{
    "success": true,
    "data": {
        "ucits": true,
        "type": "ETF",
        "replication_method": "physical",
        "derivatives": false,
        "swaps": false,
        "inverse": false,
        "leverage": false,
        "complex_factors": [],
        "classification": "non-complex",
        "supporting_data": "The ETF tracks the ATX index, which is composed of 20 Austrian companies. The KIID states the fund is passively managed and aims to replicate the index by buying all or a substantial number of the securities in the index (physical replication). The use of derivatives is mentioned as a possibility for risk management, cost reduction, and improving results, but not as integral to the investment objective. Securities lending is also mentioned as a way to generate additional income. The risk and reward profile is rated category 7, indicating strong fluctuations, but this is due to market risk, not structural complexity. The explanation of the index and the replication method are straightforward. There are no indications of embedded derivatives, leverage, or other complex features. The fee structure is standard for an ETF. The presence of securities lending does not automatically classify the ETF as complex, especially since it's a secondary feature managed within UCITS rules. The primary replication method being physical and the index being a well-established equity index points towards a non-complex classification. The KIID does not mention any features that would make the structure, risks, or payoff difficult for a retail investor to understand. The phrase 'The fund will attempt to replicate the performance of the index less costs, but your investment is not expected to match the performance of the index precisely' and 'The anticipated level of tracking error in normal market conditions is 1 per cent' are standard disclosures for passive ETFs and do not indicate complexity. The fact that the fund is classified in category 7 of the risk indicator does not inherently make it complex according to MiFID II guidelines; it refers to market risk. ESMA guidelines, particularly ESMA35-36-1640, clarify that complexity arises from the structure of the instrument. This ETF's structure is described as physical replication of a standard equity index, which is considered non-complex. The use of derivatives for efficient portfolio management, as mentioned, is generally acceptable for non-complex classification if limited and not integral to the strategy. The information provided does not suggest otherwise. Therefore, based on the available information and MiFID II criteria, the ETF is classified as non-complex."
    }
}