{
    "fund_name": "Global X Data Center REITs & Digital Infrastructure UCITS ETF",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Unfunded OTC Swaps",
        "Derivative Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The KIID indicates the fund uses 'unfunded' OTC swaps and exchange-traded equity futures for investment purposes, which introduces counterparty risk and complexity. While the primary replication method is physical, the use of derivatives for purposes beyond efficient portfolio management (EPM) and the exposure to counterparty risk from swaps make this a complex instrument under MiFID II. The risk category of 6 also suggests higher complexity and volatility.",
    "confidence": 85,
    "counter_argument": "The fund is UCITS-compliant and primarily uses physical replication, which typically suggests non-complex classification. However, the use of unfunded swaps and the explicit mention of derivative counterparty risk override this argument, as these features introduce additional layers of risk and complexity that retail investors may not fully understand.",
    "risk_level": 6,
    "benchmark_complexity": "The Solactive Data Center REITs & Digital Infrastructure v2 Index is sector-specific and may involve unique risks related to real estate and digital infrastructure, but this alone does not drive the complexity classification. The derivative usage is the primary factor."
}