Florida Law · Reserves & Capital · Updated for HB 913 (2025)

Florida SIRS: Structural Integrity Reserve Study Compliance Timeline

The most consequential legislative change to Florida condominium reserves in a generation. A board-level walkthrough of the SIRS framework, the December 31, 2025 deadline, the eight components every study must cover, and what HB 913 changed in 2025.

By the CIC-SC Editorial Team Updated May 10, 2026 Reading time: ~11 minutes Audience: Florida Condo & Cooperative Boards, Managers, Engineers

The Bottom Line

Florida’s Structural Integrity Reserve Study (SIRS) law — codified principally at § 718.112(2)(g), with the parallel milestone inspection framework at § 553.899 — requires condominium and cooperative associations responsible for buildings three or more habitable stories to commission a specialized reserve study covering eight enumerated structural components. The first SIRS for qualifying buildings must be completed by December 31, 2025, with subsequent studies required every ten years. Any budget adopted on or after December 31, 2025 must use the SIRS as the basis for funding structural reserves — and the historical practice of voting to waive or reduce reserves has been substantially eliminated for SIRS components. HB 913 (signed June 23, 2025; effective July 1, 2025) refined the framework, clarified the “habitable stories” standard, and provided narrow temporary relief tied to the milestone inspection process. This is not optional, and it is not the kind of compliance a board can quietly defer.

Operational Context: The Post-Surfside Legislative Trajectory

The June 24, 2021 partial collapse of Champlain Towers South in Surfside, Florida, killed 98 residents and triggered the most significant overhaul of community-association building safety law in the United States in decades. The Florida legislature’s response unfolded in three waves:

SB 4-D (2022): Established the milestone inspection program at § 553.899 and the SIRS requirement at § 718.112(2)(g). Set the original SIRS deadline at December 31, 2024.
SB 154 (2023) and follow-on legislation (2024): Refined definitions, allocated regulatory authority between local building officials and DBPR, and extended the SIRS compliance deadline to December 31, 2025.
HB 913 (2025) — “Condo Law 3.0”: Signed June 23, 2025; effective July 1, 2025. Confirmed that owners cannot vote to waive or reduce funding for SIRS-mandated structural reserve items starting with the 2025 budget cycle. Revised the milestone inspection scope to apply to buildings three or more habitable stories rather than three or more stories generally. Created a narrow, time-limited mechanism allowing unit-owner-controlled associations that have completed milestone inspections in the previous two years to pause or reduce reserve contributions for no more than two consecutive annual budgets — only by majority vote of all voting interests and only to fund milestone-recommended repairs — for budgets adopted on or before December 31, 2028.

From the Fundamentals of Association Management: The SIRS framework is a paradigm shift. Florida moved from a regime in which reserves were largely a matter of board discretion and owner vote to a regime in which structural reserves are statutorily mandated, professionally scoped, and substantively unwaivable. Boards still in “old framework” thinking are operating on assumptions that no longer hold.

Who Must Comply

The SIRS requirement at § 718.112(2)(g) applies to associations that operate condominium buildings, and the analogous provisions at § 719.106(1)(k) apply to cooperative associations, where:

The building is three or more habitable stories in height; and
The association is responsible for the maintenance of the structural elements of the building.

HB 913 (2025) clarified the “habitable stories” standard. Floors used exclusively for parking, storage, or mechanical equipment do not count toward the threshold. A 4-story structure consisting of one parking level and three habitable levels above is therefore on the cusp; boards should obtain written engineering or legal confirmation rather than relying on visual story-count.

Buildings not covered by SIRS — small townhome condominiums, garden-style two-story buildings, single-family attached communities — still benefit from a non-statutory reserve study and remain subject to general reserve provisions of Chapter 718 and Chapter 719, but the specific SIRS framework does not apply.

The Eight SIRS Components

The SIRS must include a visual inspection by a qualified professional and a recommended reserve schedule for the following eight structural component categories, plus any other item with a deferred maintenance expense or replacement cost greater than $25,000 that affects those components:

Roof
Load-bearing walls or other primary structural members
Floor
Foundation
Fireproofing and fire-protection systems
Plumbing
Electrical systems
Waterproofing and exterior painting

HB 913 (2025) further refined that windows and exterior doors are considered structural components for SIRS purposes in many circumstances. Boards should confirm the precise scope of their study with the engineering firm or licensed professional preparing it.

Who Can Perform a SIRS

The visual inspection portion of the SIRS must be performed by a licensed engineer or licensed architect, or by a person certified as a reserve specialist or professional reserve analyst. Practically, most SIRS engagements are led by licensed engineering firms that combine the visual inspection with the financial reserve modeling, often in cooperation with a reserve study specialist. Boards should engage providers with documented Florida experience and explicit familiarity with the SIRS statutory standard — not every reserve study firm is structured to deliver a SIRS.

The Funding Side: What “Mandatory” Means

Once a SIRS is in place, the funding requirement is what changes the financial picture most.

For budgets adopted on or after December 31, 2025, the SIRS is the required basis for funding structural reserve items.
Owners may no longer vote to waive or reduce the funding necessary for SIRS-mandated structural reserve items in qualifying buildings. The pre-2022 practice of voting to fund reserves at less than 100% — or to waive them entirely — is not available for these components.
HB 913 (2025) carved out a narrow exception: 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, only to fund milestone-recommended repairs, and only for budgets adopted on or before December 31, 2028. This is a relief mechanism for communities actively funding milestone repairs — not a return to the old waiver regime.
Reserve funds restricted by the SIRS may not be used for non-SIRS purposes without specific authorization (and, in some cases, member vote).

How SIRS Interacts with the Milestone Inspection Program

SIRS is one half of a two-part safety framework. The other half is the milestone inspection requirement at § 553.899.

Element	SIRS (§ 718.112(2)(g))	Milestone Inspection (§ 553.899)
Purpose	Identify reserve needs for eight structural component categories; set the funding basis.	Determine general structural condition and life-safety status of the building.
Frequency	Every 10 years (or sooner if conditions warrant).	First inspection at 25 or 30 years (depending on coastal proximity and local enforcement decisions), every 10 years thereafter.
Trigger	Building three or more habitable stories; association responsible for structure.	Building three or more habitable stories (post-HB 913 standard); applies to condominium and cooperative buildings.
Performed by	Licensed engineer, licensed architect, or qualified reserve professional.	Licensed engineer or licensed architect (Phase 1 visual; Phase 2 substantive if needed).
Output	Reserve schedule and funding plan for SIRS components.	Inspection report on structural integrity; may recommend repairs or further inspection.
Reporting	Findings disclosed to owners; SIRS itself is part of association records.	Inspection summary filed with local building official; substantive inspection results may be required to be reported to DBPR.

The two programs are complementary and timing-dependent. A milestone inspection that identifies structural deficiencies typically triggers immediate repair planning; the SIRS provides the multi-decade funding plan that ensures the next major repair cycle is paid for in advance. Many communities now stagger the engagements so that the milestone inspection informs the SIRS scope, particularly for components flagged for accelerated replacement.

Compliance Timeline at a Glance

Milestone	Deadline	What It Means
First SIRS for qualifying buildings	December 31, 2025	Mandatory; applies to existing buildings three or more habitable stories with the association responsible for structure.
SIRS-based budget funding	Budgets adopted on or after December 31, 2025	Structural reserves must be funded based on the SIRS schedule; owner waivers eliminated for SIRS components.
Milestone inspection (coastal, within 3 miles)	By December 31 of the year the building reaches age 25	Phase 1 visual inspection by licensed engineer or architect, every 10 years thereafter.
Milestone inspection (non-coastal)	By December 31 of the year the building reaches age 30 (or age 25 if locally required)	Same Phase 1/Phase 2 framework, every 10 years thereafter.
HB 913 narrow relief window	Budgets adopted on or before December 31, 2028	Available only to associations that have completed a milestone inspection in the previous two years; requires majority vote of all voting interests; maximum two consecutive annual budgets.
Recurring SIRS	Every 10 years from prior SIRS	Required regardless of building age; not optional after first compliance.

Why This Matters

The financial impact is substantial. Communities that previously funded reserves at 30–50% of the fully funded balance are facing the gap between their existing balances and SIRS-required funding levels, often in a single budget cycle. Estimated SIRS-driven assessment increases of 50–200% — or one-time special assessments running into five- and six-figure territory per unit — have been reported across Florida coastal markets. Boards that have not modeled this carefully may be surprised at the magnitude.

The penalty for non-compliance is meaningful. Failure to perform a required SIRS or milestone inspection is a violation of the duties of care and loyalty by board members and exposes the association to enforcement action by DBPR, owner litigation, and downstream insurance and lending consequences. Some local jurisdictions can issue unsafe-structure orders that condition continued occupancy on inspection compliance.

The market is responding. Lenders, insurers, and prospective buyers are routinely requesting SIRS reports and milestone inspection findings as part of due diligence. Communities with current SIRS in place and a credible funding plan are seeing better insurance market access and stronger resale conditions than communities with stale reserve studies or open milestone-inspection findings.

Litigation has begun. Owners challenging SIRS-related assessment increases — and former boards being sued for the under-funding patterns that produced the gap — are already producing reported decisions. Board minute books, communication records, and engagement letters with engineering firms are now litigation exhibits. Document discipline matters.

Best-Practice Guidance

1. Confirm coverage status in writing.

For any building near the three-habitable-stories threshold, obtain written confirmation from association counsel or the engineering firm about whether SIRS applies. Do not rely on intuition or pre-HB 913 advice. The habitable-stories standard is recent and material.

2. Engage a SIRS provider with Florida-specific credentials.

Ask for a sample SIRS report, the engineer’s Florida license number, recent Florida engagements, and the firm’s methodology for the eight components. Beware of generic reserve study firms branding their standard product as a SIRS without statutory tailoring.

3. Coordinate SIRS with the milestone inspection schedule.

Where the building is approaching a milestone inspection deadline, time the engagements so the milestone findings inform the SIRS component schedule. Avoid duplicate engineering scope.

4. Build the funding plan into the next budget — with member communication.

The SIRS will produce a recommended reserve contribution. Build it into the operating budget transparently and communicate the cost drivers in plain language: SIRS requirement, eight covered components, ten-year horizon, statutory funding mandate. Surprise increases are the single largest source of post-SIRS litigation risk.

5. Use the HB 913 relief only when it actually fits.

The two-year pause is available only to communities that have completed a milestone inspection in the previous two years and are using the relief to fund milestone-recommended repairs. Boards should not use it as a general affordability lever — courts and DBPR will look closely at the predicate.

6. Document the board’s deliberations.

Minutes, communications with the engineer, copies of the SIRS, copies of any milestone reports, and the board resolution adopting the SIRS-based budget should all be filed in a dedicated SIRS compliance file. This is the file the association will produce if challenged.

7. Re-run the analysis when conditions change.

Material adverse findings — concrete spalling in a parking deck, evidence of water intrusion, a roof failure — should trigger interim SIRS updates and possibly a second milestone inspection (Phase 2). Don’t wait for the next 10-year cycle if conditions are deteriorating.

Common Mistakes & Pitfalls

Pitfall 1: Assuming “three stories” equals “three habitable stories.” A common misreading of the original SB 4-D framework. HB 913 (2025) clarified that floors used exclusively for parking, storage, or mechanical equipment do not count. The coverage analysis changed for some borderline buildings.

Pitfall 2: Using a generic reserve study as a SIRS. A standard CAI reserve study and a Florida SIRS are not the same product. The SIRS requires a specific component scope, a specific qualified inspector, and statutory funding implications. Confirm the deliverable explicitly satisfies § 718.112(2)(g).

Pitfall 3: Voting to waive or reduce SIRS reserves. The vote is no longer effective for SIRS components for budgets adopted on or after December 31, 2025. Boards that allow this practice expose directors to fiduciary claims and the association to regulatory action.

Pitfall 4: Treating the HB 913 two-year pause as a budget tool. The relief is narrow, predicate-dependent, and time-limited. Misusing it — particularly without a milestone inspection in the previous two years or without milestone-recommended repairs to fund — can constitute a statutory violation.

Pitfall 5: Failing to communicate the assessment impact. The SIRS funding shift is one of the largest assessment changes most Florida condominium communities have ever experienced. Silence breeds anger. Plain-language communication tied to the statute and to specific cost drivers is the only effective approach.

Pitfall 6: Mixing SIRS-restricted reserves with general reserves. SIRS reserves are restricted for SIRS-component purposes. Boards must maintain accounting separation and may not use SIRS funds for non-SIRS components without proper authorization.

Actionable Takeaways

Confirm in writing whether the association’s buildings are SIRS-qualifying under the habitable-stories standard.
Engage a qualified engineer or architect for the SIRS if one has not already been completed; ensure delivery before December 31, 2025.
Determine the milestone inspection status: deadline year, completion date (if applicable), Phase 2 status (if applicable).
Model the SIRS-based reserve contribution against the current funding pattern; project the assessment impact for the next 3, 5, and 10 years.
Build the SIRS funding into the budget for the first fiscal year beginning on or after December 31, 2025.
Draft owner communications that explain the statutory framework, the eight covered components, the funding mandate, and the expected assessment impact.
Open a dedicated SIRS compliance file; index engagement letters, the SIRS itself, milestone inspection reports, board resolutions, and owner communications.
Calendar the recurring 10-year SIRS and milestone obligations.
If considering the HB 913 two-year pause, confirm with counsel that the statutory predicates are satisfied before any member vote.

Related CIC-SC Resources

Florida Condo Milestone Inspection Requirements — Compliance Guide
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
How to Commission a Reserve Study — What to Ask and What to Expect
Understanding HOA Assessment Authority — Who Can Raise Dues and By How Much?

Don’t let SIRS compliance become a crisis.
CIC-SC’s Florida Insights series gives boards and managers the statutory walkthroughs, engagement-letter templates, and owner-communication scripts that turn SIRS compliance from a flashpoint into a structured, professional process. Become a CIC-SC member to access the full library.

References & Sources

Common Interest Community Standards Council, Fundamentals of Association Management — chapters on Reserve Planning and Florida-Specific Compliance Obligations.
Florida Statutes § 718.112(2)(g) — Structural Integrity Reserve Study requirements for condominium associations.
Florida Statutes § 719.106(1)(k) — Analogous SIRS requirements for cooperative associations.
Florida Statutes § 553.899 — Mandatory milestone inspection program for condominium and cooperative buildings.
Florida SB 4-D (2022) — Original post-Surfside legislative framework establishing milestone inspections and SIRS; codified at §§ 553.899 and 718.112.
Florida SB 154 (2023) — Refinements to milestone inspection scope and SIRS requirements; deadline-related amendments.
Florida HB 913 (2025) — “Condo Law 3.0”; signed June 23, 2025; effective July 1, 2025; clarified habitable-stories standard, confirmed mandatory SIRS funding, created narrow milestone-tied reserve relief window through December 31, 2028.
Florida Department of Business and Professional Regulation (DBPR), Division of Florida Condominiums, Timeshares, and Mobile Homes — published guidance and FAQ on milestone inspections and SIRS.
Office of the Governor of Florida — June 23, 2025 press release on HB 913 signing.
Community Associations Institute (CAI) Florida Legislative Action Committee — analyses of SB 4-D, SB 154, and HB 913.

Tags: SIRS · structural integrity reserve study · milestone inspection · Surfside · HB 913 · SB 4-D · § 718.112(2)(g) · § 553.899 · habitable stories · Florida condominium reserves · current event

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.