{
    "complex": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "ucits": true,
    "type": "ETF",
    "complex_factors": [
        "Swap usage",
        "Counterparty risk",
        "Complex index"
    ],
    "classification": "complex",
    "supporting_data": "The ETF is classified as complex primarily due to its use of derivatives (specifically swaps) for replication purposes, which introduces counterparty risk. While the KIID states the fund uses 'physical replication' (as confirmed in the factsheet), the KIID also mentions that the fund 'may use derivatives' where direct replication is not possible or practical. This creates potential complexity due to counterparty risk, even if the primary replication method is physical. The MSCI EMU Quality Advanced Target Select Index is a complex index with multiple factor-based and ESG screening criteria, which may not be easily understood by retail investors. Additionally, the risk profile is rated 6/7, indicating high volatility. While the fund does not use leverage or inverse strategies, the combination of derivative usage (even if limited) and the complexity of the underlying index contributes to the overall classification as complex under MiFID II.",
    "confidence": 85
}