ING Netherlands publicly apologized for discriminatory banking practices in May 2025. Customers with non-Dutch names, religious institutions, and migrant communities had been disproportionately questioned or blocked under ING’s transaction monitoring procedures. As ING Netherlands CEO Peter Jacobs elaborated:
“Many customers with a migrant background feel we are too strict with them… and they are right.
Sometimes we asked questions when we already had the answers. That’s on us.”
This rare apology has placed a spotlight on two key elements of the EU’s Corporate Sustainability Reporting Directive (CSRD):
- ESRS S3 – Affected Communities how companies impact vulnerable groups or communities through their operations.
- ESRS S4 – Consumers and End-Users how fairly and inclusively products and services are offered to end clients.
Therefore we compare how four European banks, ING (Netherlands), Sparkasse (Germany), Crédit Agricole (France), and CaixaBank (Spain), address discriminatory risks and customer inclusion across both standards.
Inclusion in policy
All four banks state their commitment to non-discrimination:
- ING lists discrimination as a key retail banking risk in its human rights disclosures.
- Sparkasse guarantees access to a basic account for all residents, regardless of background.
- Crédit Agricole supports France’s legal “droit au compte” and vulnerable borrowers via Points Passerelle.
- CaixaBank prohibits discrimination based on race, gender, religion, or origin and promotes accessible financial services.
However, what matters under ESRS S3 and S4 is not just policy but evidence of implementation.
Access to basic banking
Each bank offers inclusive account options:
- ING supports the Dutch basisbankrekening for clients without traditional ID or proof of residence.
- Sparkasse offers the Guthabenkonto, a no-overdraft account guaranteed by German law.
- Crédit Agricole uses Points Passerelle to provide coaching and microcredit to overindebted clients.
- CaixaBank offers a Cuenta Social, a free account for low-income clients, and adapted it for Ukrainian refugees in 2022.
These initiatives align with ESRS S4’s focus on consumer access and S3’s emphasis on equitable community service.
Examples of ESRS 4 related issues
ING – Anti Money Laundry led to discrimiation
In 2024, the Netherlands Institute for Human Rights ruled that ING’s systems discriminated on the basis of ethnicity. Transfers were blocked when names like “Mohamed” appeared, or migrant churches received donations. ING responded with a rare public apology in 2025 and pledged to (1) reduce unnecessary Anti Money Laundry (AML) questioning, (2) create a dedicated team for religious institutions and (3) train staff on cultural and religious sensitivity.
Sparkasse – Local Service, Limited Oversight
Germany’s Sparkassen are highly localized. While they meet basic access mandates, they’ve not addressed profiling risks or transparency in customer treatment. The 2024 case of “Jüdische Stimme”, a Jewish NGO whose account was frozen by Berliner Sparkasse and later reinstated by court order, highlights the opacity of compliance decisions.
CaixaBank – Indirect Exclusion, Responsive to Elderly
Spanish NGOs reported bank access as the key issue for migrants, often due to extra ID requirements. CaixaBank has not addressed these cases directly. However, when elderly clients protested digital-only services in 2022 (“Soy mayor, no idiota” CaixaBank responded with: (1) extended in-person hours, (2) over 2,000 senior-specialist advisors and (3) simplified ATMs and telephone appointment services
United Kingdom: Account Closures Affecting Charities and SMEs
In 2024, the UK witnessed a rise in account closures affecting small businesses and charities. Stricter AML regulations and “know your customer” procedures led banks to close accounts deemed high-risk or unprofitable. This trend raised concerns about the unintended consequences of AML measures on legitimate organizations and the importance of proportionality in compliance efforts.
Measures to prevent exclusion
Each bank has set up different forms of key inclusions and reform actions. Some examples per bank are:
- ING – Anti Money Laundry (AML) reform, religious team, bias training, human rights reporting
- Sparkasse – Legally guaranteed access, some reactive adjustments
- Crédit Agricole – Points Passerelle program, general ethics training
- CaixaBank – Cuenta Social, mobile branches, senior inclusion plan, no AML changes
Stakeholder engagement and complaint handling
ESRS S4 requires data on customer complaints and redress mechanisms
- ING now follows up directly with customers who file discrimination complaints and consults faith-based communities.
- CaixaBank proactively engaged senior associations and NGOs like ONCE (disabilities) and Cruz Roja (migrants).
- Crédit Agricole maintains a cooperative model and works with social NGOs
- Sparkasse engages locally which can a strength however makes it difficult to find consolidated view across its federation.
Conclusion: lessons from S3 and S4
The ING case confirms that discriminatory banking practices are not hypothetical. They exist, and under CSRD’s ESRS S3 and S4 standards, they must be reported, addressed, and corrected.
- ESRS S3 expects companies to assess community-level impacts, especially religious institutions, migrants, and vulnerable civic groups.
- ESRS S4 requires fair, accessible treatment of consumers and end-users, including transparency on onboarding, AML checks, and complaints.
ING’s admission and remediation offer a leading example of both standards in practice. The other banks meet formal inclusion goals but fall short in transparency, complaint tracking, or engagement on discrimination.
As reporting obligations expand, financial institutions will need to shift from compliance-based ethics to auditable, people-centered practices. Under CSRD, fair access is not just a value—it’s a data point.