{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Unfunded swaps",
        "Synthetic replication",
        "Counterparty risk",
        "Commodity futures exposure",
        "Complex index with GHG tilting"
    ],
    "classification": "complex",
    "supporting_data": "The Invesco Bloomberg Commodity Carbon Tilted UCITS ETF uses unfunded swap agreements to achieve its investment objective, explicitly stated in the KIID and fact sheet. The Fund does not physically hold the underlying commodities but holds a diversified basket of US Treasury Bills and swaps the performance of the Bloomberg Commodity Carbon Tilted Index via these swaps. The index itself is complex, based on commodity futures with an environmental tilt (GHG emissions), which adds complexity beyond a simple commodity index. The Fund carries counterparty risk due to reliance on swap counterparties, with collateral arrangements mentioned. The risk profile is medium-high (risk category 6 in KIID, 4/7 in PRIIPs), reflecting the volatility of commodity futures and synthetic structure. There is no leverage or inverse exposure, but the use of synthetic replication via unfunded swaps and exposure to commodity futures derivatives makes the ETF complex under MiFID II. The PRIIPs KID confirms medium risk and highlights counterparty risk and derivative use. The monthly factsheet confirms synthetic replication, swap fees (~0.19%), and no physical replication. No capital protection or structured features are present. Costs include swap fees and ongoing charges. Overall, the synthetic replication with unfunded swaps and counterparty risk, combined with the complex underlying commodity futures index with environmental tilting, drive the classification as complex under MiFID II."
}