{
    "ucits": true,
    "type": "ETF",
    "leverage": false,
    "derivatives": false,
    "swaps": false,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": "",
    "classification": "non-complex",
    "supporting_data": "The asset is a UCITS ETF (Xtrackers MSCI Japan UCITS ETF) which is passively managed to replicate the MSCI Total Return Net Japan Index by physical replication, buying all or a substantial number of the securities in the index. The fund uses derivatives only for efficient portfolio management (EPM) purposes such as risk management and cost reduction, not as an inherent part of the investment strategy. Securities lending is employed but is a secondary feature with limited risk impact. There is no significant leverage beyond UCITS limits, no embedded derivatives, and the underlying index is transparent and straightforward. The risk profile is high due to market volatility but this does not imply structural complexity. According to MiFID II Article 25(4)(a)(iv), UCITS funds are automatically non-complex unless they are structured UCITS with complex features, which this fund is not. ESMA and regulatory guidance confirm that physical replication UCITS ETFs with limited derivative use for EPM are non-complex. Therefore, this ETF meets all criteria for non-complex classification under MiFID II Article 57 and related guidelines."
}