{
    "success": true,
    "data": {
        "leverage": false,
        "derivates": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Use of derivatives for direct investment",
            "Counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "Although the fund is a UCITS ETF using physical (optimised) replication and has a low risk indicator of 2/7, it is classified as complex. The primary reason is the statement in the Key Investor Information Document (KIID) that Financial Derivative Instruments (FDIs) 'may be used for direct investment purposes.' Under MiFID II, using derivatives as part of the direct investment strategy, rather than solely for efficient portfolio management (EPM) like hedging, introduces structural complexity. This usage creates risks, such as the explicitly mentioned 'Counterparty Risk,' which are difficult for an average retail investor to understand. The UCITS presumption of non-complexity is therefore overturned by the fund's potential reliance on derivatives to achieve its investment objective, making its structure and risk profile not simple and difficult to understand, warranting a 'complex' classification."
    }
}