ING Swap Migration
13 February 2026
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In 2026, and subject to regulatory approval, ING plans to transition certain client derivatives trading relationships from ING Capital Markets LLC to ING Bank N.V. This initiative supports our broader goal of consolidating global derivatives activity under a single platform to deliver a more seamless and efficient client experience.
Important note
To help us prepare for this transition, please take a moment to identify the appropriate contact(s) within your organization. Submit your contact(s) Opens in a new tabhere.
Overview of the Change
ING Bank N.V., our parent company, intends to register with the U.S. Commodity Futures Trading Commission (CFTC) as a Swap Dealer in 2026.
This planned registration will:
- Consolidate derivatives activity within a unified global framework
- Enhance operational efficiency across markets
- Support a broader and more flexible product offering over time
- Leverage ING Bank N.V.’s strong capital position and extensive international presence
ING intends to submit its CFTC application in the first half of 2026, with provisional approval expected shortly thereafter. We will continue to provide updates as the process advances.
What This Means for You
Beginning in 2026, we expect to migrate select client derivatives trading relationships from ING Capital Markets LLC to ING Bank N.V. Depending on your current engagement with ING, this may include:
- Requests for refreshed KYC/CDD information
- Updates to regulatory adherence and disclosure documentation (via ISDA Amend or bilateral forms)
- Negotiation or execution of new ISDA, CSA, CDEA, or other trading agreements
- Setup of new electronic trading or clearing relationships
Timing and Ongoing Support
Client onboarding to ING Bank N.V. will occur in phases throughout 2026, with full migration targeted for mid‑2027.
During this period:
- ING Capital Markets LLC will remain active, ensuring uninterrupted support
- Our teams will work closely with you to maintain continuity and minimize operational impact
- If you have any questions that this page does not answer, please contact: INGSwapMigration@ing.com
Frequently Asked Questions
Why is ING registering its head office as a Swap Dealer and a Security-based Swap Dealer?
This registration will enable us to consolidate our derivatives activity under one global platform and, over time, broaden the products and services we can offer you through ING Bank N.V.’s strong capital base and international footprint.
When will ING Bank NV be a registered Swap Dealer and a Security-based Swap Dealer?
ING intends to submit its Swap Dealer application to the CFTC during the first half of 2026. We expect to receive the CFTC’s provisional approval of our application shortly thereafter, after which we can begin trading with U.S. clients. ING intends to submit its Security-based Swap Dealer application to the SEC in 2027.
What is required from the company that I represent?
In the coming months we will reach out to you to begin the process to migrate your trading relationship to ING Bank NV in anticipation of provisional registration later this year. Depending on the nature of your trading relationship with ING Capital Markets, this process may include:
- Requests for additional KYC information
- Negotiation of new ISDA/CSA/CDEA or other trading agreements
- Execution of new regulatory agreements
- Onboarding setup for electronic trading venues and clearing
Will this migration result in additional regulatory requirements?
Most clients will be required update their existing regulatory adherence and disclosures to include ING Bank NV. This can be achieved using Markit ISDA Amend (please match ING Bank NV, LEI: 3TK20IVIUJ8J3ZU0QE75) or using a bilateral (paper) form which we will provide to you as part of our outreach.
Additional EMIR and/or MiFID documentation may be required.
We will provide clear guidance on the relevant regulatory regimes we believe are applicable to your institution during our outreach.
Will I still be able to trade with Capital Markets LLC?
ING Capital Markets LLC will remain an active entity counterparty on an interim basis. Longer term we intend to migrate all new and existing positions to ING Bank NV.
Will my open positions be novated to ING Bank NV?
In some cases we may agree to leave short-dated existing positions to remain at ING Capital Markets until they mature; in other cases we will arrange to novate existing trades to ING Bank NV. We will discuss with you at time of outreach to align with you on the best approach.
My company currently has a loan from ING Capital LLC– will this loan be assigned to ING Bank NV at the same time?
No, your loans will not be assigned to ING Bank N.V. as part of this process.
Will I need to establish new trading and clearing relationships with ING Bank NV on electronic platforms and clearinghouses?
Yes. ING Bank N.V. will support all electronic trading and clearing platforms currently available to customers of ING Capital Markets. As part of this exercise you will need to add ING Bank NV as a counterparty in relevant platforms. More information, including ING Bank NV dealer codes, will be posted below under “Additional Information.”
Where can I find KYC and other information about ING Bank NV?
Additional information can be found on ING Bank N.V.
Will all existing ING Capital Markets clients be transitioned to ING Bank NV at the same time?
We will be migrating clients on a phased approach. Our goal is to reach out to you to begin the repapering and onboarding process over the course of 2026, with the goal of completing this process for all clients by December 2028.
What if I don’t wish to move my business to ING Bank NV?
You can continue to trade with ING Capital Markets on an interim basis, noting that we reserve the right to cap the tenor for any new trades to enable us to complete migration of business from ING Capital Markets to ING Bank NV within our target timeline. Any legacy positions with ING Capital Markets can remain until they mature, or we agree to an alternative such as novation to another hedge provider or termination.
Additional Information about ING Bank N.V.
- Legal Entity Identifier (LEI): 3TK20IVIUJ8J3ZU0QE75
- Financial information: Opens in a new tabInvestor overview | ING