{
    "complex": "non-complex",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [],
    "classification": "non-complex",
    "supporting_data": "The Invesco Global Clean Energy UCITS ETF is classified as non-complex under MiFID II based on the following analysis: 1. Replication Method: The fund uses physical replication (as confirmed in the fact sheet), directly holding securities in the WilderHill New Energy Global Innovation Index. 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,' this is a standard disclosure and not indicative of extensive or complex derivative usage. The fact sheet confirms no swap usage or synthetic replication. 3. Leverage/Inverse: No leverage or inverse exposure is mentioned in any document. 4. Underlying Assets: The index tracks companies in clean energy sectors (wind, solar, etc.) with no mention of complex assets like CoCos or CLOs. 5. Risk Profile: The fund is in risk category 7 (out of 7), but this reflects the volatility of the clean energy sector rather than structural complexity. 6. UCITS Compliance: The fund is UCITS-compliant, which inherently limits complexity. 7. Transparency: The fund provides clear, frequent pricing and holds liquid, transparent securities. The only potential complexity factor is the small-cap focus (higher volatility), but this does not trigger MiFID II complexity classification. The fact that the fund is Article 9 SFDR-compliant (with sustainable investment as its objective) further supports its suitability for retail investors.",
    "confidence": 95
}