Fundamental Alteration
An EAA exemption where meeting an accessibility requirement would require a fundamental alteration of the product or service — changing its basic nature. Narrower than disproportionate burden. Same documentation duty applies.
An exemption for when meeting a rule would change what the product fundamentally is — narrow, and you still have to document it.
Article 14(1)(a) of the EAA. Like disproportionate burden, fundamental alteration must be documented, retained, and disclosed to the market surveillance authority on request. Where the exemption applies, only the specific requirements that would cause the fundamental alteration are exempt — the rest of the directive still applies.
Why this matters
Operators sometimes confuse 'we'd have to redesign' with 'fundamental alteration.' Redesigning is normal compliance work. Fundamental alteration means the resulting service would no longer be the same service. The bar is high and the documentation requirement is identical to disproportionate burden.