{
    "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 UBS (Irl) ETF plc - MSCI ACWI Universal UCITS ETF (hedged to USD) A-acc (ISIN: IE00BDQZN113) is classified as non-complex under MiFID II based on the following analysis: 1. Replication Method: The ETF uses physical replication with stratified sampling, as confirmed in the factsheet. It invests directly in the constituent stocks of the MSCI ACWI Universal Low Carbon Select 5% Issuer Capped with Developed Markets 100% Hedged to USD Index (Net Total Return). 2. Derivative Usage: While the KIID mentions the possibility of using derivatives to reduce investor risks, the factsheet explicitly states the fund uses physical replication. The only derivative-like activity mentioned is currency hedging via foreign currency forwards, which is a standard practice for hedged ETFs and does not trigger complexity under MiFID II. 3. Leverage and Inverse Exposure: The fund does not employ any leverage or inverse strategies. 4. Underlying Assets: The fund invests in large and mid-cap equities across developed and emerging markets, which are liquid and transparent securities. 5. Risk Profile: The fund is in risk category 6 due to equity market volatility, but this is typical for equity ETFs and does not indicate complexity. 6. Costs and Charges: The fund has a straightforward fee structure with a TER of 0.26%, with no performance fees or complex cost structures. 7. UCITS Compliance: The fund is UCITS-compliant, which inherently limits complexity. 8. Index Complexity: The MSCI ACWI Universal Low Carbon Select index is a standard equity index with ESG tilts, not a complex or structured index. The only potential complexity factor is the ESG methodology, but this does not trigger a complex classification under MiFID II. The fund's documentation does not contain any comprehension warnings or indications that it may be unsuitable for retail investors. The factsheet confirms the fund is passively managed and does not use synthetic replication or swaps. The only derivative usage is for currency hedging, which is standard for hedged ETFs and does not make the fund complex. The fund's risk profile is clearly explained, and the underlying assets are liquid and transparent. Therefore, the fund is classified as non-complex under MiFID II.",
    "confidence": 95
}