{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None identified",
    "classification": "non-complex",
    "supporting_data": "The Invesco S&P 500 CTB Net Zero Pathway ESG UCITS ETF is a UCITS-compliant, physically replicated ETF tracking a transparent, well-documented equity index. It does not use derivatives as a core part of its strategy, does not employ leverage beyond UCITS limits, and does not hold complex bonds, structured products, or other instruments that would introduce counterparty risk, embedded derivatives, or opacity. The ETF may engage in securities lending, but this is a secondary activity, well-managed within UCITS rules, and does not dominate the risk profile. The structure, risks, and investment objective are straightforward and can be understood by retail investors with basic knowledge. No features were identified that would override the UCITS presumption of non-complexity under MiFID II Article 25(4)(a)(iv) and Delegated Regulation Article 57[1][2]. The ETF is not a structured UCITS and does not employ complex portfolio management techniques that would require an appropriateness test[3]."
}