{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Invesco NASDAQ-100 ESG UCITS ETF is a passively managed ETF aiming to track the NASDAQ-100 ESG Index by holding, as far as practicable, all the underlying securities in their respective weightings, indicating physical replication. There is no mention of synthetic replication, swap agreements, or derivative instruments used as part of the investment strategy, only that derivatives may be used for risk management or cost reduction, which does not trigger complexity under MiFID II. The fund does not employ leverage, inverse or amplified exposure. The underlying assets are equities of large, liquid companies primarily in the US technology sector, with no complex structured products or contingent bonds. The risk profile is medium-high (risk category 5-6), typical for equity ETFs, but this is due to market volatility rather than structural complexity. The fund is UCITS compliant, with a straightforward fee structure (ongoing charge 0.25%), no performance fees, and no swap or derivative fees disclosed. Securities lending is used but is a common practice and does not add complexity. The PRIIPs KID does not include any comprehension warnings or complexity flags. The factsheet confirms physical replication and no use of swaps or synthetic structures. The index tracked applies ESG exclusions and reweightings but does not involve complex derivatives or contingent features. Therefore, the ETF is classified as non-complex under MiFID II criteria."
}