{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "None identified in the KID",
    "classification": "non-complex",
    "supporting_data": "The ETF is a UCITS-compliant fund authorized in Ireland and regulated by the Central Bank of Ireland. It seeks to replicate the performance of the Indxx Blockchain Index by holding the underlying equity securities in similar proportions, using physical replication. The KID explicitly states that the fund may invest in depository receipts if direct investment is not possible, but there is no mention of derivatives, swaps, leverage, or complex structured products. The fund may invest to a much lesser extent in money market instruments, short-term instruments, and other eligible funds, but these are not central to the strategy and do not introduce complexity. The risk profile is high due to the volatility of blockchain-related equities, but this reflects market risk, not structural complexity. The structure, objective, and risks are described in plain language and are straightforward for a retail investor with basic knowledge to understand. There is no evidence of embedded derivatives, contingent convertible bonds, complex indices, or other features that would trigger a complex classification under MiFID II Article 57. The fund is passively managed and does not use synthetic replication or derivatives integral to the investment objective. Therefore, it meets the UCITS presumption of non-complexity and does not exhibit any of the features that would override this presumption under MiFID II rules."
}