{
    "complex": false,
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Invesco MSCI USA Universal Screened UCITS ETF is classified as non-complex under MiFID II based on the following analysis: 1. Replication Method: The fund uses physical replication, as explicitly stated in the PRIIPs KID ('Physical Replication'). This means it directly holds the underlying securities of the MSCI USA ESG Universal Select Business Screens Index, which is a straightforward approach. 2. Derivative Usage: While the KIID mentions the fund 'may use derivative instruments for the purposes of managing risk, reducing costs or generating additional capital or income,' the PRIIPs KID clarifies that derivatives are not used for replication (physical replication method). The fact sheet and PRIIPs KID show no evidence of swap usage or synthetic replication. 3. Leverage/Inverse Exposure: There is no mention of leverage, inverse exposure, or amplified returns in any of the documents. 4. Underlying Assets: The fund invests in large and mid-cap US equities with ESG screening, which are liquid and transparent securities. 5. Risk Profile: The fund is in risk category 6 (out of 7), but this is typical for equity funds and does not indicate complexity. The risks disclosed are standard for equity investments (market risk, ESG risk, etc.). 6. Costs: The ongoing charge is 0.09%, and there are no performance fees or complex fee structures. 7. UCITS Compliance: The fund is UCITS-compliant, which inherently limits complexity. The only potential complexity factor is the ESG screening methodology of the index, but this does not make the fund complex under MiFID II. The fund's structure is transparent, with daily liquidity and no evidence of sophisticated derivative strategies.",
    "confidence": 95
}