{
    "fund_name": "iShares Smart City Infrastructure UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The ETF uses physical replication and optimisation techniques, including potential use of financial derivative instruments (FDIs) for direct investment purposes, but this is within the scope of efficient portfolio management (EPM). The primary asset class is equity, with a focus on global smart city infrastructure themes. The risk profile is rated 6 out of 7, but this is due to sector concentration and emerging market exposure rather than structural complexity. The KIID and factsheet indicate no leverage, inverse strategies, or synthetic replication. The use of derivatives is limited and disclosed as part of standard optimisation techniques, not as a core strategy. The fund is UCITS-compliant, which generally aligns with non-complex classifications under MiFID II.",
    "confidence": 90,
    "counter_argument": "Some might argue that the use of derivatives for optimisation could introduce complexity. However, the documentation clearly states that derivatives are used for direct investment purposes and not for leverage or synthetic replication, which are key differentiators for complexity under MiFID II. The fund's transparency, liquidity, and straightforward investment objective further support the non-complex classification.",
    "risk_level": "The fund's risk level is rated 6 out of 7, primarily due to sector concentration and emerging market risks, but this does not equate to structural complexity under MiFID II."
}