{
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "Swaps",
        "Derivatives for investment purposes"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication but allows for up to 10% exposure to total return swaps and contracts for difference, which introduces counterparty risk and derivative complexity. While the primary method is physical, the explicit mention of derivative usage for investment purposes (not just efficient portfolio management) and the potential for swap exposure up to 10% of assets triggers complexity under MiFID II. The KIID also highlights derivative risk and counterparty risk as material risks not fully captured by the standard risk indicator, further supporting the complex classification.",
    "confidence": 90,
    "risk_level": 6,
    "counterparty_risk": true,
    "liquidity_risk": false,
    "capital_protection": false,
    "structured_features": false,
    "illiquid_assets": false,
    "benchmark_complexity": false,
    "additional_notes": "Although the ETF is UCITS-compliant and primarily physically replicated, the explicit allowance for derivative usage beyond efficient portfolio management (EPM) and the potential for swap exposure (even if limited) introduces elements of complexity. The presence of derivative-related risks in the KIID, including counterparty risk and investment leverage risk, further supports the classification as complex under MiFID II. The fund's risk level of 6 also indicates higher volatility, which may not be easily understood by retail investors."
}