{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "synthetic",
    "complex_factors": "Swaps, Counterparty Risk, Synthetic Replication",
    "classification": "complex",
    "supporting_data": "The ETF is UCITS-compliant and tracks a transparent equity index, which would normally support a non-complex classification. However, the fund explicitly states it may use synthetic replication via swaps to achieve its objective, introducing counterparty risk and making the structure less transparent for retail investors. The KID highlights counterparty risk as a material risk, confirming that the ETF's performance depends on swap agreements with third parties. Under MiFID II Article 57 and ESMA guidance, any UCITS ETF that uses derivatives (such as swaps) as a central part of its strategyu2014especially when this introduces risks not easily understood by retail investorsu2014should be considered complex, regardless of the simplicity of the underlying index. The presence of synthetic replication and the associated counterparty risk are decisive factors in this assessment, overriding the UCITS presumption of non-complexity[1][2]. The ETF does not use leverage beyond UCITS limits, and there is no indication of inverse or contingent convertible features."
}