Milieudefensie summary of the summons (in Dutch)

On March 28, 2025, Milieudefensie served a formal summons to ING Bank, initiating a civil lawsuit before the Amsterdam District Court. The case follows a notice of liability issued on January 19, 2024, and a final demand letter on January 16, 2025. ING responded to both letters but did not meet the group’s demands. With over 30,000 co-claimants and 100,000 members, Milieudefensie claims standing under Dutch law to pursue collective environmental and human rights claims.

ING, headquartered in Amsterdam and classified as a systemically important bank, is accused of facilitating dangerous climate change through continued financing of greenhouse gas-intensive industries without adequate climate safeguards. In 2024 alone, ING reported emissions of 261.6 Mt CO₂e, which Milieudefensie notes is approximately 1.75 times the emissions of all Dutch citizens and companies.

Milieudefensie alleges that ING’s climate conduct violates the societal duty of care under Article 6:162 of the Dutch Civil Code. Drawing from precedent (Urgenda v Netherlands, Milieudefensie v. Shell), international climate science (IPCC, IEA), and soft law instruments (UNGPs, OECD Guidelines), the claimant argues that ING’s failure to adopt effective emissions reduction policies constitutes a tortious act.

The summons outlines that ING’s role as a financial enabler of fossil fuel expansion and other high-emission sectors results in both direct and facilitated emissions (scope 3), which ING fails to adequately report or reduce. The case relies heavily on the endangerment doctrine, highlighting ING’s long-term knowledge of climate risks, its capacity to act, and the severe, foreseeable harm resulting from inaction.

Milieudefensie asks the court to compel ING to take the following actions:
	1.	Halve its total emissions by 2030, and continue reducing thereafter, in line with the IPCC’s 1.5°C pathway.
	2.	Reduce emissions in eight major sectors it finances (e.g., steel, aviation) in line with the International Energy Agency’s Net Zero Emissions (NZE) scenario.
	3.	Cease all financing and investment in companies starting new oil and gas projects.
        4. Require all large corporate clients to submit credible, science-based climate plans.

These demands are grounded in Milieudefensie’s argument that absolute emissions reductions (not merely intensity reductions) are essential to fulfilling ING’s legal and human rights obligations.

The summons provides a comprehensive scientific basis, citing the IPCC’s Sixth Assessment Report and carbon budget data, which indicate that global CO₂ emissions must fall by at least 48% by 2030 and reach net-zero by 2050 to preserve a 50% chance of staying within 1.5°C warming.

Milieudefensie also invokes human rights law, emphasizing ING’s responsibility to protect rights to life, health, and a clean and sustainable environment under the ECHR and other international norms. The summons references the KlimaSeniorinnen v. Switzerland judgment, reinforcing that actors cannot evade climate responsibility by pointing to others.

Milieudefensie claims that ING’s “Terra approach” and other existing policies are inadequate because:
	•	They rely primarily on intensity targets instead of absolute reductions;
	•	They exclude 70% of ING’s financed emissions and all facilitated emissions;
	•	ING continues to support fossil fuel companies, including those expanding oil and gas production;
	•	ING lacks lacks absolute sector-specific targets;
	•	Executive remuneration is not linked to emissions reductions;
	•	ING’s engagement policy prioritizes financial risk over climate harm.

According to the Banking on Climate Chaos report, ING ranks among the top 30 fossil fuel financiers globally, having facilitated over €106 billion in fossil fuel investments since the Paris Agreement.

Anticipating ING’s likely “effectiveness” defence, Milieudefensie argues that requiring ING to act would have a direct and indirect impact on global emissions. Citing legal precedents (Urgenda, Shell, KlimaSeniorinnen, Brussels Court of Appeal, Montana case), it affirms that partial responsibility is sufficient for tortious liability and that holding ING accountable can have a systemic, flywheel effect on the market and policy landscape.

On September 9-10, 2026, the Amsterdam District Court ruled that Milieudefensie's claims against ING are admissible, allowing the case to proceed. The court rejected ING's argument that the claims should be dismissed because another bank would simply replace ING's financing of polluting companies if ING reduced it. This was a procedural ruling on admissibility only; the court has not yet addressed the merits of Milieudefensie's claims. A hearing on the merits is expected in Spring 2027.

Milieudefensie v. ING Group and ING Bank

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Milieudefensie v. ING Group and ING Bank - summons

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An aim to achieve a quantifiable outcome within a given time-frame, set by an institution such as a national government.

Policy instruments are techniques or tools used by governing authorities to promote certain policies in order to achieve predetermined goals. Put simply, instruments are how a government tries to achieve its goals, with this taxonomy being focused on national policy instruments.

Risk is the potential for adverse consequences resulting from the dynamic interplay between (climate-related) hazards, exposure, and vulnerability of affected human or ecological systems.

Groups  of people who are adversely affected by climate change or the response to it

A set of principles, processes, and practices that build economic and political power to shift from an extractive economy to a regenerative economy.

Justice is the ethical and political framework that addresses fairness, including issues of responsibility, rights, and structural inequity.

Renewable energy means all forms of energy produced from renewable sources in a sustainable manner.

Fossil fuel is a generic term for non-renewable energy sources such as coal, fossil gas, and oil (including crude oil, and petroleum products), that can be used for electricity and heat generation. Fossil fuels are hydrocarbons formed from pressurised and heated organic material buried over millions of years.

Molecules in the atmosphere that play a key role in the greenhouse effect by trapping heat radiating from Earth’s surface.

Area of the economy in which actors engage in identical or related activities.

In human systems, the process of adjustment to actual or expected climate change and its effects, in order to moderate harm, increase resilience or exploit beneficial opportunities. In natural systems, the process of adjustment to actual climate change and its effects; human intervention may facilitate adjustment to expected climate change and its effects.

The management and allocation of funds, assets and investments to meet various objectives

People who are less able to respond to the effects of climate change due to having limited financial or physical assets

A loan is a policy instrument where funds are provided to a borrower with the expectation of repaying the principal plus interest.

A subsidy is a direct or indirect payment to individuals or businesses, typically provided as a government cash payment or a specific tax reduction.

Removing subsidies can help reduce costs, better align economic incentives with environmental goals, and promote equity. This can mitigate environmental harm and discourage harmful behaviour. However, it may also end support for renewable energy development or negatively impact communities, households, and businesses.

Financial support to help individuals manage the effects of unexpected events, securing their livelihoods and increasing the resilience of people and businesses to the changing climate. It’s especially vital in developing regions where everyday risks, climate-related weather extremes, or crop failures can push people into poverty. Without insurance, people may have to resort to selling assets or cutting consumption to cope with losses.

Tradable permits are market-based tools that grant permission for specific activities, frequently used to regulate emissions. These permits can be issued within a trading system to manage environmental impacts.

Codes and standards are regulatory instruments that specify minimum standards to protect health and safety. This ranges from performance standards, which prescribe outcomes while allowing flexibility to achieve compliance, to the more prescriptive approach of technology-specific standards.

Zoning and spatial planning are both methods for guiding the distribution of people and activities in a space, and are regulatory restriction.

The processes through which enterprises can identify, prevent, mitigate and account for how they address their actual and potential adverse impacts. Due diligence is the idea that reasonable precautions should be taken to avoid causing harm to people, the environment, or society. It also involves identifying and mitigating risks before they occur.

A ban is a legal action that prevents the sale or supply of a product or service, or that recalls a product from the market. Examples are bans on SF6, greenwashing, fossil fuel advertisement or single-use plastics.

An integrated system of hazard monitoring, forecasting and prediction, that enables individuals, communities, governments, businesses and others to take timely action to reduce disaster risks in advance of hazardous events.

Financial actors and resources that are primarily directed towards climate change mitigation, adaptation and compensation.

Dedicated pool of financial resources for climate-related projects.

A financial institution that manages a country's currency and can promote climate-related initiatives through green monetary policy and other means.

A company that is owned wholly or partially by the state, typically operating in key sectors.

A target to reduce the prevalence of a greenhouse gas over a specific time frame

A commitment to balance GHG emissions with removal by a certain point in time, effectively reducing the net emissions to zero

Using laws and the legal system more broadly to protect vulnerable entities

Either money or something of monetary value is transferred between two or more organisations, people or countries.

Conditions that enhance the feasibility of adaptation options. Enabling conditions include finance, technological innovation, strengthening policy instruments, institutional capacity, multi-level governance and changes in human behaviour and lifestyles.

Actions or measures to adapt terrestrial systems to climate change.

Actions or measures to adapt freshwater systems to climate change.

Actions to adapt human health, healthcare systems and well-being to climate change.

Actions to adapt and increase the resilience of rural and urban infrastructure and settlements to climate change.

Actions and measures to adapt and increase resilience of societies and the economy to climate change.

Actions or measures to adapt freshwater, coastal and marine systems to climate change.

Hot temperature extremes are daily maximum temperatures  that were exceeded on average once in a decade or once in 50 years, and includes heatwaves.

A long-lived, colourless gas, chiefly emitted from fossil fuel combustion, deforestation and cement production.

A potent, short-lived greehouse gas, largely released from livestock, fossil fuel extraction and waste management.

Agriculture mitigation refers to practices used to mitigate greenhouse gas emissions at every level of the agrifood systems, from production to consumption.

Replacing technologies that burn fossil fuels directly with alternatives powered by electricity.

Actions to reduce emissions in energy generation and supply.

Technologies that capture and hold energy in reserve for later use.

Risks to the ecosystem health of the marine environment, including ocean warming, ocean acidification, and ocean deoxygenation, harming biodiversity, species health, ecosystem services, and coastal community livelihoods.

Extreme weather refers to events where a weather variable exceeds (or falls below) a threshold. Meaning it is significantly different from the average or usual weather pattern.

A drought is an extended period of unusually dry weather marked by a significant and sustained lack of precipitation, falling below a specific threshold over a large area for more than a month

Terrestrial means "of the earth" and relates to the risks to ecological system that includes all living organisms and their interactions within land-based environments, such as forests, grasslands, and deserts.

Air pollution involves harmful contaminants in the air, affecting both indoor and outdoor environments. It can lead to health issues like respiratory diseases and heart problems, and climate impacts such as global warming. Pollutants can damage plants, trees, habitats, and water bodies like rivers and lakes.

Social inclusion is the process of improving the terms on which individuals and groups take part in society—improving the ability, opportunity, and dignity of those disadvantaged on the basis of their identity.

Production of electricity and heat from solar irradiation.

Kinetic energy of airflow transformed into useful energy, mostly electrical energy.

Oil is a combustible liquid fossil fuel composed mainly of hydrocarbons, occurring as crude oil and refined into petroleum products such as petrol, diesel and kerosene.

Fossil gas, commonly known as natural gas, is a fossil fuel consisting chiefly of methane with smaller amounts of other hydrocarbons and trace gases, found in underground deposits.

Coal is a combustible sedimentary rock formed from carbonised plant matter, rich in carbon and hydrocarbons, and occurring in several main types including hard coal and brown coal.

People with different national or cultural traditions from the dominant population

Work that is productive and delivers a fair income, security in the workplace and social protection for all, better prospects for personal development and social integration, freedom for people to express their concerns, organize and participate in the decisions that affect their lives and equality of opportunity.

Social and cultural groups that share collective ancestral ties to the lands and natural resources where they live, occupy or from which they have been displaced

Jobs that contribute to preserving or restoring the environment. We include jobs which require a high amount of green skills or which spend much of their time on green activities, as well as jobs transforming polluting industries.

People whose health, both mental and physical, makes them more vulnerable to the effects of climate change

People who have left their homes, whether through force, voluntarily, or a mixture of both

woman and genders outside of the gender binary

Activities of industries that extract natural resources, such as mining, oil, and gas, for commercial use.

The activities of industries that transforms raw materials into finished goods through industrial processes.

The activities of industries involved in the production, distribution, and sale of energy, including electricity, gas, and renewables.

This sector involves managing waste treatment, sanitation, pollution control and environmental cleanup.

Activities that involve planning, designing and building infrastructure, residential, and commercial structures.

This sector involves the wholesale and retail selling of goods.

This sector involves activities to move goods and people, alongside the storage of products.

Activities that provide lodging, food, and entertainment services to guests, including hotels, restaurants, and resorts.

This sector creates and distributes information and entertainment through television, radio, print, and digital platforms.

This sector provides communication services, software development, and IT solutions.

This sector involves activities that impart knowledge and skills to individuals, including formal schooling, vocational training and educational support.

Activities of government agencies and institutions that provide public services, enforce laws and manage public resources.

Activities of businesses and institutions that provide financial services and products to individuals and organisations.

Activities that involve the cultivation of crops and raising of livestock for food, fibre, and other products essential for human life and industry.

Activities involving the catching, processing, and selling of fish for food, recreation, and industry.

This sector involves the distribution, treatment, and conservation of water resources.

Climate change can have a range of impacts on technological system. Extreme weather events can cause infrastructure failures like power outages or damage to roads and bridges, as well as the impacts from waste following natural disasters. Human activities also cause technological impacts, such as the risks posed by oil spillage and leaks.

Any substance with chemical properties that can cause physical harm to people or damage the environment, including ammonia, carbon monoxide, phosphine, chlorine, arsenic, cadmium, mercury, pesticides, dioxins, microplastics, benzene, asbestos, aflatoxins, fluoride, methanol, and toxins from marine sources.

Climate change impacts our society by disrupting the natural, economic and social systems we depend on. Physical hazards and underlying vulnerabilities can lead to increased resource competition for food and water, which can heighten the risk of conflict.

Slow onset events evolve gradually from incremental changes over many years or from increased frequency or intensity of recurring events. As defined in the Cancun Adaptation Framework (2010), slow onset events include risks and impacts from rising temperatures, desertification, biodiversity loss, land and forest degradation, glacial retreat, ocean acidification, sea level rise, and salinization.

Heavy precipitation refers to any form of weather where substances fall from the sky, including rain, snow, sleet, or hail.

The cryosphere is the frozen part of the Earth—it includes sea ice, glaciers, snow, and ice sheets. It helps regulate the climate and weather by reflecting sunlight. Rising temperatures are causing melting, leading to sea ice loss, glacier collapse, and glacier landslides and avalanches. This threatens the livelihoods of around 700 million people who rely on the cryosphere for food, water security, and cultural practices.

Geohazards are adverse geological phenomenon's that are capable of causing widespread damage or loss to property, life and the environment, such as earthquakes, volcano eruptions and tsunamis. Climate change can increase the frequency and severity of some geohazards, such as landslides, and soil erosion.

Milieudefensie v. ING Group and ING Bank - summons

Target

Policy instrument

Risk

Impacted group

Just transition

Renewable energy

Fossil fuel

Greenhouse gas

Economic sector

Adaptation/resilience

Finance