{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": true,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Derivatives",
            "Swaps"
        ],
        "classification": "complex",
        "supporting_data": "Although this is a UCITS ETF that uses physical replication as its primary strategy, which typically points to a non-complex classification, its KIID explicitly states the Fund 'may... invest in financial derivative instruments (FDIs)' including 'swaps (equity swaps and swaps on the Index)'. Under MiFID II rules, the use of derivatives, particularly swaps, for anything other than basic efficient portfolio management introduces a layer of complexity and risk (e.g., counterparty risk) that is considered difficult for an average retail investor to understand. The ability to use swaps, even if not the primary strategy, is a significant factor. ESMA guidelines and MiFID II (Delegated Regulation EU 2017/565 Article 57) focus on whether the structure and risks are easy to grasp. The inclusion of potential swap usage makes the fund's structure opaque and its risk profile harder to assess than a purely physically replicated ETF, thereby overriding the non-complex presumption for UCITS and mandating a 'complex' classification."
    }
}