{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Unfunded Swaps",
        "Synthetic Replication",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The Invesco S&P 500 UCITS ETF EUR Hdg Acc uses unfunded swap agreements to achieve its investment objective, explicitly described as synthetic replication. The Fund holds a basket of equities that do not fully replicate the index and swaps the performance of these equities for the performance of the S&P 500 EUR Daily Hedged Index. The use of unfunded swaps introduces counterparty risk, which is highlighted in both the KIID and PRIIPs KID documents. There is no leverage or inverse exposure, and derivatives are used as an inherent part of the investment strategy rather than solely for risk management, so 'derivatives' is marked false per instructions. The risk profile is medium-high (risk category 5-6), reflecting the complexity and counterparty risk. Costs include a swap fee (0.40% p.a.) in addition to the ongoing charge, indicating derivative-related costs. The synthetic replication and swap usage are the primary drivers of the complex classification under MiFID II, despite the fund being UCITS compliant and having no leverage. The PRIIPs KID does not include a comprehension warning but confirms the medium-high risk and counterparty risk exposure. The factsheet confirms synthetic replication, swap usage, and counterparty risk, with no leverage or capital protection features. The fund\u2019s complexity arises from the synthetic structure and counterparty exposure, which may reduce transparency and increase risk for retail investors, making it a complex financial instrument under MiFID II."
}