{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Vanguard FTSE 250 UCITS ETF is a UCITS-compliant exchange-traded fund that physically replicates the FTSE 250 Index by acquiring the underlying securities directly or via representative sampling when full replication is impracticable. The KIID and PRIIPs KID explicitly state the use of physical acquisition of securities and do not mention synthetic replication, swap agreements, or total return swaps. Derivatives may be used only for risk reduction, cost efficiency, or generating additional income, but not as an inherent part of the investment strategy, so derivative use is considered incidental and not complexity-driving. There is no leverage, inverse exposure, or capital protection mechanism. The risk rating is 6 in the KIID but 4 in the PRIIPs KID; the higher KIID rating reflects equity market risk and concentration risk in mid-cap UK stocks rather than complexity from derivatives or leverage. The factsheet confirms physical replication, no synthetic structures, no funded or unfunded swaps, and no complex underlying assets such as contingent convertible bonds or CLOs. Costs are straightforward with a low ongoing charge (0.10%) and no performance fees or swap fees. The fund engages in short-term securities lending to generate additional income, which is common and not a complexity factor under MiFID II. There are no capital protection or structured features. The PRIIPs KID includes a standard comprehension warning that the product 'is not simple and may be difficult to understand,' which is typical for equity ETFs tracking mid-cap indices but does not indicate synthetic or leveraged complexity. Overall, the fund's structure, replication method, and risk disclosures align with a non-complex classification under MiFID II."
}