{
    "type": "ETF",
    "ucits": true,
    "replication_method": "synthetic",
    "swaps": true,
    "derivatives": true,
    "leverage": false,
    "inverse": false,
    "complex_factors": [
        "Synthetic replication via unfunded swap",
        "Counterparty risk exposure",
        "Emerging markets exposure",
        "Derivative usage inherent to strategy"
    ],
    "classification": "complex",
    "supporting_data": "The Xtrackers CSI500 Swap UCITS ETF uses synthetic replication through swap agreements with one or more counterparties to achieve its investment objective, as explicitly stated in the KIID and factsheet. The fund invests in derivatives (swaps) rather than physical securities, which is a key complexity indicator under MiFID II. The swap is unfunded, exposing investors to counterparty risk, which is clearly disclosed in both KIID and PRIIPs documents. There is no leverage or inverse exposure, but the use of derivatives is inherent to the strategy, not merely for risk management. The underlying index tracks 500 small and medium cap Chinese equities, an emerging market with additional political, liquidity, and country risks, adding to complexity. The risk profile is medium-high (5/7), consistent with the complexity of derivative usage and emerging market exposure. Costs are straightforward with no performance fees, but swap-related costs and counterparty risks remain. The PRIIPs KID does not carry a specific comprehension warning but highlights derivative and counterparty risks prominently. Overall, the synthetic replication via swaps and the associated counterparty risk drive the classification as complex under MiFID II, despite the fund being UCITS compliant and having no leverage or capital protection features."
}