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EMERGE 2025 Reflection: Game On! ING Trailblazes with Innovative Financial Health Measurement

Working together to embed financial health into the DNA of banking and financial services will be more sustainable and effective than trying to mandate and regulate it.

By Michael J. Hsu

Monday, September 15, 2025
 EMERGE 2025 Reflection: Game On! ING Trailblazes with Innovative Financial Health Measurement

Financial Health Vital Signs is no longer just a theory.  

At EMERGE 2022, inspired by the amazing work of the Financial Health Network (FHN) and its members, I sketched out a vision for simple, granular, real-time metrics – like vital signs – to measure the financial health of individual consumers. Two years later I was able to follow up at EMERGE 2024 with a white paper from the Office of Comptroller of the Currency (OCC) that put flesh on the bones of the Financial Health Vital Signs idea.  

I expected that it would then take another couple of years for banks to do the research and heavy lifting needed to turn theory into reality. And then perhaps another year or so to get things ready for sharing with the public.  

Imagine my surprise and delight when Jennifer Tesher interviewed Peter Jacobs, CEO of ING Netherlands at EMERGE 2025 last spring (“Charting the Future of Financial Health”). Jacobs shared details from ING’s financial health measurement program, with findings from a recent white paper. ING went well beyond mere research to robustly measure the financial health of its customers. ING published its methodology and results, noting areas for future study, and actively embedding financial health thinking into its processes and business.  

“We are shifting from measuring just product sales to measuring customer outcomes,” said Jacobs in the discussion. “It’s not enough to sell a savings account, we want to know if people are actually saving. That’s how we start to make financial health part of the DNA of banking.”

In addition to trailblazing and being the first to measure the financial health of its customers, ING set the bar high by publishing insights from its work. For instance, ING tracked changes in financial health outcomes over time, noting that in aggregate increases were largely offset by decreases.

Contradictory/complementary findings: customers move between categories

% of customers who experience a Financial Health Indicator increase/decrease between Dec ‘23 and Dec ‘24 based on statistical sample-based analysis. Note: % of customers who experience a Financial Health Indicator increase/decrease between Dec ‘23 and Dec ‘24 based on statistical sample-based analysis.
Source: Financial Health Indicator white paper (ING)

ING also captured the impact of different products on the financial health of stressed and vulnerable consumers, finding goal-based and automatic savings products driving significant improvements and overdrafts leading to poorer financial health outcomes. ING assesses these outcomes over time by measuring the difference between users of their offerings and comparable control groups.

Financial Health indicator Increase After 12 months

Financial Health indicator Increase After 12 months
Source: Financial Health Indicator white paper (ING)

Financial Health Indicator Decrease After 12 months

Financial Health Indicator Decrease After 12 months
Source: Financial Health Indicator white paper (ING)

These are just a few examples. The white paper contains many more insights. Those interested in consumer financial services, consumer protection, financial inclusion, and community advocacy should read it carefully.  

The Financial Health Network has also been innovating in this area — establishing the first clear framework for the dimensions of financial health which include spend, save, borrow and plan. The new FinHealth Standards, also released at EMERGE 2025, provide guidelines for how to build financial health right into the core of products and services. The first edition, released this summer, directly addresses spending management tools, with specific guidelines for features, policies, and account onboarding. Later this year, FHN will release an Industry Assessment for these standards.

Together FHN and ING’s efforts represent a significant step forward in measuring financial health.  For this to inspire the momentum we need, though, everyone needs to lean in and do their part: 

    • Banks, data aggregators, and fintechs need to study, learn from, and improve on ING’s work. Organizations that have financial health measurement initiatives already underway should accelerate their plans for implementation and roll out. Those who are new to financial health should benchmark themselves against the FinHealth Standards.  
    • Trade groups and banking associations should share ING’s white paper and FHN’s FinHealth Standards with their members. FHN stands ready to present, engage, and discuss financial health measurement pilots with any and all interested parties. 
    • Regulators should focus on encouraging financial institutions to adopt and accelerate their own financial health measurement initiatives. Regulators should continue to prioritize engagement, innovation, and building momentum towards a race to the top.  
    • Consumer and community advocates should focus on working with leading financial institutions and trade groups to build a strong culture around financial health measurement, building off of the FinHealth Standards and ING’s trailblazing efforts.  

Working together to embed financial health into the DNA of banking and financial services will be more sustainable and effective than trying to mandate and regulate it.  

The groundbreaking work of Financial Health Network to develop the first set of voluntary product-design standards — along with ING’s data-driven measurement work — should inspire and energize all who believe in financial health. Both are built on research foundations and shared values, showing what’s possible and inviting us to think bigger, work harder, and move faster. We each have a role to play in promoting consumer financial health at scale. Game on!

Written by

  • Michael J. Hsu
    Former Acting Comptroller of the Currency
    Office of the Comptroller of the Currency