{
    "success": true,
    "data": {
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "ucits": true,
        "type": "ETF",
        "complex_factors": [
            "Currency hedging using derivatives (forwards)",
            "Counterparty risk"
        ],
        "classification": "complex",
        "supporting_data": "The asset is a UCITS ETF that uses physical replication, which are factors that support a non-complex classification. However, the assessment identifies this specific share class as complex due to its currency hedging strategy. The KID states that the fund uses 'foreign currency forwards' to hedge currency risk for this share class. These forwards are derivative instruments, and their use is integral to achieving the investment objective of this specific hedged share class, not merely for incidental efficient portfolio management. The KID explicitly warns of risks associated with derivatives, including 'potential loss due to failure of counterparty.' The introduction of derivative instruments and the associated counterparty risk makes the ETF's structure and risk profile difficult for an average retail investor to understand, thus overturning the initial non-complex presumption for UCITS. As per MiFID II and ESMA guidelines, a financial instrument that incorporates a structure making it difficult for the client to understand the risk involved is classified as complex. The currency hedging mechanism constitutes such a structure."
    }
}