{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Xtrackers DAX UCITS ETF aims to replicate the DAX\u00ae Index by buying all or a substantial number of the underlying securities, indicating physical replication. The KIID and PRIIPs KID documents confirm the fund is a UCITS ETF with a straightforward, passive investment objective focused on large-cap German equities. There is no mention of synthetic replication, swap agreements, total return swaps, or derivative instruments used as part of the investment strategy beyond limited use for risk management purposes. The factsheet explicitly states 'Direct Replication (physically)' and lists the top 40 constituents, all equities, with no complex underlying assets such as contingent convertible bonds or CLOs. Leverage or inverse exposure is not present, and the risk profile is medium-high (category 5 out of 7) due to market risk inherent in equity investments, not complexity. Costs are simple with a low ongoing charge (0.09%) and no performance fees or swap fees. Securities lending is minimal and does not add complexity. There are no capital protection or structured features. The risk disclosures mention derivatives risk only in the context of risk management, not as a core strategy element. No complexity flags such as contingent bonds, leverage, or synthetic replication are identified. Therefore, under MiFID II criteria, this ETF is classified as non-complex."
}