ING DiBa Review – A solid choice for passive investors

ING Diba Review

Category Ranking

4.3

GOOD

LAGGER
FAIR
GOOD
EXCELLENT
<2.5
2.5-3.5
3.5-4.5
4.5-5.5

CATEGORY: Bank Broker

AVAILABILITY: Germany

BROKER SCORE

4.3

/5

Category Ranking

4.3 GOOD

LAGGER
FAIR
GOOD
EXCELLENT
<2.5
2.5-3.5
3.5-4.5
4.5-5.5

CATEGORY: Bank Broker

🌎 Germany

BROKER SCORE

4.3

/5

Our take: ING‑DiBa is one of Germany’s largest retail banks and a significant online broker. Its services are limited to German residents, and while its trading platform may not offer all the sophisticated features of specialized brokers, it provides a solid experience for passive investors. The ETF savings plans are competitively priced, and the product range is extensive. Moreover, the seamless integration with full banking services makes ING‑DiBa particularly attractive for existing ING customers.

Our assessment: ING DiBa scores 4.3 in its category driven by safety and fee aspects. Here are key highligts: 

  • Passive Investors: ING-DiBa offers an attractive platform for passive investors with free custody accounts and competitive pricing on ETF savings plans. The broker provides access to a wide range of ETFs and the full banking license provide additional security for long-term investors.
  • Semi-Active Investors: May find the platform suitable for regular trading with competitive fees capped for larger amounts.  The broker offers access to all major German exchanges and international markets.
  • Advanced Investors: Might find ING-DiBa’s offering somewhat limiting. While the platform provides access to derivatives and certificates, it lacks majority of other advanced options.

Pros & Cons and suitability

Pros & Cons

Suitability

VERY Suitable

SOLID PARENT & CHEAP ETF savings plans

Suitable

Good choice of exchanges and instruments and capped fees for higher amount

somewhat suitable

Lack of Advanced Options

Availability

ING-DiBa is only Available In Germany

Broker Snapshot

Why Is ING-DiBa A Bank Broker?

ING-DiBa earns its bank classification through its strong institutional foundation as part of ING Group, one of Europe’s major banking institutions. While it offers comprehensive services and robust protection schemes, it primarily serves the German market. The broker provides good execution quality and competitive pricing for regular traders and although some fees are higher than pure-play fintech competitors, its integration with the ING Group provides additional security.

A Bank Broker with A Solid Foundation

ING-DiBa operates under ING Group, which is listed on the Euronext Amsterdam stock exchange. ING-DiBa is regulated by BaFin, Germany’s federal financial supervisory authority. 

Company Info

CharacteristicING DiBa
Inception Date🛈 1965 (as BSV Bank),
1998 (as ING-DiBa)
Headquarters🛈 Frankfurt am Main, Germany
Key Owner🛈 ING Group 100%
Bank Affiliated✅ Yes
Listed on Stock Exchange✅ Yes (Parent) - €45.6 bn
Rating (Parent)✅ A+ (Fitch), A- (S&P), A3 (Moody’s)
Net Income (2023)✅ €7.3B (Parent)

Regulation

FeatureING DiBa
EU Entity🛈 ING-DiBa AG
UK Entity🛈 N/A
Key Regulators✅ BaFin
EU RegulatorBaFin
UK RegulatorN/A
EU Guarantee€20,000
UK Guarantee🛈 N/A

No custody fees and commission-free trading for ETF Savings Plans

ING‑DiBa does not charge custody fees and offers commission‑free trading for ETF savings plans. It encourages using the free Tradegate trading venue where higher spreads may apply; however, fees on other exchanges remain reasonable. Note that the bank does not offer a multicurrency account, and FX fees are average.

Features

FeatureING DiBa
Key Base CurrenciesEUR
ETF Availability✅ Very High (2,000+)
Multicurrency❌ No
Cash Interest✅ Yes
Margin Loans❌ No
Exchanges✅ Major European & International
Security Transfer✅ Yes
External PFOF Reliance✅ Medium

Fee Structure

FeatureING DiBa
Custody Fees✅ None
Inactivity Fees✅ None
ETFs Dealing Fees⚠️ €4.90 base fee + 0.25% , max €69.90 per order ¹
FX Fees✅ 0.25%
Deposit Fees✅ None
Withdrawal Fees✅ None
Security Lending🛈 Not Available
¹ For normal transaction, Venue Fees to be added. ETF Saving Plans are free but Venue Fees apply.

I. Company

ING-DiBa is Germany’s third-largest retail bank, serving over 9 million customers with savings accounts, loans, investments, and business banking. It is a wholly owned subsidiary of ING Group, a Global Systemically Important Bank. While the bank itself has a solid reputation, ING Group has faced some regulatory fines in the past.

Business Profile

ING-DiBa is Germany’s third-largest retail bank, serving over 9 million customers. The bank operates primarily in retail banking, offering savings accounts, mortgages, investment products, consumer loans and current accounts for private customers. They also provide business banking services for SMEs and wholesale banking solutions for large corporations.

ING is a leading global financial institution with a strong European base, providing retail and wholesale banking services through its operating company ING Bank. In 2023, the bank reported total revenues of €27.4 billion and an operating profit before tax of €9.4 billion, with a net profit of €7.3 billion. Its core business segments include Retail Banking and Wholesale Banking, serving over 38 million customers across more than 40 countries. ING has a market capitalization of approximately €45.6 billion as of 2024. The bank employs more than 60,000 people globally and operates under the supervision of the European Central Bank and local regulators.

Ownership and Transparency

ING-DiBa operates as a wholly owned subsidiary of ING Group, one of Europe’s largest banking groups. Additionally, the bank is rated and listed on a stock exchange. 

Safety Considerations

The bank’s safety framework is reinforced by its integration within the ING Group, one of Europe’s leading financial institutions. ING Group bonds are rated A- by S&P and A+ by Finch, which based on historical default data implies a probability of default of around 1-2% over 10 years. ING Group is classified as a Systemically Important Financial Institution (SIFI) and a Global Systemically Important Bank (G-SIB), which – alhough uncertain – improves the likelihood of a state bailout. ING-DiBa demonstrated strong financial performance in 2023 with a net profit of €2.5 billion.

Regulation & Investor Compensation Schemes

ING-DiBa is regulated by the German Federal Financial Supervisory Authority (BaFin) and provides investors with a protection amount up to €20,000. Specifically, the scheme covers up to 90% of an investor’s claims, with a maximum limit of €20,000 per investor. This level of protection – while standard among most EU brokers – is considered low. Cash held at ING-DiBa is protected by the German Compensation Scheme up to €100,000, though it is pooled unless held in your name.

Share & Cash Custodians

  • Cash Holdings:  ING-DiBa AG (€145.2 billion in customer deposits as of 2023)
  • Securities Custody: Clearstream Banking AG

Reputation

ING-DiBa have not had any major fines recently but their parent company ING Group’s reputation has been impacted by several regulatory and compliance issues. Most notably, ING faced a €775 million settlement with Dutch authorities in 2018 over anti-money laundering failures, and in February 2024, received a $200 million fine for insufficient monitoring of cross-border transactions and AML compliance failures. The bank is currently facing a €500 million lawsuit from 158 institutional investors who claim ING concealed information about its anti-money laundering deficiencies. 

II. Fee structure

ING DiBa generally provides commission-free trading on Tradegate exchange, but higher spreads on single market maker exchanges may apply. Based on NCA studies, small trades on Single Market Maker Exchanges can be assumed to be executed in line with other exchanges, however trades above €500 may be routed in a way that increases overall execution cost. Commissions on other venues are very reasonable and may potentially benefit from lower spreads. Capped costs mean that large trades can be relatively cheap and ETF Savings Plans transactions incur no transaction costs. Finally, FX currency fees are average. 

Platform fees

No platform fees. In addition, ING – DiBa offers individual segregated custody at €35,395 per year + €29,750 one-time connection fee (via Clearstream Banking AG).

Trading Commisions

    • Standard Order Fee: €4.90 base fee + 0.25% of trade value (max €69.90 per order).
    • Savings Plans: €0 for ETF savings plans.
    • Stocks: €4.90 + 0.25% per trade.
    • Phone Orders: Additional €14.90 service fee.
    • Trading Venue Fees:
      • Direct Trading: Free. ING-DiBa’s Direct Trading (Direkthandel) for stocks and ETFs is exclusively available through Tradegate Exchange. Other products like bonds, funds, and structured products are traded via Gettex (Munich Stock Exchange) and OTC issuers like BNP Paribas and Deutsche Bank. Higher spreads on Single Market Maker Exchanges may apply.
      • Xetra, Frankfurt, Berlin, Dusseldorf, Hamburg, Hanover: €2.90
      • Munich, Stuttgart, Euwax, Frankfurt Certificates: €1.90
      • International Venues: €14.90

Overall Fee Simulation vs Competitors

Most of our readers have simple Index portfolios. Using our Broker Total cost calculator, you can estimate the total cost of holding ETFs throughout the investment period. For our simulated scenarios, ING DiBa comes out as very competitive but just if you use the direct trades via Tradegate exchange and this is misleading.

We compared it against another fintech bank-backed broker and one Tier 1 Broker with a good financial record and international offer. We’ve chosen to compare ING DiBa to Comdirect, that has a similar offer and history, and IBKR, which is one of the best international brokers.

⚠️ SINGLE MARKET MAKER EXECUTION COSTS

The below simulation only takes into account direct visible commissions. As an investor you also face less visible costs including spreads. ING DiBa Savings Plans may direct trades to Tradegate Exchange if you choose the cheaper commission offer. Single market maker exchanges like Tradegate are opaque and according to numerous NCAs in Europe have worse execution (spreads) as compared to traditional exchanges like Xetra, particularly for trades above €500. While ING DiBa also offers other exchanges, users’ choice may be incentivised by the apparent low visible commissions. Read more about our research on this 👉🏻

Fee Simulation For General Accounts

The simulation shows a cost of €0 for ING DiBa, however, its €0 cost applies only to regular ETF savings plan direct trade transactions on the Tradegate exchange. It does not include spreads. IBKR has a total cost of €731 but likely lower spreads, so overall cost may be lower, and Comdirect is the most expensive option, with a total cost of €48,547.

Investor assumptions

Model FeatureAssumption
InvestorGerman
InstrumentETF
Account General
Initial Investment€ 100,000
Monthly€ 1,000
Time Horizon20 years
Gross Return8%

Trading Commissions

Currency Exchange fees

There is a currency exchange fee of 0.25% on FX rates on the foreign exchange middle rate.

Other fees

Transfer securities in and out is free. 

III. Platform & Features

ING-DiBa provides good features for investors, such as a wide selection of ETFs and regular savings plans but it lacks of advanced options with the exception of Derivatives. Cash interest is relatively averaged. 

Account Opening Process

New customers can complete their application entirely online through the bank’s website or mobile app. The process typically takes 10-15 minutes, requiring basic personal information, tax residency details, and identity verification. For verification, customers can choose between VideoIdent (fastest option), PostIdent at any post office, or electronic ID (eID) if available. Once verified, account activation usually occurs within 24 hours. Initial funding can be completed via bank transfer from any existing European bank account. The minimum deposit requirement has been removed.

account Features

  • Custody accounts – Depot, Girokonto and joint accounts. 
  • Large Range of ETFs including Amundi, iShares and Xtrackers;
  • Apps for Android and iOS;
  • All Major Stock Exchanges: including Nasdaq, Euronext, Xetra, LSE, Zurich & Milan
  • Customer Service: it is available trough mail, phone and chat although it has mixed review indication room for improvement;
  • Intuitive Interface  including regular, scheduled investment service.
  • Additional tools:price alerts, basic portfolio analysis, and real‑time quotes. Although the platform offers advanced order options, it may not match the full suite of charting and analytical tools found on more specialized trading platforms.

Internalisation and PFOF

ING-DiBa offers the possibility to trade through several exchanges; however, the discounts on fees incentivize routing trades through Tradegate. This raises concerns about Payment for Order Flow (PFOF), though degree of reliance on PFOF cannot be determined due to the lack of a public order execution policy. Tradegate’s internalized execution model suggests potential conflicts of interest, as it limits price competition and may prioritize broker incentives over best execution. Without transparency, there is a risk that orders are routed based on rebates rather than securing the best possible price for clients.

Cash Interest

ING-DiBa offers tiered interest rates on uninvested cash balances in trading accounts. As of December 2024, the Extra-Konto (savings account) linked to trading accounts earns 3% p.a. for the first 4 months on balances up to €250,000. After this introductory period, the rate becomes 1.25% p.a. (valid until January 6, 2025), followed by 1% p.a. from January 7, 2025.

Interest is calculated daily and credited to the account quarterly. These rates are variable and subject to change based on market conditions and ECB policy decisions. 

Advanced Features

ING DiBa offers limited advanced features with an offer focussed on more traditional financial products. 

Features

Investment TypeAvailability
ETFs
Stocks
Bonds
Funds
Options
Derivatives
Futures
CFDs
Forex
Crypto
Commodities✅ (through ETC’s only)

IV. Taxes

Tax Wrappers

ING-DiBa, as a German broker, automatically handles tax obligations for German residents under the flat-rate withholding tax system (Abgeltungssteuer). The broker withholds 25% capital gains tax plus solidarity surcharge (5.5% of the capital gains tax) and church tax if applicable, for a maximum total of approximately 26.375%. The annual tax-free allowance (Sparerpauschbetrag) of €1,000 per person (as of 2024) can be registered with the broker through a tax exemption order (Freistellungsauftrag).

Tax Reporting

The broker provides comprehensive tax reporting services for German residents, including:

  • Annual tax statements (Jahressteuerbescheinigung)
  • Automatic calculation and withholding of taxes on capital gains and dividends
  • Pre-filled tax forms for German tax authorities
  • Detailed transaction history with tax-relevant information
  • Loss offsetting across different types of investments within the same calendar year
  • Automatic consideration of partial exemptions for equity funds (Teilfreistellung)
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