{
    "fund_name": "Invesco Preferred Shares UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Perpetual Preferred Securities",
        "Subordinated Debt Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its exposure to perpetual preferred securities and subordinated debt, which are inherently complex instruments. These securities have no maturity date, can defer or omit distributions, and have lower priority in bankruptcy, making them harder to value and understand. Additionally, the risk category of 6 and the extensive disclosures about the risks associated with preferred securities and subordinated debt further support this classification. While the ETF uses physical replication and does not employ leverage or derivatives, the underlying assets' complexity is sufficient to warrant a 'complex' classification under MiFID II.",
    "confidence": 85,
    "risk_level": 6,
    "counter_argument": "The ETF uses physical replication and does not employ leverage or derivatives, which are typically indicators of non-complexity. However, the complexity of the underlying assets (perpetual preferred securities and subordinated debt) overrides these factors, as these instruments require specialist knowledge to understand fully.",
    "additional_notes": "The ETF's high risk level (6) and the detailed risk disclosures about the specific risks associated with preferred securities and subordinated debt further reinforce the complexity classification. The fact that these securities can be perpetual and have deferrable distributions adds to their complexity."
}