{
    "type": "ETF",
    "ucits": true,
    "fund_name": "Xtrackers MSCI Europe Small Cap UCITS ETF",
    "investment_objective": "To replicate the performance of the MSCI Total Return Net Europe Small Cap Index by buying a portfolio of securities that may comprise the constituents of the index or other unrelated investments.",
    "primary_asset_class": "Equity",
    "geographic_focus": "European developed markets",
    "replication_method": "physical",
    "swaps": false,
    "derivatives": false,
    "leverage": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses direct physical replication as confirmed by the factsheet stating 'Direct Replication (physically)'. There is no mention of synthetic replication, swap agreements, or total return swaps in the KIID, PRIIPs KID, or factsheet. The fund may use derivatives only for risk management purposes, which does not trigger complexity under MiFID II. There is no leverage or inverse exposure indicated. The underlying assets are small and mid-cap European equities, which are liquid and transparent. No capital protection or structured features are present. The risk profile is medium-high (5/7), reflecting market volatility and small-cap risks, but not complexity from derivatives or leverage. Costs are straightforward with a TER around 0.30%, no performance fees, and minor securities lending income. No complexity warnings or comprehension warnings appear in the PRIIPs KID. The index tracked is a standard MSCI small cap index without complex features. Therefore, the ETF is classified as non-complex under MiFID II criteria."
}