Florida Law · Building Safety · Updated for HB 913 (2025)
Florida Condo Milestone Inspection Requirements: Compliance Guide
The structural-safety inspection mandate Florida built into the law after Surfside. A board-level walkthrough of who must inspect, when, by whom, and what happens when the inspection finds something.
The Bottom Line
Florida’s milestone inspection program at § 553.899 requires condominium and cooperative associations responsible for buildings three or more habitable stories to commission a structural inspection by a licensed engineer or architect when the building reaches a defined age — 25 years for coastal buildings (within three miles of a coastline) and 30 years for inland buildings (or 25 years if local enforcement requires) — with subsequent inspections every 10 years. The inspection proceeds in two phases: a Phase 1 visual inspection and, if that flags substantial structural deterioration, a Phase 2 substantive evaluation. The findings must be reported to the local building official and shared with owners. HB 913 (2025) clarified the “habitable stories” threshold and tightened the interaction between milestone inspections and reserve funding. This is one half of a two-part mandate — the SIRS framework is the other half — and the two are timed to inform each other.
Operational Context: A Building-Safety Regime Born of Tragedy
Champlain Towers South in Surfside collapsed on June 24, 2021, killing 98 people. Subsequent investigations identified delayed structural maintenance, a deferred 40-year recertification, and chronic underfunding of reserve obligations as contributing factors. In 2022, the Florida legislature responded with SB 4-D, creating two parallel mandates: a recurring structural inspection program (the milestone inspection at § 553.899) and a financial mandate (the SIRS at § 718.112(2)(g)) to ensure the money exists when the inspection identifies necessary work. Refinements followed in SB 154 (2023) and HB 913 (2025). The two mandates together replaced what had been a patchwork of city- and county-specific recertification programs (most prominently the Miami-Dade and Broward County 40-year recertification programs) with a statewide framework.
For boards, the milestone inspection is no longer optional, no longer county-specific, and no longer a slow-moving issue. Compliance deadlines have already passed for many qualifying buildings; tens of thousands of inspections have been completed across Florida; and DBPR and local building officials are actively enforcing.
Who Must Comply
The milestone inspection requirement applies to:
- Condominium associations governed by Chapter 718 that are responsible for the maintenance of a building’s structural integrity, and
- Cooperative associations governed by Chapter 719 with the same structural responsibility,
where the building is three or more habitable stories in height. HB 913 (2025) confirmed that floors used exclusively for parking, storage, or mechanical equipment do not count toward the habitable-stories threshold. A 4-story building with one ground-floor parking deck and three habitable floors above is on the threshold — boards should obtain written confirmation from counsel or an engineer rather than rely on intuition.
The requirement does not apply to:
- Single-family, two-family, three-family, or four-family dwellings with three or fewer habitable stories above ground.
- Buildings not within the scope of Chapter 718 or 719 (most HOAs governed solely by Chapter 720, for example).
- Buildings where the association is not responsible for the structural maintenance.
When the Inspection Is Due
The age trigger is set against the date the certificate of occupancy was issued:
| Location | First Milestone Inspection Due | Recurrence |
|---|---|---|
| Within 3 miles of a coastline | By December 31 of the year the building reaches age 25 | Every 10 years thereafter |
| More than 3 miles inland (default) | By December 31 of the year the building reaches age 30 | Every 10 years thereafter |
| More than 3 miles inland (local override) | By December 31 of the year the building reaches age 25, if local enforcement agency requires based on local conditions | Every 10 years thereafter |
For buildings that had already reached or passed the trigger age when the statute took effect, the 2022 framework imposed initial-compliance deadlines that have since elapsed for most qualifying buildings. Associations that have not yet complied with an overdue deadline should engage counsel and an engineer immediately. Local building officials may issue unsafe-structure orders for buildings that remain non-compliant.
The Two-Phase Inspection
Phase 1: Visual Inspection
A licensed Florida engineer or architect performs a visual inspection of the building’s structural condition. The inspection covers the primary structural elements: foundation, load-bearing walls, columns, beams, slabs, the building envelope, and other components that affect the structural integrity of the building. The inspector documents the findings and submits a written report.
If the Phase 1 inspection identifies substantial structural deterioration, the report triggers a Phase 2 inspection. If it does not, the report concludes the inspection cycle, and the building must be re-inspected at the next 10-year recurrence.
Phase 2: Substantive Inspection (Triggered)
The Phase 2 inspection is more invasive and substantive than Phase 1. It may involve destructive testing, material sampling, engineering calculations, and recommendations for repair or remediation. The Phase 2 inspector must be a licensed engineer or architect with appropriate qualifications. The output is a Phase 2 report that identifies the structural deficiencies, the recommended scope of remediation, and (where applicable) interim safety measures the association must implement.
Reporting and Owner Disclosure
The completed inspection (Phase 1 and, if applicable, Phase 2) must be:
- Submitted to the local building official in the jurisdiction where the building is located.
- Maintained in the association’s official records under § 718.111(12) (for condominiums) and the analogous Chapter 719 provisions (for cooperatives).
- Provided to unit owners and, in many cases, posted on the association’s website or mobile application (particularly for associations with 150+ units, and increasingly for smaller associations under HB 913).
Phase 2 reports that identify substantial structural deterioration may trigger additional disclosure obligations — including reporting to prospective buyers and lenders — and may require interim life-safety measures or occupancy restrictions imposed by the local building official.
How the Milestone Inspection Interacts with SIRS
The milestone inspection and the SIRS are complementary mandates:
| Element | Milestone Inspection (§ 553.899) | SIRS (§ 718.112(2)(g)) |
|---|---|---|
| Primary purpose | Determine current structural condition; identify deficiencies. | Plan and fund the next decade of structural reserve obligations. |
| Frequency | Initial at 25 or 30 years; every 10 years thereafter. | Every 10 years, regardless of building age. |
| Output | Phase 1 / Phase 2 inspection report. | Reserve schedule covering eight structural components, with funding plan. |
| Performed by | Licensed engineer or architect. | Licensed engineer, architect, or qualified reserve specialist. |
| Financial implication | May require immediate repair funding (often through special assessment). | Annual reserve contribution required; waivers no longer available for SIRS components. |
Where possible, boards should sequence the engagements so that the milestone-inspection findings (particularly any Phase 2 results) inform the SIRS component scope and funding plan. A coordinated engagement saves engineering cost and produces a more accurate reserve plan.
What HB 913 (2025) Changed
HB 913 (signed June 23, 2025; effective July 1, 2025) refined the milestone inspection framework in several material ways:
- Clarified the “habitable stories” standard. Floors used exclusively for parking, storage, or mechanical equipment do not count. This reduced the coverage scope for some buildings that had been treated as qualifying under the original “three or more stories” reading.
- Narrow reserve relief tied to milestone repairs. Unit-owner-controlled associations that completed a milestone inspection in the previous two years may, by majority vote of all voting interests, pause or reduce structural reserve contributions for no more than two consecutive annual budgets in order to fund milestone-recommended repairs — only for budgets adopted on or before December 31, 2028.
- Strengthened transparency. Expanded online posting and electronic-delivery obligations make inspection results more visible to owners and prospective buyers.
- Reaffirmed insurance and reserve coordination. Property insurance obligations apply regardless of governing-document provisions, and the elimination of waivers for SIRS-mandated structural reserves removes the historical pressure point that delayed milestone-recommended repairs.
Why This Matters
This is life-safety legislation. The milestone inspection exists because a building collapsed and people died. Boards that treat the inspection as a paperwork exercise are missing the legislative intent and exposing themselves to fiduciary claims that will not be defended by “we didn’t want to alarm anyone.”
Non-compliance has visible consequences. Local building officials can issue unsafe-structure orders, condition occupancy on inspection compliance, and require evacuation in severe cases. DBPR can pursue administrative enforcement. Lenders are increasingly conditioning loans on milestone-inspection compliance and Phase 2 status.
Phase 2 findings trigger fast-moving obligations. Substantial structural deterioration is not a problem the board can study for two years. The Phase 2 report typically requires repair scoping, contractor selection, financing decisions (special assessment vs. loan vs. reserve drawdown), and often interim safety measures — all on a compressed timeline.
The market is pricing this in. Resale conditions, insurance availability, and prospective-buyer questionnaires now routinely ask about milestone-inspection status. Buildings with current Phase 1 reports and (where applicable) actively remediated Phase 2 issues sell better than buildings with stale or open inspection records.
Best-Practice Guidance
1. Confirm coverage and timing in writing.
Get a written assessment from counsel or an engineer on (a) whether the building meets the habitable-stories test under the current HB 913 standard and (b) the precise date the next inspection is due based on the certificate of occupancy.
2. Engage an experienced licensed professional.
Use a Florida-licensed engineer or architect with documented milestone-inspection experience. Ask for sample Phase 1 reports, recent client references, and the firm’s Phase 2 protocol.
3. Coordinate with the SIRS engagement.
Time the milestone inspection so its findings can inform the SIRS scope. If both engagements are due in close proximity, engage providers (or a single firm) that can deliver an integrated work product.
4. Plan the financing before the report lands.
Develop financing scenarios in advance: reserve drawdown, special assessment, association loan, or hybrid. The board that already has a financing strategy on the shelf can act decisively if Phase 2 surfaces a material finding.
5. Communicate proactively with owners.
The inspection is a fact, not a scandal. Boards that explain the statutory framework, the timeline, and the financial implications in advance avoid the rumor mill and reduce the political cost of any subsequent assessment.
6. Build a complete records file.
The compliance file should include the engagement letter, the inspector’s license verification, the Phase 1 report, any Phase 2 report, the building-official submission confirmation, the owner-disclosure record, the website posting screenshot, and minutes of every related board action.
7. Calendar the next cycle on the day the current inspection is delivered.
Ten years passes faster than expected. Calendaring the next inspection (and the next SIRS update) immediately after the current cycle closes prevents the slow drift that produces overdue inspections.
Common Mistakes & Pitfalls
Actionable Takeaways
- Confirm the building’s habitable-stories status under the current statute, in writing.
- Identify the certificate-of-occupancy date and the resulting first-inspection deadline.
- If the deadline has passed and no compliant inspection has been performed, engage counsel and a qualified engineer immediately.
- If the inspection is upcoming, scope a coordinated milestone + SIRS engagement.
- Develop financing scenarios for potential Phase 2 remediation in advance of the report.
- Build an owner-communication plan that explains the statutory framework and the timeline.
- Submit the completed inspection to the local building official and post per association-size disclosure rules.
- Open the compliance file and calendar the next 10-year cycle immediately after the current inspection closes.
Related CIC-SC Resources
- Florida SIRS — Structural Integrity Reserve Study Compliance Timeline
- Florida Chapter 718 — Condominium Act Overview for Board Members
- Florida Chapter 718 — 2025 Legislative Amendments Summary (HB 913)
- Reserve Funding Methods — Fully Funded, Threshold, and Percent Funded
- Operating Fund vs. Reserve Fund — The Critical Distinction
- Capital Project Planning and Approval Guide
- Understanding HOA Assessment Authority — Who Can Raise Dues and By How Much?
The CIC-SC Florida Insights series provides engagement-letter templates, owner-communication scripts, Phase 2 response protocols, and integrated milestone + SIRS planning checklists. Become a CIC-SC member to access the full library.
References & Sources
- Common Interest Community Standards Council, Fundamentals of Association Management — chapter on Structural Safety and Florida-Specific Compliance.
- Florida Statutes § 553.899 — Mandatory milestone inspection program.
- Florida Statutes § 718.112(2)(g) — Structural Integrity Reserve Study requirements.
- Florida Statutes § 718.111(12) — Official records access (relevant to inspection-report disclosure).
- Florida Statutes § 719.106 — Cooperative association provisions analogous to milestone-inspection and SIRS requirements.
- Florida SB 4-D (2022) — Original legislation creating the milestone inspection program and SIRS framework.
- Florida SB 154 (2023) — Refinements to milestone inspection scope and timelines.
- Florida HB 913 (2025) — “Condo Law 3.0”; signed June 23, 2025; effective July 1, 2025.
- Florida Department of Business and Professional Regulation (DBPR), Division of Florida Condominiums, Timeshares, and Mobile Homes — milestone inspection FAQ and published guidance.
- Florida Building Code and local building-official enforcement procedures — for unsafe-structure orders and substantive inspection requirements.
CICSC publishes this article for educational and informational purposes only. It is not legal, tax, accounting, engineering, insurance, or financial advice and does not establish an attorney-client relationship. Statutory references and operational frameworks are intended to support informed governance, not to substitute for advice from qualified legal counsel and other professional advisors familiar with your jurisdiction and your association's facts. CICSC, its authors, and its members assume no liability for actions taken in reliance on this content.