{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The Amundi Euro Government Bond 10-15Y UCITS ETF Acc is a UCITS-compliant ETF that tracks the Bloomberg Barclays Euro Treasury 50bn 10-15 Year Bond Index via physical replication, primarily investing in fixed-rate, investment grade sovereign bonds denominated in euros with maturities between 10 and 15 years. The ETF may use securities lending as a secondary technique, which under UCITS rules is collateralized and does not automatically trigger complexity. There is no indication that the ETF uses derivatives as an inherent part of its investment strategy (derivatives are only mentioned as financial instruments invested in, but the replication is physical and no synthetic replication or embedded derivatives are described). The ETF does not employ leverage beyond UCITS limits, nor does it embed complex features such as contingent convertible bonds or structured products. The risk profile reflects market risk typical of long-term government bonds, not structural complexity. The ETF's structure, replication method, and risk profile are transparent and understandable to retail investors with basic knowledge. According to MiFID II Article 25(4)(a)(iv) and Article 57 criteria, UCITS ETFs using physical replication and not embedding derivatives or complex features are automatically non-complex. ESMA and CESR guidance confirm that physical replication UCITS ETFs without embedded derivatives or leverage are non-complex. Therefore, this ETF is classified as non-complex under MiFID II. This classification aligns with Janus Henderson's statement that all UCITS funds are automatically non-complex, and with ESMA's supervisory briefing emphasizing that UCITS ETFs with physical replication and no complex derivative use are non-complex. No PRIIPs comprehension alert is required."
}