{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for risk management, ESG tilted index, no synthetic replication",
    "classification": "non-complex",
    "supporting_data": "The Xtrackers Japan Net Zero Pathway Paris Aligned UCITS ETF is a UCITS-compliant ETF, which generally presumes non-complex classification under MiFID II[1]. The fund aims to replicate a transparent ESG-focused equity index by physical replication, buying all or a substantial number of the underlying securities, which supports non-complex status[search data]. Although the fund may use derivatives for risk management and efficient portfolio management, these are limited and not integral to the investment objective, thus derivatives are not considered as making the product complex under MiFID II criteria[search data]. There is no indication of synthetic replication or embedded derivatives such as swaps or structured products, which would trigger complexity[2]. The fund does not employ significant leverage beyond UCITS limits, nor does it have capital protection features or complex payoff structures. The underlying index is transparent and publicly available, and the ETF's structure and risks (market volatility, tracking error) are straightforward for retail investors with basic knowledge to understand[search data]. Therefore, according to MiFID II Article 25(4)(a)(iv) and Article 57 criteria, this UCITS ETF is classified as non-complex. ESMA guidance confirms that UCITS ETFs using physical replication and limited derivative use for EPM are non-complex unless other complex features are present[2]. No PRIIPs comprehension alert is required for non-complex products. Hence, the classification is non-complex."
}