{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Amundi BEL 20 UCITS ETF is a UCITS-compliant ETF that aims to replicate the EUR-denominated BEL 20 Net Return Index through direct physical replication, mainly investing in the underlying securities of the index. The ETF may use sampling and guaranteed temporary sales of securities for optimization, but there is no indication that derivatives are used as an inherent part of the investment strategy or that synthetic replication is employed. The ETF does not use leverage beyond UCITS limits, nor does it embed derivatives or structured products such as CLOs. The risk profile reflects market volatility typical of equity investments, without structural complexity. Counterparty risk is limited and managed within UCITS rules, and securities lending, if any, is a secondary feature and well collateralized. The underlying index is transparent and publicly documented. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Commission Delegated Regulation, UCITS ETFs using physical replication and not embedding derivatives or complex structures are automatically classified as non-complex. This ETF meets all criteria for non-complex classification: it does not embed derivatives, does not use synthetic replication, does not employ significant leverage, and its structure and risks are straightforward and understandable by retail investors with basic knowledge. Therefore, no appropriateness assessment is required for execution-only sales, and no comprehension alert is mandated in the PRIIPs KID. This assessment aligns with ESMA and CESR guidance that physical replication UCITS ETFs tracking transparent indices are non-complex, while synthetic or structured UCITS ETFs with embedded derivatives or complex features would be complex. The ETF's use of derivatives, if any, is limited to efficient portfolio management with negligible impact on risk-return, which does not trigger complexity under MiFID II. Hence, the classification is non-complex."
}