{
    "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": "Although the fund is a UCITS ETF that primarily uses physical replication by investing directly in securities, its classification is driven by the specific features of this share class. The KIID clearly states that this is a currency-hedged share class that 'sells currency forwards' to reduce the impact of currency fluctuations. Currency forwards are derivative instruments. According to the MiFID II framework, while derivative use for EPM (like hedging) can sometimes be non-complex, it becomes complex if it is integral to the strategy and introduces risks that are difficult for retail investors to understand. In this case, the currency hedging is a core, advertised feature of this specific share class, not merely incidental portfolio management. It introduces counterparty risk, which is explicitly mentioned in the KIID ('potential loss due to failure of counterparty'). Understanding the mechanics of currency forwards and the associated counterparty risk requires more than basic financial knowledge. Therefore, the structure makes the product difficult for the average retail investor to understand, overriding the UCITS non-complex presumption and leading to a 'complex' classification."
    }
}