{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None",
    "classification": "non-complex",
    "supporting_data": "The Invesco BulletShares 2029 USD Corporate Bond UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent, investment-grade corporate bond index. It uses derivatives only for efficient portfolio management (EPM) with minimal impact on risk-return, not as a core strategy. There is no significant leverage, no use of swaps or synthetic replication, and no embedded derivatives or complex features. The structure, risks, and payoff are straightforward and easily understood by retail investors with basic knowledge. All UCITS are automatically non-complex under MiFID II unless they are structured UCITS or use derivatives as a core strategy, which is not the case here[1]. The ETFu2019s risk profile reflects standard market and credit risks, not structural complexity. Securities lending is present but well-managed within UCITS rules and does not dominate the risk profile. The index is transparent and the ETFu2019s documentation is comprehensive and clear. Therefore, the ETF meets all criteria for non-complex classification under MiFID II Article 25(4) and Article 57[1]."
}