The definition in the regulation states that (3) “‘multi-speed drive’ means a fan motor that can be operated at three or more fixed speeds plus zero (‘off’).”
Turning the maintenance switch ‘off’ or equivalent is adequate for the ‘off’-mode. Turning off a door switch or a circuit breaker is also adequate.
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.