.2 billion payments at ING, of which 54% is already on that platform. We'll continue to push it. We have built a contact center platform, technology and operationally, that is in all the markets except for Australia, which follows in 2025. The Financial Markets business, we've invested in to make sure that standardization of products and also improvement of pricing and important things for FM can go across the world to the most important locations. We'll continue to do so.
Our Lending platform in wholesale is reaching almost all corners of the globe at ING, and we'll continue to push it. I think what is important is that we have done this over the last period. We've done this over the last couple of years, and we can do more of it, and we will do more of it. Then what will we add? Well, we'll certainly add in retail, as we talked about earlier, consumer Lending. We'll do investment products as an important feature. We'll also have insurance to add. That work has started, and that will continue, and that will help us grow those local franchises in retail, including Business Banking over the next period.
In wholesale, it's important to mention that if you look at payments, you look at cash management, it will allow end-to-end teams to deepen our profile and our offering in Spain, or certainly also in Germany and in Australia. I think just to come back to it, the speeds, and nothing is still. I know that technology is never really speedy, but the speed by which we can do this has gone up tremendously. I want to focus on Italy, where we have over the last 12 months really reworked the bank tremendously front to back in terms of our capabilities and our abilities to really go to the clients smoothly in the ING fashion.
And also, I think when we look at Belgium, and although there's still a lot of work in Belgium, it couldn't have been done without these foundations and shared elements as we have used them over the last couple of years. And I think that's really important to mention again. Now, one thing I haven't mentioned yet, which of course is tremendously important, but I saved it for last because it's a bridge, AI and GenAI. So AI we have used over the last couple of years. I don't want to make it sound too mundane. GenAI, we've only more recently started. But again, it's important to say it will be with us, and I'll talk to those topics in a minute. It will be with us.
It's already here, and we are really focusing on the big ticket items in GenAI to make sure we do the best with those opportunities for our clients and for ourselves. Let me then wrap up for technology. So I think I've kind of implied it. It is more consumption of what we have, adding product to it, and making sure we've got as much as possible our colleagues on the platform from a contribution perspective. We'll get increased productivity. Time to market will be reduced. There's more personalized client solutions that we can push and use across the markets. Reliability and security, as was already mentioned by Ljiljana, certainly with DORA coming on and operational resilience taking pole position in Europe, very important. And last but not least, I think this is never going to work without being attractive for engineers around the world.
So having that big contributor platform, I think, is very important for our colleagues to feel that they can have impact at ING and also new colleagues to come on. We'll simply look at how many of those engineers are on that platform as a metric and how many of those shared solutions go around the world and are being consumed. The AI GenAI was my bridge to operations. Again, I said we've built digital over the last few decades and certainly over the last couple of years, we have improved and increased our digital rate at ING. We think we can do a whole lot better still and actually do a whole lot more of it over the next period. What we said, let's choose the big topics that we can really make a big difference.
The four in retail and the four must-wins in wholesale really are the largest areas where impact can be maximized. For us, those focus areas are critically important. I'll talk about contact centers in a minute, but contact centers in retail and wholesale, Lending in terms of mortgages, but also Business Banking Lending and wholesale Lending, Financial Markets, and trade processing, those are the big items. We think we should at least be able to have 25% efficiencies in these focus areas. That's what we're going for. Those are included in our plans, and those we will go over with our stakeholders over the next period to make sure we do this in the way we always do in bite-sized chunks, and we take everybody with us when we go for execution.
So having said that, two examples, and these are really, I find everything exciting in this, I must admit, but these two are really exciting. And let's talk about contact centers. So Pinar spoke really eloquently about taking friction away, right? We really get excited about frictionless banking and trying to make sure that our clients don't have any problem doing what they want to do banking-wise with ING. But 95% of our calls is because of friction. 5% is because of something meaningful for them. So we need to take that friction away. And we'll use the maximum input towards higher STP rates, but we'll also make sure that when there is still a need for information or something needs to be resolved, that we'll use other technology like our chatbot today to make it easier for clients to have more speedier and better resolve interaction with the bank.
Now, we already use a large language model of GenAI chatbots. I don't want to say, because I don't know exactly, but a lot of people tell us we were the first in the market. Certainly, quite a few people in the world have been saying that we were the first in the market. So I will say we were the first in the market, but you didn't hear it from me. And why do I say this? Because, look, like Liliana said, we do this very prudently, but we'll also say we don't do this across everything that we got. We choose our focus areas very maturely based on what we can achieve and when we can achieve it. And in contact centers, that's one of the big items that we've chosen to use GenAI.
We already said in the previous period, we will reduce unnecessary contacts with clients, in other words, that they have got something that doesn't work with 30% of the 2025. That will be achieved for sure. Actually, we'll go over it. And now we're saying we'll go 60% lower up to 2027. So we really think with what we have built, what we've got, and what we can do, we can take a lot of that friction out and we can reduce the load on the contact centers and the load on our clients. And that's all based also on our experience that we can have a chatbot adopted by 75% at least by our clients. And also the deflection, in other words, what can it resolve is also at least up to 75%. The other side of the page, mortgages.
We're going to be the first bank in a market in Germany to launch a fully digital mortgage in 2024, which is really, really fantastic. We're going to use this, as you also know, in other markets. We're going to bring it to other markets later. What we will do is we'll get that introduced in 2024. We'll expand it in 2025 and years beyond. For our new flow in 2025, we estimate between 15%-70% fully digital. In other words, from our flow or new flow in 2025 and up to 50% by 2027. That allows us to have a time to yes, which is 80% quicker than what we got today, which of course is the most important thing. It's not necessarily about when you pay the money. It's when you can say to the client, yes, you can have this mortgage, right?
So this is something that really excites us. And again, there's lots of stuff that excites us, but this is very good because we're the first ones in the market and we can really leverage on it. Then, summarizing on operations, we will use a lot of tech, obviously. We'll continue to do so. We become a lot more digital, seamless. Our productivity, as I said, 25% on the big topics, on the must-wins we should be able to achieve. High quality, consistently, very important. Also here, attracting talent. We shouldn't forget also in operations, when it comes down to the world going forward, it's more complex. So we need different types of skills. We need different types of approaches. And hence, I think if we can offer this kind of digital environment to the existing colleagues, but also new colleagues, I think that's going to be very conducive.
Lower cost of serve, obviously, on the back of what I just spoke about. Kind of concluding, 85% Digi Index is what we should have at least by 2027. We should have an improvement in FTE over customer balances by 10% at least. Probably the page you hoped for at least, or at least something along these lines, cost. What's the financial impact? The summary is quite simple. We continue to invest in technology because we believe we can really still make a big difference with that technology. We've done it before. We're doing it today, and we're doing it tomorrow. We also believe there should be a real yield on it, and there will be. That means that our overall operational cost will go down at least. That's what we are saying here. It's important to then get those 8 must-wins done.
I'm convinced we will because we know we're doing, but that should then lead to this picture. Summarizing it, get our colleagues on the platform that we can contribute technology locally and globally, making sure we got more products shared that can go to the markets more quickly, making sure that in wholesale and in retail, we can grow as we have just talked about today. We need to make sure the digital service goes up to tremendous levels of at least 85%. Apologies. Of course, we need to become more efficient and productive on the back of it, which is the last topic that I put on this page. That's it for Tech & Ops. Thank you.
Hi, thank you very much. You heard this morning, or sorry, this afternoon about the strategy as outlined by our CEO.
You heard about our growth plans in the retail bank, the capital discipline in the wholesale bank, the risk framework that we have done, and the scalable ops and the scalable tech. So what I'd like to do now is to give you some of the details of the financials. And the three takeaways I'd like you to take with me in my presentation is number one, we are in a good place financially, very strong, building the foundations and ready for growth. The second, I want to give you some details about the financial guidance that we will give over the next three years, ambitious plans that we have. And then the third is what does it imply for our enhanced return on equity target for 2027 of 14%. Okay? Now, let me tell you about why I'm very confident about where we stand financially today.
The first thing is that we're highly diversified in how we operate our business. You heard from Andrew how we're diversified in the wholesale bank, right? Multiple locations, multiple products. That's highly diversified. The same you can say for retail banking. You hear from Pinar's presentation. I really like the bubble chart. It shows how many domestic banks, really strong domestic banks that we have with big operations in Belgium, in Netherlands, in Germany, and in Poland to name but a few. Highly diversified. And we have proven ourselves over time in terms of our risk management and our ability to manage risk. So that's one key story that I like to emphasize. The second part of the uniqueness of ING, and as we engage with each other over time, I kind of alluded to it every time, is that the balance sheet of ING is unique.
It's unique in its ability to finance itself using predominantly customer deposits, right? 67% of our balance sheet is funded with customer deposits. It's highly stable, highly granular, incredibly sticky, very predictable. So that's the second aspect that I want to highlight about our franchise. The third aspect of the franchise is that we have ample buffers. We're highly capital generative, and we have a predictable business model. Okay? What does that mean for you as our shareholders? It means that we're able to have a structurally improved profitability over the past few years, and we've been able to return quite a significant amount of our cash in terms of share buybacks, right? We've been doing share buybacks since 2020 or beginning of 2021. And up to the program to date, we have bought back 19% of our outstanding shares. I repeat again, 19%, right?
That structurally improves our earnings per share. It structurally improves our return on equity. Now, just on what we have delivered in terms of our journey from the last investor day, we have been able to grow, right? From this page, you see that we've been able to have net growth in balances of EUR 62 billion. So we're confident about our future. We've done it before, and we believe we can do it again. The second aspect, and you see it comes through our financial plans, is fee income, that we want to grow our fee income. We have quite an ambitious plan for fee income. And what I'd like to highlight here is that daily banking fees, which is very stable in our engagement. We say this is one of the most stable parts of our fee income.
A growing part of our fee income has grown significantly over the past period. To give you a bit of perspective of how structurally we've changed, if you go back and look at ING back in 2020, daily banking fees represented 27% of our total fees, okay? By 2023, that ratio has increased to almost 40%, right? So we are structurally a different fee machine than we were three years ago. Now, we, of course, will continue to focus in terms of optimizing our cost base. We continue to migrate a lot of our operation footprints into operational Hubs. We continue to close physical branches as we become more digital. And we have taken the discipline when we don't believe that we achieve scale in either wholesale or retail banking to kind of trim the network that we have, okay?
The last but not least is that we are generating capital at a higher rate than we were previously, structurally higher profitability, and particularly in the wholesale bank, higher income on risk weight. You hear that mantra across both our retail and wholesale banking, is to bring greater intensity to our franchise in terms of income over risk weight. Now, to the outlook. Three things I want to cover on this page. First, we believe we can grow. Our guidance is that we can grow our balances both on loans and liability at a pace of around 4%. Second, we believe that we can manage well our margins, right? A point I want to make is that even if the ECB rates go from 4%-2.5%, we believe we can operate well at either interest rate footpoint points.
For example, today, we are ending up at around 110 basis points in terms of margin on liability. We expect that we can manage within that range of 100-110 basis points. And the same on Lending. We think we can operate at a Lending margin of above 130 basis points with some upside even beyond that. Overall, our guidance is that our net interest margin will range around 150 basis points at bank level over the planning cycle. Now, fee income, a very important part of our story. Two points I want to make. Why are we confident in terms of making fee income? Because we have done it before, and we're going to continue to deliver on that promise.
We are giving guidance that by the end of 2024, our fee income will be approximately EUR 4 billion, and we have the ambition to grow that fee income by a further EUR 1 billion by the end of 2027. Now, the way I look at fees is in two parts, right? I look at fees from what we call beta, which is things that are driven by market movement, stock market movement, loan growth activity, mortgage activity. But what I really like to focus on is what I call the alpha, is what can business, what can we as ING manage ourselves in terms of delivering a greater fee momentum. Daily banking, why are we confident that we can grow daily banking fees? We just discussed it about the structural change in the way we charge fees within the bank.
And also, we have the ambition to add 1 million primary mobile customer a year. That drives fee income. We also will drive fee income by to have more differentiated packages of what service they would like and at what price point they would have these fee services. Another area is Lending. You heard from Andrew about our plans to be more capital light, to be turning over our balance sheet more, and that will drive greater DCM, Global Capital Markets fees. But what I'm really ambitious about is the investment funds business, people with investment accounts with ING. Today, we have 4.5 million customers with investment funds with ING. Today, we have 39 million customers. So the runway to increase the participation of our clients in investment funds has a long, long runway ahead of us, okay? Now, to investments.
We basically will continue to invest in our franchise to deliver the value that we see in the future. But the first thing I want to highlight is that we do see, however, that labor market wage inflation remains tight, at least over the next period, particularly in 2025. And that's why we're guiding that inflation, both salaries and procured expenses, will be around 3% or so. The second aspect and the second outlook that we have is that whatever we invest, we believe we can compensate for that through savings over time. And then you might ask, what are we investing in? I think I can bucket it in three things, okay? The first, we will invest in customer acquisition. That is basically acquisition costs, marketing spend, and adding selectively front office staff to basically increase client acquisition. That's the first bucket.
The second bucket of investment spend is actually around product, broadening our product offering. You hear Marnix talks about enhancing our Financial Markets plans, increasing our payments engine, to name but a few on the wholesale bank. In the retail bank, another good example is what we're doing in SME Business Banking in Germany, what we're doing in terms of building out our businesses in Italy as an example. Then the third areas of actually investing is in the scale of our operation with respect to technology spend. These are big long-term plans that we have. These are three buckets where we will invest in our future. Where do we save? Well, you hear from Marnix also the big ambition, the must-win opportunities that we have.
Something that he went through rather quickly, but I want to re-highlight is today we have 31 million customers, or back in 2021, 31 million customers who call our call center, right? And many of those calls are because they're experiencing friction in our call centers. What we have already done is that we reduced that call volume by 18% by the end of 2023, okay? The ambition that we have is that that friction call numbers will go down by 60% over the next three years. This is a big deal. And he's right to be excited about these ambitions, okay? So this is a little bit about how we're looking at the cost numbers. And we believe that our cost over the next three years will grow around 3%-4%.
So bringing it a little bit all together, what do we see as guidance with respect to our cost and our income? We guide that our income will grow between 4%-5% over the next period. Our cost will grow from 3%-4% over 2027, and that our cost-income ratio will range in the point of between 52%-54%, okay? The question is, how does this impact our return on equity and our capital distribution plans? Three points I want to make in terms of return on equity. The first guidance we want to give is that we believe we can achieve with these plans a return on equity in the retail bank of consistently above 20% over the coming period. The second guidance that we want to give is that we believe the wholesale bank can deliver more than 12% return by 2027, okay?
So, strong, high levels of return on equity for both divisions. Having said that, we are on a much more capital discipline place in terms of the wholesale bank. We're in a growing phase in the retail bank, so you would see a shift in our capital allocation from retail to wholesale from roughly equal to around 55% in retail banking and 45% in the wholesale bank, okay? What does that mean in terms of structural profitability to get to 14%? I'd like to give a somewhat different lens of how we build that step up in terms of returns. First, we are going to converge on capital levels of around 12.5%. We've done that before. We were going to continue to do that again, okay? We're going to improve our fee income. That would make another step up in terms of our return on equity.
We've done that before. We're going to continue to deliver on that as we go forward. The third aspect, we basically are going to shift our capital allocation. We already demonstrated in the past 2 years capital discipline in the wholesale bank. We've done that before, and we can continue to grow in the retail bank. We've seen that happening in the past 3 years. We will continue to deliver on that going forward. And last but not least, we will deliver on operating leverage. Again, we've done it before. We're going to continue to deliver on that. Now, just on capital return, 3 points to make. The first one is we are very disciplined in how we spend the capital that we generate. We have a clear waterfall of how that happens in terms of making sure we meet buffers requirement, regulatory requirements.
That's the first primary use of our excess capital. The second is actually fund the growth of the franchise. And as Steven has mentioned, selectively look at M&A if it meets our stringent requirements. The rest, we look to return to our shareholders. So clear focus in terms of capital discipline. The second is that we reconfirm our targeted quarter one level of around 12.5 by the end of 2025. And as you know, we give updates on our capital management action twice a year. We're in the middle of a share buyback today, and we'll give you an update in terms of our next steps in terms of capital in our third quarter results at the beginning of November. And the last but not least is we reaffirm our dividend policy of 50% of resilient profits. So not much change.
It's steady business as usual from a capital strategy perspective. Now, just to summarize, I'd like to summarize three things. We are in a good place financially. We're structurally profitable. We're highly generative of our capital, and we have laid the foundation for growth, number one. The second, we believe that our ambition for return on equity is an ambitious one at 14%, but we believe that the execution risk in terms of getting that is low because it depends on levers that we have deployed before, and we're going to continue to deploy that again. And last but not least, we come into 2024, as you've seen from our first quarter results, with a lot of commercial momentum, and we expect that commercial momentum to continue to be there going forward. So that's it. Thank you very much for listening to me.
Then we're going to turn it over to Sjoerd Miltenburg to handle the Q&A. Thank you.
Yes, so after the presentations, we're now ready to commence with the Q&A part of today's program. We will have questions coming in in different ways, so we'll have our virtual audience who can put their questions in the chat. And for the audience here in the room, please post your question after you've received the microphone for the benefit of our virtual audience so they can also hear your questions. So on that note, let's begin. Benoît.
Yeah, thank you for the presentation. Benoît Petrarque from Kepler Cheuvreux.
I just wanted to come back on the shift of the capital allocation, just to understand if this is mainly just an organic move, so growing faster in retail versus wholesale, or is there any kind of one-off capital allocation decision, de-risking actions on the wholesale bank which will move the shift? Linked to that, I think I heard Tanate talking about 4% growth. Could you help us to understand how much growth you expect from retail? I guess it's more than 4% versus wholesale, probably less than 4% in terms of balance sheet growth. So that's question number one. On the fee growth, yeah, very interesting, the alpha beta discussion. On the EUR 1 billion fee growth, how much is coming from beta versus alpha? It will be interesting to get your views on that. The final question will be on the cost growth.
So you have a business growth impact on expenses of about EUR 600 million. This is the 2% CAGR. So now looking at the operational side, it seems that you are going to get to a 25% efficiency on some of the processes, which is about EUR 600 million cost cutting. Is that the real figure you have in mind, or just to confirm a bit this idea? Thank you.
I was tasked by being the moderator for this Q&A. You asked four questions, not three. And a lot. But let me, I think we first need to talk a little bit about the capital and how we move the capital, which is largely, by the way, autonomously. But Tanate will talk about that.
We will also then talk about Tanate, and then I think we move to Marnix to talk a bit about the four times two big wins in the operations domain.
Okay. I think our plans in terms of risk weighted assets shift is organic, right? But the organic in the sense that we will consider significant risk transfer, loan sales, turning over our balance sheet as being organic as well, right? But we don't expect incredibly large, lumpy transactions in the wholesale bank to deliver that shift. It's a question of maintaining that discipline in the wholesale bank and growing, as Pinar has mentioned, in the retail bank. And I think the second question you had was around loan growth.
I think you're right in terms of our expectations is that we expect that loan growth in Eurozone to be a bit more modest than 4%, non-Eurozone growth to be higher, and that Lending in the wholesale bank to be the least growth given the fact that we're going to turn over our balance sheet more. But the blend of it is around 4% expectations.
Fees. Yeah, there's one more on fees.
Sorry, I was so focused on the first two. Oh, alpha and beta, yes. Well, I think it's hard for us to distill how much it's alpha and beta, but I think we are really focused on delivering on the alpha aspects of it, right? Fundamentally, the key big drivers why we're confident is that we continue to have strong ambition in terms of growing the number of investment accounts. That's one big driver.
The income over risk weight to improve that by 50 basis points, that drives it. Then the rest of the way is really another million primary mobile customers every year. These are the big drivers of our fee income.
Okay . Then we move to the year, the 25% that was mentioned. By the way, it was the 25% on these journeys.
Yeah.
Maybe you want to elaborate a bit.
Yeah. So first of all, bear in mind we're growing the bank, so we can either do more with the same or we can reduce. There's two options here, and both apply across what we're doing over the next couple of years. So that's point one. Point two is that, look, we will go through this over the next period.
Yes, these are firm plans, but we also need to work with our stakeholders to make sure that we know exactly what we do when. So I think that's where I'm going to leave it today.
Okay. Raul
Thank you. It's Raul Sinha from JP Morgan. Maybe two issues. The first one is on just staying a little bit on the volume growth, but on the loan growth side. Given this is an external factor, loan growth depends upon customer demand, especially within your risk appetite. If you don't get enough customer demand, do you still feel confident about getting to your target? What are the levers you could pull? I guess that's really the question. The second one is sort of related to this shift in capital allocation, but just looking at the divisional targets you're setting. So retail gets 20%+ ROE, right?
Wholesale makes 12% plus ROE, and ING makes 14. Why does wholesale get a lower hurdle rate? And do you think that this shift in capital allocation, 55%, is this the start of a bigger journey, or do you think 55 is the optimal level for ING to operate at through the cycle? Thank you.
Okay. Let me take the question on the capital allocation, and then you can say something more about it. I think in the end, we look at the bank as one. So there are many parts that are separate, but there are also many overlapping parts, including the way we operate in our payments business, including our Financial Markets business. And at least we want to make sure that we make a return overall that is adequate from our shareholders' of view.
We are moving now from, let's say, a 12% target or over 12% target to a 14% target in the next three years. What we do say is that we want also wholesale bank to further grow their return on equity. Still, as far as we are concerned, surpassing what would be required. As long as we are above what is required, we add economic value. In that sense, wholesale bank can also further grow. But to make sure that they grow adequately, also with using the right amount of capital, do on the capital side. As I've said to you in the past, we came from an environment whereby we were very focused on underwriting and then holding.
We eat what we underwrite to moving much more towards we underwrite and hold, but we also underwrite and sell so that we can work much better and more with our clients than we have done before. 55-45 is the direction of travel that we have for the next three years. We will continuously look at what we can do more, for sure. Andrew showed it on his slides. In terms of what we have been doing so far compared to our peers in terms of capital allocation or capital diet, has been very limited. So most likely, we will continue on that path, but we first need to train a muscle. That is what we have done over the past couple of years. That's what we will now do for the next three years. Then we will update you further.
And then Raul, on your question on loan growth, we're confident looking at the environment where we are that we can achieve these loan numbers. I think a couple of points that I would say on levers that we would pull. We talked about us being diversified, right? Sometimes the Eurozone, Northern Europe is slow on mortgages, but we saw strong growth in Eastern Europe. Sometimes U.S. is running high. We see slowness in Asia. So the diversification aspects of it helps. The other levers that we would pull is margin, right? That we had talked about the margin being 130 basis points. Historically, it's been higher. We can actually play with in terms of margin depending on loan demand as well. So these are different levers.
That's why we come back to one of the mantras that we have at ING, that diversification in income, in geography, in sectors stands us well.
Tarik.
Hi, good afternoon. Tarik El Mejjad from Bank of America. Three quick questions. First, I'll start with revenues. I mean, it's a good effort. The fee growth and you've been showing quite actually growing at the height of the range lately. But you know me now. I mean, the same question. I mean, I was expecting something a bit different. I was expecting some more strategic shift in terms of generating the fees. So primary clients is number one thing to do, I agree. But I mean, what really blocks you to go for some initiatives to create new products, I mean, new product offer? So you have the primary clients' growth, but then also the number of products you can offer.
At the moment, when you look at the product you have on the retail side at least, I mean, you have savings, mortgages, and some third-party products you can offer. But what's the opportunity there to really, I mean, and you showed the opportunity by countries. So you have this chance to be diversified by countries, which multiplies the opportunity for you to find opportunities to grow. And so is that something for later? You want to stabilize first the business and then look for more faster non-organic growth? Or is it too difficult to really even contemplate? So that's question number one. And then on the capital, I mean, joins a bit the discussion we had on loans. I mean, I know it's not exact calculations, but I think that you probably expect to grow RWAs above Lending for retail, Lending growth.
And then on the wholesale banking, probably slightly below if we adjust for the 20 basis points up risk first application next year. So I mean, you showed under the slide with the SRT and upside there, but we're expecting a bit more capital velocity and RWA workaround. Is that something that's an upside? And there's upside in your guidance, and we can actually have better control of RWAs and then higher ROE in wholesale? Or this is really what you think you can do the next three years? And then one quick question. I mean, on the bubble chart, I liked it as well. I think this is a great chart. And it would be better if we had the bank in one because you can actually merge them all in one and optimize your balance sheet. So it's a bit tricky question.
But given all the uncertainty we have in the political space at the moment, do you think this banking union, capital markets union is something shelved or best case delayed? What's your sense in there? I mean, when you are one of the biggest banks in Europe, and it would be interesting to hear your view. Thank you.
Look at my interview and Les Echos from last week. So I'll take the one on the fees, and obviously, I'll take the one on the banking union. And then Andrew, if you can say something about your capital adequacy. On fee income, I think we're not so far apart from in terms of what you're asking and what we're doing.
I think what we have said is we say, look, we have all these customers and even these primary customers, but we can be much more bespoke about what we offer them. We offer the same things to someone who's Gen Z or mass affluent or the average ING customer or a pensioner or an expat. We offer them, not always, but mostly the same things. And what we need to do, depending on the market, because there's different speeds per market, we need to offer them something more bespoke depending on who they are and what they exactly need. That is, next to the growth of our primary customers, the most low-hanging fruit. We have already these customers. It's just a matter of making much more impact and be much more relevant to them than we have done before. So we will offer more to them.
The second thing we do is, rather than going to a new country, is to say, we already did Business Banking in some countries. We already did self-employed digital in the Netherlands. Why not export these things that we have done highly successfully to the countries in which we're active, but we're not really yet the force in society or the economic environment in that country that we want to be? We can just extend that to other market segments as well. That is the focus that we currently have because there is a lot of low-hanging fruit that we have to do that within the current geographical footprint.
And again, if there is an opportunity to further accelerate that by either means of, let's say, here I say, domestic consolidation or retail by moving clients from other banks on our platform or buying a certain skill set to broaden the offering, then we will look at it. But again, it needs to make sense from a culture point of view. No structural integration challenges. Focus on synergies both on a revenue and a cost side. Those are the key lenses that we look at when we look at these opportunities. And it leads nicely into the banking union. Yes, of course, for a bank like ING, a banking union is very helpful because we are arguably the most European of the European banks in terms of the number of countries in which we have significant presence. It is not only about capital and liquidity, by the way.
It's also about the regulations around products and the cultural differences. A mortgage in Germany is different than a mortgage in Poland, which is different than a mortgage in Spain. Even with a banking union, that is not necessarily going to change. So also product standardization is also something that's required. But undoubtedly, from a capital and liquidity point of view, a banking union would favor a bank like ING. Am I more optimistic than before? That depends on the time frame in which you asked me the question. When before? I think there's at least more conversation now also at the political level and at the ECB level that a banking union makes sense. We heard, of course, Macron talk about that a little while ago. We also hear the Germans talk about the Capital Markets Union. We hear the ECB talking about it.
So it's a bit more front of mind. Am I optimistic it will be there in the short term? The answer is still no. Andrew.
All right. So in terms of guidance, we've shown you that we have a route, that we have a target of 12% longer term. And obviously, that builds on the 10% that we achieved that we looked to set originally in 2025. So what are the building blocks of that? Firstly, on the income lens, what is the income mix that we can enjoy and build on, whether it's fee income or non-interest income from a Financial Markets platform and the build of our capital markets capability? We'll continue to work out how that weighs. And some of that, to Tanate's point, some of that relates to beta. Some of that relates to capability builds. We'll continue to look at that.
And so that becomes live. I think in terms of the cost side, I talked about driving the efficiency there, and that will continue through leveraging the work that's being done. On the denominator, the capital, how do you get the return on that ROE? For us, when we think about how we manage the business as a team in the wholesale banking business, we don't focus on Lending volume in and of itself. What we focus on is the leadership in transactions and then the ability to distribute. So we're going to continue to look at how we get better, less holds in the primary syndication phase, more leadership positions, continue to drive the secondary work we've done, what we've done also on CPRI as a lever. We do have risk participation partnerships, and SRT will continue. So we'll keep working all three levers.
I mean, look, we've given the guidance at 12%. We're now going to go and execute that. What I can tell you is all the wholesale banking teams understand the capital diet. They all understand we need to be leaner, fitter, better. And we're just going to obsess with how we drive all three of those levers. But definitely part of that is just continue to drive down the denominator to try and work towards that 55-45% weighting.
CPRI is insurance, by the way. We buy insurance on it.
Thank you.
Thank you very much for taking my question. I'm coming from RBC. Two questions, please. The first is on your organic RWA growth. X bar is at four. Do you have a target and what you expect? And if the RWA growth is not coming through like in the past, I assume you would return the capital to shareholders.
Then the second question, thank you for laying out the numbers so clearly. Where's the flexibility in the plan? So I suppose you do a lot of investments upfront for the revenues to come in. If the revenues are not coming in, would you slow down on costs or you think, well, the 27 ROE will then basically deliver it later? So how should we think about the flexibility adjusting costs if the revenues are not coming in by 27 as you expect? Thank you.
Okay, Tanate, where is the conservatism in the plan?
Everywhere. I think, first of all, we don't expect that the risk weight intensity of ING would change dramatically over the planning cycle. Okay? I think the wholesale bank, we have been able to keep the risk-weighted asset actually flat to declining the past three years.
We expect that trend to continue to be achievable over time. I think looking at the risk-weighted assets increase in the retail bank, we also don't expect the intensity of risk weight to pick up. To confirm, we have a clear waterfall in terms of use of our generated capital. We build for buffers. We build for growth. Whatever is left, we give back to our shareholders, barring any M&A transaction that meets our stringent requirements. The flexibility against the plan, I think we don't want to give the notion that we invest now and that the savings will come three years from now. That's not what it means. We basically try to make sure that that formula of 2% of investment and 2% of reduction happen consistently, right? It does not mean that the 2% reduction comes from the new investment that we make.
It's come from previous programs that we have already executed that delivers value. So some of what Marnix have talked about in terms of operational leverage that delivers the closing of branches in Belgium, in Poland, in other places, that will already feed through into our 2024, 2025 numbers. So there's a balance there. It's not invest first and then delivery later.
So the RWA growth is below the volume growth?
It will be the same intensity, roughly, as it is today.
Julia?
Thank you very much. If I can just follow up on this last question. In terms of operating jaws, would you commit that you will achieve operating jaws every year? Because I get it to 2027, but 2025 perhaps looks less straightforward to me. So that's my first question.
Then secondly, Liliana, on Basel IV, assuming for a moment no mitigating action, balance sheet as it is today, what would be the 2033 impact? And I get it on unrated corporates that you want to get them rated, but what about mortgages? What is the offsetting measure there? I didn't quite get it. Thank you. And if I can add a third one, on wholesale banking, I think the opportunity to grow deposits is quite materially a positive rate environment. Why hasn't this happened already? So what is going to change there?
Thank you. Good. Okay, we first go to Tanate.
I like the word you use, commit, but we give you an outlook.
But at the same time, there's a transition that happens, particularly in 2025, where the replicated income on liability will be a bit more challenging given the fact that we're going to move likely, if you look at the forward curve, from 4%-2.5%. So that's why in one of the pages, I said that our cost-income ratio will rise a little bit and then come down to our targeted level. So it's not every year that we'll be there, but it's driven not by something that we're doing internally within ING. It's more the shape of the curve that we see going forward, particularly 25.
Good. And you see it on that slide, you see the cost-income first moving up and then moving down again. That assumes that curve change. Then Basel IV, which you spoke about so eloquently.
Yeah.
I'm sure you're aware, Julia, and all of you are aware, there is a discussion in the industry going with EBA on the disclosure on the output floor at the level, as you'd explained, it's static gross. And actually, there is not much willingness from the banks, I would say, to go that way because it's obvious that we are talking about almost a 10-year period and the number of available mitigating actions that the banks will put in place to mitigate there. So what I can say for our portfolio is that we've proven in the past that we are able to manage the RWA. We have decreased only on the wholesale banking side by EUR 32 billion in the last few years. So the intention going forward is as well to apply the same, I would say, capital diet, capital discipline in order to mitigate those measures.
So I'm not sure there is a benefit of talking about static balance sheet as it is today because it's going to change. And plus, we already started applying these mitigating measures. So I would say disclosure moment depends very much on the agreement with EBA when the banks are going to need to disclose this impact. On the mortgages, you're right, there is not much to be done specifically if you're in the better part of the Europe where the IRB current, I would say, low RWA density is lower than the standardized. But that also depends, as I say, in a 10-year period, where are we going to structure our mortgage books going forward?
For example, as you know, probably the southern part of the Europe is less affected because already the IRB LGDs are at the level which are closer to the impact of the risk weights that is going to come from the standardized approach. So in the end, it is the business steering. It is where you want to grow your mortgages in the future in order to try to mitigate this effect. But again, this is not the biggest effect that is coming of our portfolio. The higher impact is coming clearly from the unrated corporates, which we have already started, as I say, getting the external ratings into the bank, and we are able and confident that we'll be able to manage the overall impact therefore until 2033.
Thanks. Can I follow up on that?
So if your plan is to throw mortgages where they are slightly riskier or maybe even throw more consumer credit, are you still confident that cost of risk is a basis point?
Well, 20 basis points is a cost of risk that is historically being proven, as I've said. So it's backward looking. As you know, we never give the forward-looking view. I'm not sure that this 20 basis point is going to be the risk cost of the future in three years, in five years, whatever. I'm also willing to take stronger risk costs in case the profitability follows. So it's not about 20 basis points risk point. It's something that we have proven our risk strategies once put in place, they're working.
However, if there is a specific risk return that enables this risk cost to go even higher, I think we are all happy here to discuss this topic. So I wouldn't talk about 20 bps risk cost now in three years, or in five years. It's going to depend on the risk return that we're going to gain.
Okay. Andrew. Why did you not do this before?
So maybe give you my own personal perspective on it. I think that my first time working in a European-based bank with negative interest rates when I joined ING in 2021. And there's something about the history of ING that we have these phenomenally strong retail deposit bases that are being built, particularly in Northern Europe over multiple years. And I think what that created a negative interest rate environment was the wholesale banking business was an avenue to generate assets.
Then you layer in our very strong history, which was the bedrock of our sector expertise, which came out of our structured finance history. I think that we had very, very strong capability around structured finance and deposits. While we built good capability in European cash management, it didn't have the same strategic priority that I've been used to historically. Having said that, you made the point in a positive interest rate environment that changes because we're able to deploy that liquidity support. As I said in my comments, we're circa EUR 75 billion today. If you're benchmarking, we would be EUR 250 billion. I'm not saying wholesale banking deposits go to EUR 250 billion straight away. But over a 10-year window, there is opportunity for us to ask for our clients for those deposits.
We have a very strong credit rating, and we have the cash management propositions to be able to support that. But it's not just deposits for deposits' sake. It's making sure that we earn the right margins, delivering services across our platform. So it's a multi-year journey that we're on. But maybe I'll pass it back to Steven. Maybe I missed the history before I joined. No,
No, you did not. And I think that by building these three differentiators and by building a long-term relationship, it also plays you in a position to get the right deposits in against the right price and to develop a strategy. So you also need to make sure that you build a sticky relationship into wholesale banking to also build a deposit strategy on the back of it. And that's what we're now doing.
Ben?
Yes, thank you. Benjamin Goy from Deutsche Bank.
Two questions. One on Business Banking , one on the remaining stakes you have. You mentioned Business Banking as a growth opportunity. Maybe you can highlight a bit more the time horizon or what percentage or just give a bit more color about the magnitude of the opportunity because at the moment, it might be coincidental, but you're particularly strong in the markets where you have a branch network still, even if it's small. It seems like in retail, the digital adoption is quicker than in SMEs, for example, if you look at also in the fintech space. Is it changing? Yeah, so what's the opportunity in Business Banking ? The second question would be, you cleaned up your portfolio a lot in the last years, always with a lens of capital efficiency. Still have two stakes into Asian banks.
I was just wondering what's the criteria for them to remain strategic or whether they could become non-strategic and fund maybe another share buyback over time? Thank you.
Okay, for the first question, we'll go to Pinar. And please know that Pinar also talked about the Netherlands and said we have less than 35 branches in the Netherlands. Remember?
Pinar. Yes, I will repeat that. Thanks, Steven. Thanks for the question. As I said, the way we do Business Banking is very different than most other banks. So we do it in such a way that the majority of our clients, who are self-employed to even mid-size SME, we do not have branches. We do not have bankers. So they are primarily sort of digital, also in markets like Belgium, which is a pretty branch-based market, also Netherlands.
When we have advisors and bankers who are trained for it, they serve our clients. We call them the relationship segment for the mid-corp clients. And then when our portfolio of clients who has no banker assigned, but if they need an advice or any capability they need, then we use our remote advice centers. So therefore, we do not have a Business Banking operation based on a branch model. And therefore, we feel very confident since we have done this in the markets for years and recently really investing in this capability both in Belgium and Netherlands that we can export it to markets like Germany, Australia, and also Italy in the future.
Good. Tanate.
Yes. Two points. The stake in Bank of Beijing and TTB used to be reported in retail banking. It's no longer reported there, but in our corporate center.
It gives you an indication of our thoughts whether something is strategic or not. In the meantime, we get the right return on equity from these investments. And I take your comment with regards to capital management. But of course, we don't disclose anything until something would happen. But we are getting the right return on the investment, but it's no longer considered strategic.
Okay.
Joan?
Thank you. Johan Ekblom from UBS. Sorry to come back to the RWA and volume growth, but if I've done my math correctly, if the risk density is going to stay roughly the same in the wholesale and the retail, as you said, Tanate, then even if all 4% growth at a group level comes in retail, you will not reach 55, 45.
So what am I missing in terms of driving that shift in where the RWAs are kind of allocated in the group? And then maybe just to confirm that the 4% growth that you're targeting, that's an on-balance sheet growth number after adjusting for lower take rates in transactions, etc.?
Tanate?
Yes. Well, I think we have seen the trend in the wholesale bank, and I think maybe I misunderstand my answer. I think the intensity of risk weight in the retail bank will not materially change, but the capital diet that Andrew has given could mean that we would operate at a lower risk-weighted asset in the wholesale bank. Okay? So that's the first question. The second. Is the 4%? Oh, yes, it's on balance. Yes.
Okay. Farquhar?
Hi, Farquhar from. Sorry. Farquhar from Autonomous, and apologies for my voice. Two quick questions.
Just firstly, coming back to the loan growth, I mean, you want to accelerate essentially from 3 to 4. I just wondered if you could give us a bit more color on what's going to drive that acceleration, which businesses in particular are going to accelerate, and perhaps how significant the Business Banking and consumer finance opportunities might be within that. And then secondly, just coming back to fees, I mean, the fee progression has been very good lately. Equally, I'd have thought on the daily banking fees, particularly the payment account packages, a lot of the low-hanging fruit has been done. What scope do you see further to optimize that side? Because you do mention it as part of it. Maybe I'm missing what's the key driver of that element of the growth on the fees. Thanks.
Okay. Let's first start with the loan growth.
Maybe you want to say something about where do we see the loan growth? Then we move to fees. Then we'll divide between Pinar and myself. Okay.
Then loan growth, Farquhar, is across the board, right? If you look at, I give a specific market, we do see that given the good work we've done in the Netherlands, for example, our market share on loan growth has been strong. You see that in the first quarter, for example. We also see that in the non-Eurozone countries, the loan growth has been strong, and we expect that that is actually quite a big driver in terms of loan growth, in terms of what we see at the moment. So that's driving the growth. And I think, and maybe Ljiljana, you can add, but I don't see material pickup in consumer Lending that would drive such a composition.
It will grow, but as a percentage of the balance sheet, it's still modest.
Maybe I'll start on fees, but then at a higher level, and Pinar can give a few examples in the markets that we work in. So first of all, on daily banking, the fact that we grow our primary customers also means we can still continue to grow our daily banking fees. That's maybe one too. In this setting, we are operating in a number of markets whereby we're either lower still than a number of our peers, or some of our peers are local blue chips and only are confined to that market. So they will feel pressure to actually move up if there is a possibility to do so.
But besides that, if you look at the total fee wallet that we grow from EUR 3.6 billion-EUR 5 billion by the end of 2027, a big proportion comes also from investment, comes next to the payments that we have from primary customers. Also in payments in Business Banking , we hardly started charging for payments in Business Banking . And now that we have our digital journeys in Business Bank ing, also in order, that is now the moment when we can be more specific on what we charge to whom. And secondly, in the segmenting of what we do, there is a lot of investment fees to be gained by increasing the number of accounts and by focusing much more specifically on the segment of mass affluent so that we get our fees and investment products up as well.
The big pockets of growth in the fee, the whole fee spectrum is investment products first, and then daily banking, but daily banking more in the business banking space and investment products more in the private individual space. Pinar?
Yes, I think you summarized it well. You should also not forget that even in the daily banking space, first of all, what you call low-hanging fruit, I think, is not low-hanging fruit for us. But so still, there is a lot of work in terms of what you put in the packages. So we have in most of our countries simple packages. So we also see an opportunity to increase and enhance what is in our packages that we can develop new value propositions where we can increase the willingness to subscribe.
I didn't explain in detail on the page for PI, but we now have a subscription model thinking. In our markets, we see an opportunity to increase the number of daily banking offers we have and not only have daily banking in it, but also, for instance, include protection in it for people who actually want to invest, combine the offers of daily banking with insurance and investment to create tailored value propositions that people would love to subscribe to, to increase our subscriber space for recurring fees. And another thing to add to what Steven said is on the insurance side, we also see a massive opportunity. We have significantly invested in our digital journeys in almost all markets. We are extremely good on it now. We sell almost fully digitally.
We are also in a process to renew our partnerships on insurance in multiple markets, which we also believe will bring us a significant opportunity. Just as a market, for instance, Germany has a very small fee income on insurance with a client base that is very large. That's a big opportunity for us. Equally, in places like Belgium, we see a big opportunity to also increase the penetration both for investments but also insurance. Finally, the private banking segment, which is relatively small but a very lucrative ROE, a big part of that income base will also bring us sizable investment account fees. These are the three drivers.
Good. Okay. We have also a question from our virtual audience. What are the most important drivers/steps to improve the ROE in Belgium from 11% to the above 14%?
Pinar.
Should I take it? Okay.
So, first of all, we have done this before. So, as I've shown you, Belgium actually has done many improvements on digitalization that really let the bank to perform significantly better than competition on the cost side. That really helped us, but also on the income side. So, compared to most banks, we have managed our NII much better in Belgium because we are quite sophisticated in the management we do pricing on the savings side. So, those things, sophistication on managing our NII and managing the cost, will remain to be there because we still have a road ahead in terms of digitalization, which means we have closed a lot of branches. So, we will have savings coming from physical buildings, branches, facility management, and costs related to that still in our plans.
In addition, thanks to what Marnix and the team has been doing on digitalization end-to-end, also on the way we serve this client base, we do expect some savings on the operations side. Part of the savings Marnix described also falls into the scope of Belgium. On the income side, there is a sizable opportunity on Business Banking because our Business Banking segment has really revamped its capabilities in the last years in Belgium on growth. And that includes fee-based growth on different offers like insurance, for instance, as we discussed, but also on liability-driven growth because we are very good in the smaller side of SMEs. Our digital capabilities have become much better. So we will also bring both Lending but also liability-driven NII in Business Banking . And Belgium is a market where there is a large revenue pool for investments.
All the investments we have made to get up to speed our investment platform in Belgium last couple of years is now finished. Therefore, we are fully focused on investments offering both on affluent side but also on the private banking side. These elements, investments, insurance, and Business Banking are the key drivers of top line and continued very strong cost discipline. Digitalization is on the cost side. We'll take Belgium to the level of ROE that we have given as a guideline.
Good. Okay. Sam?
Thank you. Hi. Sam S mith here from Barclays. Two questions, please. One is on the news we saw that you're planning to open your European investment banking headquarters in Madrid. Just strategically, why you chose Spain or why you may have chosen Spain as the location for that?
Should we perhaps bigger picture think about Spain as your fourth core market in the future? And then secondly, on fees, apologies, this is perhaps a bit of a nasty question, but I appreciate more primary customers means more fee income, but also in markets like Belgium, Germany, and Spain, where you offer discounted packages to primary customers, it also means less fee income. So if we have to prioritize the 2027 primary customer growth targets and the fee income targets, which one would be the priority?
Right.
Thank you.
The first one is on our new head office in Spain. I'm looking forward to that.
I'll retake that one, Steven. Yeah, there was some media speculation in Spain that we were setting up an investment banking hub in Spain, or indeed moving our investment bank to Spain, which is patently not true. So maybe just.
I find it very unfortunate, by the way.
Be fair. I have had a number of wholesale banking colleagues going, "Oh, that could be quite good fun." So if I say that's categorically not true, what it actually is is linked to the adjacencies that Steven was talking about. So we're hiring some VPs. We're hiring some associates to augment our existing capital markets advisory proposition in Spain, where the teams are already doing a great job. But hiring, as you know, hiring VPs and associates isn't quite moving the bank to Spain.
On the priority between primary customers and fee growth targets, I will give it to Pinar, but this is not one or the other. It can be both, Pinar.
Yes, definitely. So we already, by the way, grow, and we have grown like that in the past.
So this is not like we have not done this before, and suddenly we will grow this much and increase fees. So if you look at our history, we managed to grow our primary banking clients, and at the same time, we managed to increase our fee income. So the numbers and the plans you have seen include the assumptions that the primary growth will bring fees. Of course, occasionally, in some countries, not in all countries, based on our positioning, we may have some promotional product packages in which daily banking fees can differ from time to time, right? But what we have presented includes already those assumptions already incorporated. So there is no trade-off between the growth numbers we presented and the daily banking fees that we have presented. So we are confident both of them, as presented, will happen.
Good. Okay.
We have another question from our virtual audience. As ING has a very stable business model, did you ever discuss a progressive dividend policy to give dividend investors a more reliable income stream, i.e., 50% of resilient dividend, but at least the same dividend amount as last year?
We go back to the past.
Yeah. Indeed. We had a progressive dividend policy in the past. And quite frankly, from a stress test perspective, it actually costs you some capital buffers from that perspective. But I think the right way to answer the question is that your dividend policy should follow your business model, right? And now we're comfortable with the business model that we have. It's shifting to be more capital-light over time. But given our business model today, we think 50% dividend policy is the right one for us. And of course, we do share buybacks.
We do cash distribution on top of that.
You?
Hi. Hugh here from Berenberg here. A couple of questions, please. Firstly, on other income, how should we think about the role that this line item might play in the 4%-5% income growth? And secondly, on your capital updates to the market, how should we think about the frequency beyond 2025? Thank you.
Other income, I think let us give you a bit more guidance when we do Q2 results announcement, but it's just accounting noise. That's what we see basically in financial market and treasury. So from that perspective, nothing changes there. In terms of capital targeting, we like the rhythm that we do of giving twice a year market guidance. And so we will stick with that until something changes.
Okay. We have time for one more question.
Any more questions here in the audience? Benoit?
Why not? Why not? No, just to come back on the 12.5% CET1 ratio target. So you have it for end of 2025. I mean, it's subject to regulatory changes or any buffers, but are we going to see the 12.5, or is that around 12.5? Is that a 13%? Are you really committed to bring that down to 12.5? Because it will be, I think, versus where the consensus stand, even more bullish share buyback for next year. And just maybe on the insurance side, because we did not talk too much about insurance, but that has been always a big opportunity for you. So where do you stand now on the insurance partnership? How much fee growth do you expect from insurance going forward? What is your opportunity there?
All right. On the capital side, when we mentioned around 12.5, we mean around 12.5. Otherwise, we would have said around 13. So if it consistently is closer to 13 than 12.5, we would say that. But we want to leave some room open to now and again trade a bit above that or below that, as the case may be depending on macroeconomic circumstances. On insurance fees, Pinar.
Yeah. So overall, between daily banking, protection, insurance, and investments, overall guidance is 5-10. So we do not give forward guidance for each fee type. So we are very confident among the three we will be in that range. But just to give some more color on insurance, we have, as I said, completely digitized our insurance software in almost all markets.
At the same time, we are in discussions with our partners in multiple markets to a stage we are at the end stage of these discussions in markets like Belgium, Netherlands, and mid-stage, I would say, for Germany, Turkey, end stage. And we are looking into other markets like Italy, which is also a big bank insurance market, and later on to Australia. So insurance is definitely something we are taking it very steering it with experts functionally globally in a very professional way in every market because it's a big source of insurance income for a large client base like ING in private individuals. But also, Business Banking is also giving us a great opportunity. Just to give you an example, this year in the Netherlands, we will launch for the first time a fully end-to-end digital insurance proposition for Business Banking clients.
Based on the results, we will also then replicate it across the markets.
Open architecture or it's closed?
Yeah. Sorry?
It will be based on an open architecture, the insurance product offering, or is that on a one-on-one with single partners in specific countries?
Market by market, dependent on the market characteristics, we are looking into that. In certain markets where the open architectures are more mature, we may choose to go with that path. But in some markets where it is not yet as developed, we will go with one or two partners. And in private banking, for instance, the insurance providers typically are different. So therefore, we may choose a different partner for private banking route.
Okay. So on that note, sorry. Okay. Last question. Okay.
And really last question.
Really last question. Sorry.
Maybe more of an opportunity for you to comment on 2024 as well, given the comments you gave on the guidance on the revenues for EUR 22 billion for 2024, which is slightly below consensus. But I guess it's more like within the range of your starting base to give us a starting point. And I guess if the 2022 revenue number would be lower. 2024. 2024, yes. 2024 would be lower than the EUR 22 billion, sorry. Should we be looking at the growth rate on a lower base on the 14% ROE is basically more like a normalized level, which could then potentially be delivered later?
No.
I think what we would like to do is to give you an update on our 2024 numbers as part of our Q2 results. And I'd like to leave it at that. Okay.
If we would have a different target in 14%, I would have written down a different target in 14%. Typically, we keep our promises.
Okay. On that note, Steven, can I give you the floor to wrap it up?
Next to keeping our promises. Ho-ho, guys, sit down, please. Turn off the heat. First of all, thank you very much for your time, both here in the room but also on the screen. Thank you for your questions. Please note, we'll go to the drinks right now, the most important part of this gathering. It's getting warmer by the hour. We'll open the windows. You can stand outside. Don't forget, because there are CEOs of the Netherlands, Belgium, Germany, Business Banking , the heads of Transaction Services, and Lending are here. The head of FI is here.
So, jump on them, get more out of them. We have trained them to say exactly the same as we have said. So if it gets too difficult, they'll tell us, "Drinks are over." So that's maybe the first message. But have fun. Secondly, I want to repeat what I said in the beginning of this presentation or at the closure of what I said in my presentation, which is we have been very successful because of our DNA of being entrepreneurial, collaborative, and very client-focused. You've heard it in the presentations. We have delivered, and we keep our promises. We have built a number of foundations, which is setting us up for now growing the difference. And I'm very, very proud with the great team. That's why you had to sit here. It is very committed, but also very confident that we will also deliver going forward.
With that, thanks again very much for your time. Enjoy the drinks, and hope to talk to you soon. Thank you very much.