{
    "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 MSCI Europe Universal Screened UCITS ETF is classified as non-complex under MiFID II based on the following analysis: 1. Replication Method: The fund uses physical replication, as explicitly stated in the PRIIPs KID ('Physical' replication method). This is a non-complex indicator. 2. Derivative Usage: While the KIID mentions the fund 'may use derivative instruments for the purposes of managing risk, reducing costs or generating additional capital or income,' the PRIIPs KID and factsheet confirm no actual derivative usage for investment purposes. The derivatives clause appears to be a standard legal disclaimer rather than an active strategy. 3. Leverage/Inverse Exposure: No leverage or inverse exposure is indicated in any of the documents. 4. Underlying Assets: The fund invests in large/mid-cap European equities with ESG screening, which are transparent and liquid. 5. Risk Profile: The fund is in risk category 6 (out of 7), which is relatively high but not indicative of complexity. The risks are standard equity risks (market, currency, ESG). 6. Costs: The ongoing charge is 0.16%, with no performance fees or complex fee structures. 7. UCITS Compliance: The fund is UCITS-compliant, which inherently limits complexity. The only potential complexity factor is the ESG screening methodology, but this does not trigger MiFID II complexity rules. The fund's structure is straightforward, with daily liquidity and transparent holdings. The absence of synthetic replication, leverage, or complex derivatives confirms the non-complex classification.",
    "confidence": 95
}