{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Swaps",
        "Derivative Usage"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its use of total return swaps and derivatives, even though it primarily employs physical replication. The KIID explicitly states that the fund may invest up to 10% of its assets in total return swaps and contracts for difference, which introduces counterparty risk and potential complexity in understanding the fund's performance drivers. Additionally, the fund may use derivatives for efficient portfolio management, which, while not leveraged, still adds a layer of complexity. The presence of these elements, combined with the fund's exposure to real estate and potential liquidity risks, aligns with MiFID II criteria for complex instruments. The fund's risk profile is categorized as level 6, indicating higher volatility and risk, further supporting the complex classification.",
    "confidence": 85,
    "risk_level": 6,
    "counter_argument": "The fund could be argued as non-complex due to its primary use of physical replication and straightforward index-tracking objective. However, the explicit allowance for swaps and derivatives, even if limited, introduces elements that require a more sophisticated understanding of the fund's mechanics and risks, thus overriding the non-complex argument."
}