{
    "ucits": true,
    "type": "ETF",
    "replication_method": "physical",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "complex_factors": "Derivative use for efficient portfolio management, including swaps, futures, options, and currency forwards. No significant leverage, no embedded derivatives, no complex indices, no contingent convertible bonds.",
    "classification": "non-complex",
    "supporting_data": "The VanEck Morningstar US Wide Moat UCITS ETF is a UCITS-compliant ETF that primarily uses physical replication to track its benchmark index by holding the underlying equity securities. While the fund may use derivatives such as swaps, futures, options, and currency forwards for efficient portfolio management (EPM)u2014including situations where full replication is not practical or cost-efficientu2014these derivatives are not central to the fund's investment objective and are used only to manage inflows/outflows, hedge currency risk, or reduce transaction costs. There is no indication of significant leverage, embedded derivatives, complex indices, or contingent convertible bonds. The fund's structure, risks, and objectives are transparent and typical of a passive equity UCITS ETF. Under MiFID II, all UCITS are automatically non-complex unless they employ complex portfolio management techniques or structured features that make the product difficult for retail investors to understand[1]. ESMA guidance confirms that UCITS using derivatives for EPM, without making them integral to the investment strategy, generally remain non-complex, provided the risks are well-disclosed and the structure remains straightforward[2]. The fund's KIID highlights standard risks such as equity market risk and limited diversification, but does not indicate complex mechanisms or opacity that would override the UCITS presumption of non-complexity. Therefore, despite the potential use of derivatives for EPM, this ETF is classified as non-complex under MiFID II."
}