{
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Synthetic replication using unfunded OTC swaps",
        "Potential counterparty risk from derivatives",
        "Concentration risk in niche sector"
    ],
    "classification": "complex",
    "supporting_data": "The ETF uses unfunded OTC swaps for replication, which introduces counterparty risk and complexity beyond physical replication. While the underlying index focuses on data center REITs and digital infrastructure (a niche but understandable sector), the synthetic structure and derivative usage trigger MiFID II complexity classification. The KIID mentions 'total return unfunded OTC swaps' and 'exchange-traded equity futures', confirming derivative exposure. The PRIIPs KID would likely contain a comprehension warning if reviewed, further supporting complexity. The fact sheet may provide additional details on swap usage, but the KIID's disclosure of synthetic replication is sufficient to classify this as complex under MiFID II.",
    "confidence": 85
}