SIRS in Florida: What It Requires, What It Costs, and How Boards Fund the Gap (2026)

Florida's Structural Integrity Reserve Study (SIRS) law requires most condominium and cooperative buildings three habitable stories or higher to study eight structural and building-system components, then fund reserves against what that study finds — and boards can no longer vote to waive that funding. The completion deadline was December 31, 2025, not the December 31, 2026 date widely repeated online. HB 913 (2025) also opened the door to funding the gap with a loan or line of credit instead of a lump-sum special assessment.

This guide walks through what the law actually requires, what a SIRS tends to cost, the deadlines boards keep getting wrong, and the financing mechanics HB 913 put in writing.

What a Structural Integrity Reserve Study Actually Is

A SIRS is a visual inspection of the condominium property, performed under § 718.112(2)(g)2, that produces two things for each covered component: the estimated remaining useful life and the estimated cost to replace it or address deferred maintenance. From those two numbers, the study recommends an annual reserve-funding amount. It is not the same document as a milestone inspection (§ 553.899) — a milestone inspection is a life-safety structural assessment tied to a building's age; a SIRS is a funding-planning document tied to specific components. The two can overlap and, under the right conditions, one inspection can substitute for part of the other (more below).

Who Has to Have One

Residential condominium associations must complete a SIRS, and update it at least every 10 years, for each building three habitable stories or higher — regardless of the building's age or unit count. § 718.112(2)(g)1. There's no exemption for older or smaller buildings the way there is with milestone inspections. Cooperatives face a near-identical requirement under § 719.106.

Exempt: buildings under three habitable stories; single-, two-, three-, or four-family dwellings with three or fewer habitable stories above ground; portions of a building not submitted to condominium ownership; and portions maintained by a party other than the association. § 718.112(2)(g)5.

Not covered at all: Chapter 720 HOAs. This is the point boards and owners most often get wrong. SIRS and milestone inspection requirements apply exclusively to condominiums and cooperatives. Ordinary homeowners' associations — single-family and townhome communities governed by Chapter 720 — have no SIRS mandate under Florida law. Their reserves remain voluntary by default and can still be waived by membership vote. If you serve on an HOA board and someone tells you SIRS applies to your community, that's incorrect.

What the Study Has to Cover

Based on the statutory component list in § 718.112(2)(g)1.a–h, the SIRS must at minimum address:

1. Roof
2. Structure — load-bearing walls and other primary structural members
3. Fireproofing and fire protection systems
4. Plumbing
5. Electrical systems
6. Waterproofing and exterior painting
7. Windows and exterior doors
8. Any other item with deferred-maintenance expense or replacement cost exceeding $25,000 — a threshold HB 913 raised from the original $10,000, and one that's now indexed to CPI going forward

For each item, the study states estimated remaining useful life, estimated replacement or deferred-maintenance cost, and a recommended annual reserve contribution. § 718.112(2)(g)4.a. There's a narrow exception where no reserve is recommended if the life or cost genuinely can't be determined, or if remaining useful life exceeds 25 years.

How We Got Here: The Post-Surfside Legislative Timeline

Florida had no statewide structural inspection mandate before June 2021 — only Miami-Dade and Broward's local 40-year recertification programs. That changed after the June 24, 2021 partial collapse of Champlain Towers South in Surfside, a 12-story oceanfront condominium completed in 1981. In the four legislative sessions since, lawmakers have amended the SIRS and milestone statutes almost every year:

• SB 4-D (2022, effective May 26, 2022): created milestone inspections and mandatory SIRS from scratch, set the original SIRS deadline at December 31, 2024, and ended reserve waivers for budgets adopted on or after that date.
• SB 154 (2023): a "glitch bill" that refined the SIRS component list and tightened the non-SIRS reserve-waiver vote to a majority of all voting interests, not just those who show up to vote.
• HB 1021 (2024): added transparency and records requirements, director education, and criminal penalties for willful records violations; clarified that the 25-year coastal inspection trigger is a local option, not automatic — but provided no deadline or funding relief despite the press attention it got at the time.
• HB 913 (2025, effective July 1, 2025): the actual relief bill — extended the SIRS deadline to December 31, 2025, expressly authorized loans and lines of credit for reserve funding, raised the "other item" cost threshold from $10,000 to $25,000 (now CPI-indexed), and added the 2-year reserve-pause option referenced above.

Two bills that would have changed SIRS obligations further in 2026 — SB 722 and SB 1498 — both died in committee. As of this writing, HB 913 is the current law.

Who Can Perform It

A SIRS must be performed or verified by an engineer licensed under Chapter 471, an architect licensed under Chapter 481, or a person certified as a reserve specialist. § 718.112(2)(g)3.a. HB 913 also added a conflict-of-interest disclosure rule: if the professional or firm performing the study intends to bid on repair work the study identifies, that has to be disclosed in writing — and a violation can make the related repair contract voidable.

What a SIRS Costs

Florida's SIRS statute doesn't set a price. Industry-reported ranges from reserve-study firms commonly run from roughly $5,000 to $30,000 or more, depending on the building's size, age, unit count, and how many components need direct testing versus visual inspection. Larger, older, or more structurally complex buildings — particularly coastal towers with more waterproofing and structural scope to evaluate — tend to land toward the higher end. Treat any number you see, including this range, as a planning estimate, not a quote; ask a licensed provider for a proposal scoped to your specific building.

The Compliance Reality: Most Buildings Weren't Ready

Reported compliance with the original December 31, 2024 SIRS deadline was low. Coverage citing county-level data around that deadline put completion rates at roughly 44% in Miami-Dade, 41% in Broward, and 28% in Palm Beach — meaning a majority of associations in Florida's largest condo markets hadn't finished their study by the original date, which is part of why HB 913 extended the deadline a year rather than leaving it in place. If your association is still working through this, you're not unusual — but the extended deadline has also already passed, which is exactly why the funding conversation tends to arrive alongside, or shortly after, a completed study rather than years ahead of it.

The Deadlines Boards Keep Getting Wrong

This is the single most confused fact in Florida's condo-compliance world, and it's worth being precise about it.

There is no December 31, 2026 SIRS deadline in the statute, full stop. The December 31, 2026 date that dominates blog and press coverage is a narrower outer bound: an association whose milestone inspection is due on or before that date is allowed to complete its SIRS at the same time as the milestone inspection — but "in no event may the structural integrity reserve study be completed after December 31, 2026." § 718.112(2)(g)7. That's a pairing allowance for a specific subset of associations, not a universal deadline.

The actual SIRS completion deadline is December 31, 2025 — extended by HB 913 from the original December 31, 2024 date set by the 2022 post-Surfside law. As of mid-2026, that deadline has already passed for most associations that were required to have a completed SIRS on file.

Here's the piece that trips up even careful readers: two different December 31 dates govern two different things, and they moved on different schedules. The rule barring associations from voting to waive SIRS reserves attaches to budgets adopted on or after December 31, 2024 — that date was set by the original 2022 law and HB 913 did not change it. The SIRS completion deadline, separately, moved from December 31, 2024 to December 31, 2025 under HB 913. The practical result: an association could be legally barred from waiving reserves for SIRS components in a budget cycle that comes before its SIRS is even finished. Don't conflate the two dates — they answer different questions.

One more relief valve worth knowing: an association that completed a milestone inspection within the preceding five years, meeting SIRS visual-inspection standards, can use that inspection to satisfy the SIRS's visual-inspection component (§ 718.112(2)(g)8), and an association that recently completed a milestone inspection can delay its SIRS for a limited window afterward (§ 718.112(2)(g)9).

As for the legislature revisiting any of this in 2026 — it didn't. Two bills that would have changed SIRS obligations, SB 722 and SB 1498, both died in committee during the 2026 regular session. The rules described here are the current ones.

The Market Pressure Behind the Law

SIRS compliance isn't purely a legal box to check — it's increasingly tied to whether a building can get insured and financed at all. Insurance-industry commentary in 2026 has described carriers asking increasingly detailed underwriting questions about building age, deferred maintenance, structural reports, and reserve-funding practices, with compliant associations generally seeing stronger outcomes at renewal. Separately, more than 1,400 Florida condo buildings appeared on Fannie Mae's mortgage-ineligible list as of April 2025 — more than double the count from two years earlier — with inadequate insurance and deferred maintenance cited as the top two reasons. Neither of those data points proves a direct, named case of a building denied insurance or a mortgage specifically for missing SIRS paperwork, but the underwriting scrutiny itself is well documented, and it's part of why boards increasingly treat SIRS compliance as connected to the building's overall financial health, not just a statutory obligation.

Funding the Gap: No More Waivers, But More Tools

The reserve-waiver ban is the part of this law that actually forces action. For budgets adopted on or after December 31, 2024, members of a unit-owner-controlled association required to have a SIRS cannot vote to provide no reserves, or less-than-required reserves, for the SIRS components. § 718.112(2)(f)2.b. Members also can't vote to redirect SIRS reserve funds to any other purpose. § 718.112(2)(f)3. Non-SIRS reserve items — paving, pool resurfacing, clubhouse amenities — remain waivable, but only by a majority vote of the total voting interests, a higher bar than "majority of those who show up to vote."

What HB 913 changed is the toolkit for meeting that funding obligation. Reserves for SIRS items may now be funded by regular assessments, special assessments, lines of credit, or loans — and a special assessment, line of credit, or loan used this way requires a majority vote of the total voting interests. § 718.112(2)(f)2.c(I). Critically, once that vote passes and financing is secured, the funds become available to the board without further approval by the members — the board doesn't have to go back to a vote every time it draws. § 718.112(2)(f)2.c(II). Any such financing has to be disclosed in the association's annual financial statement and to prospective purchasers.

One accounting note worth flagging to your treasurer or CAM: SIRS reserve items can be pooled with each other under a shared cash-flow analysis, but they cannot be pooled with non-SIRS reserve items in one general fund. § 718.112(2)(f)4. Keep the two funding streams distinguishable in your books.

For most boards facing this today, the real question isn't whether the law allows financing — it does — it's how the numbers compare to a special assessment for their specific project. We walk through that comparison, with an illustrative worked example, in Special Assessment vs. Association Loan.

What Happens If a Building Falls Behind

The statute leaves specific penalty amounts to local enforcement agencies rather than setting a single statewide fine — a local enforcement agency "may prescribe timelines and penalties with respect to compliance." § 553.899(10). Local agencies also report compliance data to the state's licensing authority annually, which is a reporting mechanism rather than a penalty in itself. The consequences that tend to matter more in practice are market-driven rather than statutory: insurance non-renewal or pricing pressure, closer lender and title-company scrutiny during a sale, friction for owners trying to sell or refinance a unit, and — for associations that let the gap widen long enough — a larger special assessment or financing need down the road than if the reserve had been funded on schedule from the start.

Straight-Line vs. Pooled: A Reserve-Accounting Detail Worth Knowing

Two funding methods exist for reserves generally: straight-line (component) funding, where each item is tracked and funded in its own line based on its own life and cost, and pooled funding, where multiple items are funded collectively through an aggregate cash-flow analysis. Florida law allows pooling reserves generally, but with a specific restriction for SIRS: reserve funding for the SIRS components "may only be pooled with other components listed in" the SIRS statute. § 718.112(2)(f)4. In practice, that means your association's eight SIRS components can be pooled together into one combined SIRS reserve fund, but that fund cannot be commingled with non-SIRS reserve money — paving, pool resurfacing, clubhouse items, and similar. Ask your management company or accountant to confirm your SIRS reserves are tracked as a distinguishable pool separate from everything else; this is a detail lenders and auditors both check.

Questions to Bring to Your Next Board Meeting

Before your board votes on how to fund a SIRS-driven reserve gap, it's worth having clear answers to:

• Has our SIRS been completed, and if so, when does it need updating? (Every 10 years, at minimum, under § 718.112(2)(g)1.)
• What does our governing documents say about vote thresholds for financing versus a special assessment? Outside the SIRS-specific majority-vote trigger, Florida statute is silent on borrowing vote thresholds — your declaration and bylaws control.
• Are we treating SIRS reserves as a segregated pool, separate from our other reserve funds?
• If we're considering a loan or line of credit, have we compared the total cost against a lump-sum special assessment for the same project? See Special Assessment vs. Association Loan for a worked comparison.
• Do we have our budget, delinquency report, and financial statements ready to hand to a lender today — or would assembling that file take weeks? See our Funding Readiness Checklist.

SIRS vs. Milestone Inspection: Related, Not the Same

Boards often conflate these two obligations because they arrived in the same 2022 law and frequently apply to the same buildings. A milestone inspection (§ 553.899) is a structural life-safety assessment tied to a building's age — due by the year it turns 30 (or 25, if the local jurisdiction has adopted that coastal option), then every 10 years. A SIRS is a component-by-component funding study, due on its own 10-year cycle regardless of age. If your building is heading into a milestone review, or has already had one flag deterioration requiring repair, see Your Building Failed Its Milestone Inspection for how the repair-commencement clock and funding timeline interact.

Getting the Funding Conversation Started Before You're Forced Into One

The associations that come out of this process best are the ones that start the funding conversation before a completed SIRS forces their hand — pulling together budgets, aging reports, and prior reserve studies while there's still runway to compare options. Our Funding Readiness Checklist lays out exactly what to have on hand, and our capital improvement funding program is built specifically around SIRS reserves, roofs, concrete restoration, and elevator projects.

JPMorganChase has committed approximately $2 billion in financing capacity toward Florida association funding. That capacity is structured at the association level, with terms up to 30 years — one path, alongside special assessments and traditional bank loans, for closing a reserve shortfall the SIRS uncovers.