ING Bank on living wages, transparency and fair pay

3 August 2026

Why Living Wages and Why Now?

The EU’s Corporate Sustainability Reporting Directive (CSRD) is now requiring companies to be transparent about the adequacy of their wages. As Wencke Boehm shares, ING started building its fair pay framework before CSRD took effect. While the directive has since added a regulatory layer, it wasn't the starting point for ING.

The core motivation was simple: ING has approximately 60,000 employees spread across 35 countries, ranging from retail and wholesale banking to IT and operations. The diversity in operations creates real variation in pay and makes it quite complex to implement one harmonised global approach for fair and transparent pay, but Living Wages are foundational to ING’s pay frameworks.

“From a practical standpoint, our research indicates employees who are treated fairly, which also includes pay, tend to perform better”, says Boehm. “Transparency and fairness are core to how ING operates, as established in ‘Our People Offer’. This describes how we want to pay and treat our people fairly and transparently. When we assess our remuneration and benefits through this lens, we find that our employees are generally paid above the living wage threshold”.

To maintain this baseline the bank is deliberate about one aspect of its pay methodology based on WageIndicator’s: it does not use the ‘Single Earner Household’ model, which assumes only one adult in a household earns income. ING uses the Typical Family Household model, maintaining the belief that if men and women are treated equally, a Living Wage should be based on a household where both adults earn an income, rather than only one.

Working with WageIndicator

ING started using WageIndicator data in 2024, based on a recommendation from Korn Ferry, while it was setting up its Living Wage project.

“The choice was deliberate”, Boehm explains. “We wanted an independent, non-profit source without a commercial interest in the estimates it produces. As a large, international employer, the ability to access comparable data across all countries through a single dashboard is very important.”

On an annual basis ING assesses every employee against WageIndicator's Living Wage estimates - both upper and lower bounds - as well as against minimum wages. In most countries, ING pays above the upper bound (for example, recently seen in 2024 where all employees earned salaries above the living wage threshold). In the few countries where adjustments are currently needed, the lower bound of the Living Wage estimate is used as the adjustment target.

Boehm notes that for these few cases ING’s salaries are typically high relative to the national average. Both ING’s own analysis and the Living Wage calculation point deem the proposed levels as appropriate and necessary to genuinely cover the cost of living there.

“While we are confident in our current analysis, we also recognise the complexity that comes with a global compensation model. We take action where needed, particularly in cases where hyperinflation or other structural pay imparity may exist causing the Living Wage estimate to become a moving target. Unfortunately, sometimes the gap can widen faster than annual salary reviews can close it.”

Year-on-year volatility in benchmark shifts can be difficult to interpret, but leveraging the underlying data, bounds and factors driving the changes improves conversations around the topic. “The range itself, rather than a single point estimate, is particularly useful,” Boehm explains. “When managing country-wide decisions regional differences within a single country can be significant and having upper and lower bounds gives country teams a credible basis for conversations about pay levels that might otherwise seem arbitrary”.

How adjustments are made in practice

At ING each country manages its own budget and can independently decide how it allocates salary increases. However, the central principle for ING is to prioritise employees whose pay falls in the lower ranges first.

Performance pay is handled separately: “it sits on top of the base salary adjustment, rather than being used to compensate for a pay gap”. Boehm clarifies.

She shares that finding the right formula isn’t a universally applied approach as it varies considerably by country and by workforce composition. But Managers’ pay decisions are supported by data insights and a consistent framework, while still allowing room for individual discretion.

This becomes particularly relevant when looking at how different roles are impacted. Whether someone falls below a Living Wage often depends on the type of job. Roles typically requiring more informal credentials - such as call centre operator or customer-facing jobs - are more likely to be affected. Even if pay is at the market norm, ING still considers an adjustment if it does not meet that market’s Living Wage.

Beyond compliance: embedding fair and transparent pay

When it comes to reporting, ING currently tracks Living Wage progress internally with a clear ambition for everyone to receive a Living Wage. However, an assessment by ING’s disclosure team found Living Wage was not sufficiently material in ING’s double materiality assessment. As a result, its Living Wage analysis is not published in external sustainability reporting.

Here, Boehm emphasises that this does not change ING’s commitment to fair pay, “it remains a priority for us, even if it hasn't yet been included in external reporting”.

Ultimately, having a Living Wage is one component of broader commitment to fair and transparent pay, not a standalone achievement.

Boehm concludes: “Fair and transparent pay should simply be part of how a responsible employer operates, rather than something exceptional”.