{
    "fund_name": "iShares Core FTSE 100 UCITS ETF Hedged EUR Accumulating",
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": [
        "Currency hedging using derivatives",
        "Securities lending"
    ],
    "classification": "non-complex",
    "supporting_data": "The ETF primarily uses physical replication to track the FTSE 100 Index, which is a straightforward equity index. While it uses derivatives for currency hedging (FX forward contracts) and may engage in securities lending, these activities are common in mainstream ETFs and do not significantly alter the fund's risk profile. The derivatives are used for efficient portfolio management rather than for complex strategies. The underlying index (FTSE 100) is a well-known, liquid equity index, and the fund's risk profile is clearly communicated as medium risk. The use of derivatives here is for hedging and not for leverage or inverse exposure, which are typical complexity triggers under MiFID II. The fund's structure is transparent, and the risks are easily understandable for retail investors.",
    "confidence": 90,
    "counter_argument": "One could argue that the use of derivatives for currency hedging introduces some complexity, but this is a standard practice in many ETFs and does not materially change the fund's risk profile. The derivatives are used for risk management rather than as an inherent part of the investment strategy, which aligns with MiFID II's guidance on non-complex ETFs. The fund's physical replication method and the simplicity of the underlying index further support the non-complex classification.",
    "risk_level": "medium",
    "risk_profile_alignment": "The fund's risk profile is clearly communicated as medium risk, which aligns with the straightforward nature of the FTSE 100 index and the fund's physical replication method. The use of derivatives for hedging does not significantly alter this risk profile."
}