{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "Use of derivatives for efficient portfolio management with counterparty risk mitigated by collateral; physical replication of MSCI EMU Index; securities lending possible but secondary",
    "classification": "non-complex",
    "supporting_data": "The UBS Core MSCI EMU UCITS ETF is a UCITS-compliant ETF that tracks the MSCI EMU Index primarily through physical replication or direct investments in the index components, with possible limited use of derivatives for efficient portfolio management (EPM) purposes. The derivatives usage is not integral to the investment objective but used to manage practical replication issues or generate efficiencies, with counterparty risk mitigated by a collateral policy. The ETF may engage in securities lending, which introduces some counterparty risk but is managed within UCITS rules and does not dominate the risk profile. There is no indication of significant leverage or embedded derivatives such as structured products or swaps central to the strategy. The risk profile is elevated (risk category 5) due to market volatility inherent in equity investments, not due to structural complexity. The ETF's structure and risks are transparent and understandable to retail investors with basic knowledge, consistent with MiFID II Article 254 and Delegated Regulation EU 2017/565 Article 57 criteria. According to ESMA and CESR guidance, UCITS ETFs using physical replication and limited derivatives for EPM with collateralized counterparty risk are generally classified as non-complex. Therefore, this ETF does not meet the criteria for complexity under MiFID II and does not require a comprehension alert in the PRIIPs KID."
}