{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "leverage": false,
        "complex_factors": [
            "Index composition (small and mid-cap stocks)",
            "Italian specific investment restrictions"
        ],
        "classification": "non-complex",
        "supporting_data": "The ETF tracks the FTSE Italia PIR PMI Net Tax Index, which represents small- and mid-cap stocks on the Borsa Italiana. It uses direct replication, meaning it holds the underlying components of the index. The document states that UCITS are presumed non-complex. There is no mention of derivatives being integral to the strategy, leverage, or any other complex features that would typically lead to a complex classification. While the index composition might be considered more nuanced than a broad-market index, the replication method and the absence of other complex elements support a non-complex classification under MiFID II. The specific Italian investment restrictions are related to the fund's mandate and do not inherently make the instrument complex from a MiFID II perspective, as long as they are clearly disclosed and managed within UCITS regulations. The presence of a counterparty risk disclosure and liquidity risk disclosure is standard for ETFs and does not automatically classify it as complex."
    }
}