{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for risk management, ESG screening, securities lending",
    "classification": "non-complex",
    "supporting_data": "The Xtrackers MSCI Innovation UCITS ETF is a UCITS-compliant ETF, which under MiFID II is generally presumed non-complex. The fund aims to physically replicate the MSCI ACWI IMI Innovation Select Screened 200 Index by buying a substantial number of the underlying securities, supporting a non-complex classification. The fund may use derivatives only for risk management, cost reduction, and efficient portfolio management, not as an integral part of the investment objective, which aligns with non-complex derivative use under MiFID II. There is no indication of synthetic replication or embedded derivatives such as swaps or structured products. Securities lending is employed but is a secondary feature with well-managed collateral arrangements and does not dominate the risk profile. The fund does not use significant leverage beyond UCITS limits. The index tracked is transparent and well-documented, and the ETF's structure and risks are straightforward for retail investors with basic knowledge to understand. Therefore, despite the presence of some derivatives for EPM and securities lending, the ETF meets the criteria for non-complex instruments under MiFID II Article 25(4)(a)(iv) and Article 57 of the Delegated Regulation. This is consistent with ESMA and CESR guidance that UCITS ETFs using physical replication and limited derivative use for EPM are non-complex. No features such as embedded derivatives, leverage beyond UCITS limits, or complex payoff structures are present to trigger a complex classification."
}