{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Fidelity Emerging Markets Quality Income UCITS ETF is a physically replicated ETF that tracks the Fidelity Emerging Markets Quality Income Index. The KIID and factsheet indicate that the fund uses physical replication by holding all or most of the index securities in similar proportions to their weightings in the index. While the KIID mentions that the fund may use derivatives for efficient portfolio management and currency hedging purposes, this usage is limited to EPM (Efficient Portfolio Management) and does not introduce complexity beyond what is typical for standard ETFs. The fund does not employ leverage, inverse strategies, or synthetic replication. The underlying assets are liquid equities from emerging markets, and the fund's risk profile is clearly disclosed. The absence of complex structures, leverage, or significant derivative exposure supports the classification as non-complex under MiFID II.",
    "confidence": 95,
    "counter_argument": "Some might argue that the use of derivatives for any purpose could introduce complexity. However, the derivatives are explicitly stated to be used only for EPM and currency hedging, which are standard practices in many non-complex ETFs. The fund's physical replication method and straightforward investment in equities further support the non-complex classification. The risk profile (risk class 6) is high but does not indicate complexity in structure or strategy."
}