{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Vanguard FTSE 100 UCITS ETF (GBP) Accumulating",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Vanguard FTSE 100 UCITS ETF employs a passive, physical replication strategy by investing directly in the constituent securities of the FTSE 100 Index, using full replication or representative sampling only when full replication is impracticable. There is no indication of synthetic replication or use of swap agreements. The fund may use derivatives only for risk reduction or cost management, not as an inherent part of the investment strategy, so derivatives are considered non-complex in this context. There is no leverage, inverse or amplified exposure. The underlying assets are large-cap UK equities, which are liquid and transparent. No capital protection or structured features are present. The risk profile is medium (4 in PRIIPs, 6 in KIID), reflecting equity market risk and some counterparty and liquidity risk typical of physical equity ETFs, but not complexity. Costs are straightforward with a low ongoing charge (0.09%) and no performance fees or swap fees. The PRIIPs KID includes a comprehension warning stating the fund is 'not simple and may be difficult to understand,' but this is a standard phrase for equity ETFs and does not reflect structural complexity such as synthetic replication or leverage. The monthly factsheet confirms physical acquisition of securities, no use of swaps, and a straightforward benchmark (FTSE 100). Therefore, under MiFID II criteria, this ETF is classified as non-complex."
}