{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Invesco MSCI Emerging Markets ESG Climate Paris Aligned UCITS ETF is a UCITS-compliant ETF that aims to physically replicate the MSCI Emerging Markets ESG Climate Paris Aligned Benchmark Select Index by holding the underlying securities in their respective weightings. The ETF uses derivatives only for risk management purposes, such as hedging currency risk or efficient portfolio management, but not as an integral part of its investment strategy. There is no indication of synthetic replication or embedded derivatives. The ETF does engage in securities lending, but this is a secondary feature with collateral management consistent with UCITS rules, which does not automatically render the ETF complex. There is no significant leverage beyond UCITS limits. The underlying index is transparent, based on a well-documented MSCI index with ESG and climate alignment criteria, and the ETF's structure and risks (market volatility, tracking error) are straightforward and understandable by retail investors with basic knowledge. According to MiFID II Article 25(4)(a)(iv) and Article 57 of the Commission Delegated Regulation, UCITS ETFs that physically replicate transparent indices and use derivatives only for efficient portfolio management with minimal risk impact are classified as non-complex. ESMA guidance and regulatory practice confirm that such ETFs do not require an appropriateness assessment and do not trigger complexity classification. Therefore, this ETF is classified as non-complex under MiFID II."
}