{
    "type": "ETF",
    "ucits": true,
    "replication_method": "physical",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "complex_factors": [
        "Emerging market exposure",
        "Potential use of ADRs/GDRs",
        "Counterparty risk from securities lending"
    ],
    "classification": "non-complex",
    "supporting_data": "The iShares MSCI EM UCITS ETF USD (Dist) is classified as non-complex under MiFID II based on the following analysis: The fund uses physical replication (as confirmed in the PRIIPs KID) and does not employ leverage, inverse strategies, or synthetic replication methods. While it may use derivatives for direct investment purposes (e.g., ADRs/GDRs), these are not used for leverage or complex strategies. The fund's primary risk factors (emerging market exposure, currency risk, and counterparty risk from securities lending) are clearly disclosed and typical for equity ETFs. The absence of structured products, capital protection features, or complex derivatives supports this classification. The fund's risk rating (6/7) is within the typical range for equity ETFs and does not indicate excessive complexity. The PRIIPs KID does not contain a comprehension warning, further supporting the non-complex classification.",
    "confidence": 90
}