{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Invesco MSCI Europe ESG Climate Paris Aligned UCITS ETF is a passively managed ETF aiming to track the MSCI Europe ESG Climate Paris Aligned Benchmark Select Index by physical replication, holding as far as possible all securities in the index in their respective weightings. The KIID and PRIIPs KID explicitly state that derivatives may be used only for risk management, cost reduction, or generating additional capital or income, but not as an inherent part of the investment strategy, and no synthetic replication or swap usage is mentioned. The monthly factsheet confirms physical replication and no use of synthetic instruments or leverage. The fund is UCITS compliant, with no leverage or inverse exposure, and no capital protection or structured features. The risk indicator is medium (4 out of 7 in PRIIPs KID, 6 in KIID, reflecting market risk rather than complexity). Costs are straightforward with a low ongoing charge (0.16%) and no performance fees. Securities lending is used but is a common practice and does not add complexity under MiFID II. There are no references to complex underlying assets such as contingent convertible bonds or CLOs. The index tracked is ESG-optimized but does not introduce complexity through derivatives or structured products. No comprehension warnings or complexity flags appear in the PRIIPs KID. Therefore, the ETF does not meet the MiFID II criteria for a complex financial instrument."
}