{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Xtrackers Spain UCITS ETF aims to replicate the Solactive Spain 40 Index by direct physical replication, purchasing a substantial number of the underlying shares. The KIID and PRIIPs documents confirm the fund is UCITS compliant and uses physical replication rather than synthetic or swap-based methods. While the fund may use derivatives for risk management or cost reduction, these are not inherent to the investment strategy and are limited in scope, so derivatives are marked false. There is no leverage, inverse or amplified exposure mentioned. The underlying assets are large-cap Spanish equities, which are liquid and transparent. No capital protection or structured features are present. The risk profile is medium-high (risk level 5 out of 7), reflecting market and regional concentration risks rather than complexity. Costs are straightforward with a single ongoing charge of 0.30% and no performance fees or swap fees. Securities lending is minimal and revenue sharing is disclosed but does not increase costs. The factsheet confirms direct physical replication with no swap usage. 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."
}