{
    "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 Pacific Ex Japan 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') and confirmed by the absence of any synthetic replication language or swap references in both the KIID and PRIIPs documents. 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 for UCITS funds and does not indicate active derivative usage. The PRIIPs KID and factsheet confirm physical replication with no swap or derivative exposure. 3. Leverage/Inverse: No leverage or inverse exposure is mentioned in any document. 4. Underlying Assets: The fund invests in large/mid-cap equities across Pacific ex-Japan markets with ESG screens, which are straightforward and transparent. 5. Risk Profile: The risk category is 6/7, but this reflects equity market risk rather than structural complexity. 6. Costs: Simple TER structure with no swap fees or performance-related charges. 7. UCITS Compliance: The fund is explicitly UCITS-compliant, which inherently limits complexity. The only potential complexity factor would be the ESG screening methodology, but this does not meet MiFID II's complexity thresholds. The absence of synthetic replication, leverage, or inverse strategies, combined with the fund's transparent physical replication approach, supports the non-complex classification.",
    "confidence": 95
}