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Reserve studies

Florida HOA reserve study requirements after 2024 reform

What the 2022 SB 4-D reforms and 2024 follow-on legislation actually require from condo and HOA boards on reserves, SIRS, and milestone inspections — and how to avoid the most common compliance mistakes.

Published 5/13/2026

Florida HOA reserve study requirements after 2024 reform

If you sit on a Florida community-association board and you have not personally read the post-Surfside reserve-study rules at least once, do that this week. The 2022 SB 4-D bill rewrote the way Florida condominium associations plan for capital expense, the 2023 SB 154 amendment narrowed and clarified pieces of it, and the 2024 follow-on legislation closed several remaining gaps. Mobile-home parks and pure HOAs (Chapter 720) operate under different rules and are mostly unaffected, but the reform changed the financial planning regime for every Florida condominium of three or more habitable stories.

The core requirement: SIRS

Every Florida condominium of three or more stories must obtain a Structural Integrity Reserve Study (SIRS) and update it at least every ten years. The first deadline was December 31, 2024. The SIRS is performed by a licensed engineer or architect (or in some cases a person designated by the engineer) and must address, at minimum, the following components: roof, load-bearing walls or other primary structural systems, floor, foundation, fireproofing and fire protection systems, plumbing, electrical systems, waterproofing and exterior painting, windows and exterior doors, and any other item with a deferred maintenance expense or replacement cost over $10,000 that, if not addressed, would negatively affect the items listed.

For each component the SIRS must identify the remaining useful life, the estimated replacement cost or deferred maintenance expense, and the recommended annual reserve contribution to fund that replacement on time.

The funding requirement: no more waiver

Before SB 4-D, Florida condo associations could vote to waive or reduce reserve contributions every year. That ability is gone for SIRS components. Starting with the budget year that began on or after January 1, 2025, the association must collect reserves for every SIRS-identified item in the amount the SIRS recommends. Member vote cannot waive it. Board vote cannot waive it.

For non-SIRS reserve items (paint, paving, pool resurfacing — items below the SIRS threshold) the older Chapter 718 reserve regime still applies, and members can still vote to waive or reduce by a majority of those voting at a duly noticed meeting.

The milestone inspection overlay

In parallel with the SIRS regime, Florida law now requires a milestone inspection of any condominium or cooperative building three stories or taller, performed at 30 years of age (25 years if within three miles of the coast) and every ten years thereafter. The milestone inspection is a separate engineering exercise from the SIRS and addresses life-safety questions (is the building structurally sound right now?) rather than capital-budget questions (when will the roof need replacement?).

Boards regularly confuse the two. The SIRS is forward-looking and budget-focused. The milestone inspection is backward-looking and safety-focused. You need both, on different timelines, performed by different engineering specializations.

The Phase 1 / Phase 2 milestone inspection

A milestone inspection is performed in two phases. Phase 1 is visual and engineering-judgment-based. If the Phase 1 engineer finds no signs of substantial structural deterioration, the inspection is complete. If the engineer identifies signs of substantial structural deterioration, Phase 2 begins — destructive or non-destructive testing as needed to characterize the deterioration, followed by a structural-repair plan.

A Phase 2 milestone inspection can be expensive and disruptive. Plan for it.

Common compliance mistakes

Mistake 1: treating SIRS as optional in 2025. Several boards I have spoken with this winter still believe a member vote can waive SIRS funding. It cannot. The waiver provision applies only to non-SIRS reserves. Boards that fail to fund SIRS in 2025 are creating a personal-liability problem under 718.111(1)(d).

Mistake 2: scheduling SIRS and milestone inspections from the same vendor without separation. The two are different engagements. Bundling them with the same engineering firm can be fine, but the deliverables should be separate documents with separate fees. A blended deliverable raises insurance and audit questions later.

Mistake 3: ignoring the $10,000 threshold. The SIRS captures any deferred-maintenance or replacement item over $10,000 — not just the named structural items. Boards that focus narrowly on roofs and load-bearing walls and ignore the catch-all are setting up for an updated SIRS in 2034 that adds a long list of previously-uncovered items.

Mistake 4: budgeting the SIRS contribution at year five instead of year one. The funding obligation begins with the budget cycle that starts on or after January 1, 2025. Phasing in over multiple years is not authorized in the statute.

Mistake 5: skipping the formal member presentation. The SIRS results must be presented to the members. A board that quietly adopts the SIRS funding without a formal member presentation invites a 720.303-style records inspection lawsuit.

Practical board checklist for 2026

  1. Confirm your SIRS was completed and filed with the Department of Business and Professional Regulation by the deadline.
  2. Verify the 2026 budget includes the full SIRS contribution.
  3. Calendar the next milestone inspection date.
  4. Review the SIRS update cycle — every 10 years, not "when we get to it."
  5. Document, in writing, that the board has reviewed the SIRS and the milestone inspection in the current year. A two-line resolution in the minutes covers it.

Going beyond compliance

The reform is the floor, not the ceiling. Boards that limit themselves to bare-statutory compliance are missing the larger opportunity: a real reserve-funding program lets the association avoid special assessments, hold property values, and finance projects through accumulated capital rather than emergency lending. The Florida Surfside collapse was a structural failure first, but the financial failure that allowed deferred maintenance to compound was the precondition.

Common Elements articles are educational and not legal advice. Consult a licensed Florida attorney before making decisions that affect your association.