{
    "success": true,
    "data": {
        "type": "ETF",
        "ucits": true,
        "leverage": false,
        "derivatives": true,
        "swaps": false,
        "inverse": false,
        "replication_method": "physical",
        "complex_factors": [],
        "classification": "non-complex",
        "supporting_data": "The Fund is explicitly identified as a UCITS ETF ('Invesco FTSE Emerging Markets High Dividend Low Volatility UCITS ETF'). According to the MiFID II Complexity Assessment Rules and, critically, the provided ESMA guidance (CESR/09-295, Section IV, Paragraph 69 and 80, and Annex I), all UCITS are automatically classified as non-complex for the purposes of appropriateness requirements. Paragraph 69 states: 'All investments in UCITS are non-complex instruments by definition, for the purposes of the appropriateness requirements, regardless of the underlying instruments in which the UCITS invests. Nothing in MiFID Art.19(6) requires a person to look through to the underlying investments of the UCITS for these purposes.' Furthermore, Annex I of the ESMA guidance explicitly lists 'Units (or u2018sharesu2019) in any UCITS' as 'AUTOMATICALLY NON-COMPLEX UNDER ART. 19(6)' and notes that 'the fact that an undertaking invests in derivatives will not automatically make it u2018complexu2019 for these purposes.'The KII document indicates that the Fund aims to 'replicate all of the constituents of the Index' by holding 'all the securities in the Index in their respective weightings,' confirming a physical replication method, which supports a non-complex classification. The Fund does engage in securities lending ('The Fund may engage in securities lending'), which involves derivative instruments for efficient portfolio management and introduces counterparty risk. However, per the ESMA guidance for UCITS, this does not automatically render the UCITS ETF complex. There is no indication of significant leverage or the use of swaps for index replication. The index tracked is an equity index based on dividend yield and volatility criteria, which is transparent and does not suggest the type of inherent complexity (e.g., roll costs, contango) that would make the ETF difficult for retail investors to understand beyond typical market risks. The high-risk category (6/7) is attributed to market fluctuations, not structural complexity. Based on the explicit regulatory definition for UCITS, the ETF is classified as non-complex."
    }
}