{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "leverage": false,
        "derivates": false,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "complex_factors": [],
        "classification": "non-complex",
        "supporting_data": "The Invesco EQQQ NASDAQ-100 UCITS ETF is designed to track the NASDAQ-100 Notional Index (Net Total Return) in GBP. It uses physical replication, holding all the shares in the Index. The KID states the ETF uses foreign exchange transactions to minimise exposure to fluctuations. There is no mention of derivatives being central to the strategy, leverage, or complex structures like capital protection. The fund's objective, structure, and risks appear straightforward for retail investors. Therefore, based on the provided information, the ETF is non-complex under MiFID II.",
        "esma_assessment": "The ETF's structure is clear. It uses physical replication, which is straightforward, and its objective is to track a transparent index, minimizing complexity. The KID states this fund is in risk category 6 indicating some market risk. The ETF holds all the shares in the index and therefore can be considered non-complex per MiFID II Article 25(3). Furthermore, this is consistent with the ESMA guidelines on MiFID II and in reference to the ESMA document referencing Supervisory briefing ESMA35-36-1640, MiFID II Appropriateness and Execution-only in reference to 2.1 Determining situations where the appropriateness assessment is required in paragraph 15 of the document: 'In accordance with Article 25 (3) of MiFID II , when providing MiFID investment services other than investment advice or discretionary portfolio management services, firms must ask the client or potential client to provide information regarding that personu2019s knowledge and experience in the investment field relevant to the specific type of investment prod uct or service offered or demanded to assess whether the investment service or product envisaged is appropriate for the client in question.'"
    }
}