{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF is a physically replicated, actively managed government bond fund with no leverage, inverse exposure, or complex derivatives usage. It primarily invests in EUR-denominated government bonds and follows a straightforward active management strategy. The use of derivatives is limited to efficient portfolio management (EPM) purposes only, which does not trigger complexity under MiFID II. The fund's risk profile is transparent, and its underlying assets are liquid and easily understandable. The absence of synthetic replication, leverage, or complex structured products supports the non-complex classification.",
    "confidence": 95,
    "risk_level": 4,
    "benchmark_complexity": "low",
    "esg_integration": true,
    "counterparty_risk": "minimal",
    "liquidity_risk": "low",
    "additional_notes": "While the fund uses derivatives for EPM, this is explicitly permitted under MiFID II without triggering complexity, as the derivatives are not used to alter the fund's risk profile or create additional complexity. The fund's active management and ESG integration do not introduce elements that would make it difficult for retail investors to understand."
}