{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The iShares S&P 500 EUR Hedged UCITS ETF is a UCITS-compliant ETF that aims to replicate the S&P 500 EUR Hedged index by physically holding the underlying equity securities in similar proportions to the index. It uses FX forward contracts solely for currency hedging purposes, which is a form of efficient portfolio management (EPM) and does not constitute derivatives integral to the investment objective. The ETF may engage in short-term securities lending, but this is well-managed under UCITS rules and does not dominate the risk profile. There is no indication of leverage beyond UCITS limits, embedded derivatives, or complex structured products such as CLOs. The replication method is physical, transparent, and straightforward. The risks disclosed relate mainly to market volatility, counterparty risk from FX forwards, and securities lending, all of which are standard and understandable for retail investors with basic knowledge. The ETF's structure, investment policy, and risk profile align with MiFID II Article 25(4)(a)(iv) and Article 57 criteria for non-complex instruments. Therefore, it does not require an appropriateness assessment for non-advised sales and is classified as non-complex under MiFID II. This assessment is consistent with ESMA guidance and CESR technical advice, which consider UCITS ETFs physically replicating transparent indices and using derivatives only for EPM as non-complex. The absence of synthetic replication, embedded derivatives, or leverage confirms this classification."
}