{
    "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 S&P 500 CTB Net Zero Pathway ESG UCITS ETF is classified as non-complex under MiFID II. The fund uses physical replication to track the S&P 500 Climate Transition Base Pathway-Aligned ESG Index, with no mention of synthetic replication, swaps, or derivatives. The fund's investment objective is straightforward, focusing on large-cap US equities with an ESG and climate transition overlay. The risk profile is typical for an equity ETF, with no leverage, inverse exposure, or complex structured features. The fund is UCITS-compliant, which inherently aligns with MiFID II's transparency and investor protection standards. The PRIIPs KID and fact sheet confirm the physical replication method and lack of derivative usage beyond efficient portfolio management. The index methodology, while incorporating ESG and climate transition criteria, does not introduce complexity beyond standard equity index tracking. The fund's risk category (6/7) is consistent with its equity exposure and does not indicate complexity. No counterparty risk or collateral management risks are disclosed, further supporting the non-complex classification.",
    "confidence": 95
}