SB 4-D: what Florida boards actually need to do, in plain English
The 2022 condo safety law produced more compliance noise than action. Here's the short list of what your board has to do this year, what 'completed' looks like, and where the deadlines actually bite.
The post-Surfside reform in Florida, Senate Bill 4-D, signed into law in 2022 and then layered with SB 154 (2023) and HB 1021 (2024), landed on every condominium board's desk as a giant pile of compliance. Most of the panic-tier reading you'll find online is two years out of date. Here's what's actually live, what the deadlines mean, and what "done" looks like on each one.
The two new things you must complete
1. Milestone Inspection. Required for any condo three stories or higher. Phase 1 is a visual inspection by a Florida-licensed engineer or architect. If they identify substantial structural deterioration, Phase 2 follows: destructive testing as needed.
The trigger: 30 years from the initial certificate of occupancy, or 25 years if the building is within 3 miles of a coastline. Re-inspect every 10 years thereafter.
What "done" looks like: a signed Phase 1 report on file with the local building official AND distributed to every owner. If Phase 2 is required, the engineer specifies what work is needed. That work has to happen on the timeline the engineer sets, not later.
2. Structural Integrity Reserve Study (SIRS). Required for condos and cooperatives three stories or higher. A licensed engineer or reserve specialist studies the major structural components (roof, load-bearing walls, foundation, fireproofing, plumbing, waterproofing, windows, electrical) and tells you what they'll cost to replace and on what schedule.
The output is a funding plan. You can't waive funding the SIRS items. That loophole closed.
What "done" looks like: a SIRS report on file with the association AND a budget that fully funds the reserve items it identifies, no waiver, no reduction.
What changed recently
A few things from the original SB 4-D that didn't survive intact:
- The "no waiver" rule got refined. The original 2022 law banned waivers across the board. SB 154 (2023) clarified that buildings under three stories are not subject to SIRS, period. So small-condo boards aren't on the hook.
- The deadline got extended. Originally Dec 31, 2024 for the SIRS. HB 1021 pushed it to Dec 31, 2025 for buildings whose milestone inspection requires Phase 2 work. They get an extra year because the SIRS depends on the engineer's findings.
- Local building officials got more enforcement teeth. A board that ignores a milestone inspection requirement now faces direct enforcement, including potential evacuation orders. This is not a paper compliance regime anymore.
What this means for your association
If you're a Florida condo board three stories or higher, you should already have completed both the milestone inspection and the SIRS, or have a contracted engineer with a delivery date.
If you don't have either: the gap isn't a paperwork problem, it's an exposure problem. Your D&O insurance carrier will ask. Your owners can sue. The local building official can act.
If you do have both: the next thing is making sure your reserve funding plan is actually executing: money in the reserve account, not promises in a budget document.
Where to go from here
This is the kind of operational reality that the Common Elements RFP Hub was built for. When the SIRS says "your roof has eight years left and will cost $2.4M to replace," you don't want to find a roofer through the manager's brother-in-law. You want three qualified bids on apples-to-apples terms.
Post your milestone or SIRS-driven RFP in the RFP Hub, or talk through the practical end of compliance with other Florida boards in Board Discussions.
This is general informational content, not legal advice. For your specific association, talk to your community association attorney and your structural engineer.
About the author
Common Elements Team· Common Elements
The team building a community and procurement platform for community associations. Boards, managers, vendors, and counsel in one workspace.
More from the blog
- Guide
The vendor vetting checklist boards actually need
Most board-vendor disasters trace back to four things that should've been checked in week one. Here's the short list (license, insurance, references, and scope clarity) and how to verify each in under an hour.
- Product
Why we built Common Elements
After twelve years inside this industry, the same gaps keep showing up: boards making vendor decisions on word of mouth, RFPs running in email chains, attorneys and managers finding each other through luck. We built the platform the industry never got around to building for itself.
- Guide
SIRS reserve funding without the panic
Your engineer just handed you a structural integrity reserve study with a $4.2M number on it. Here's how to translate that into a funding plan that doesn't blow up special assessments, and what your options actually are.
Join the industry expo
Compare notes with boards and managers in the Common Area forum. Free account.