Florida Condo Milestone Inspections and the SIRS: A Plain-Language Guide for Board Members

When the Champlain Towers South collapsed in Surfside in 2021, 98 people died in a building that engineering assessments had flagged for structural problems years earlier. The response from Florida's legislature was sweeping and fast. Within months, new laws required that aging Florida condo buildings undergo formal structural inspections and that the reserves to fund future structural repairs be fully funded and non-waivable.

Those laws have been refined in every legislative session since. The requirements are now clearer but also more complex, and the deadlines are real. I have talked to board members across Florida who are either unaware that their building has already missed a deadline, or who are confused about which requirement applies to them and when.

This is the plain-language explanation I wish had existed when all of this started.

The Two Requirements: Milestone Inspection and SIRS

Florida's post-Surfside condo safety framework has two separate but related requirements. They are often confused because they overlap in scope and timing, but they serve different purposes and have different rules.

A Milestone Inspection is a structural engineering inspection of the building itself. Its purpose is to determine whether substantial structural deterioration exists right now. It answers the question: is this building safe today?

A Structural Integrity Reserve Study, known as a SIRS, is a financial planning document. It identifies the major structural components of the building, estimates their remaining useful life and replacement cost, and produces a funding schedule that tells the association how much to set aside each year so the money is there when those components need to be replaced or repaired. It answers the question: will this building be financially maintained going forward?

Think of it this way. The milestone inspection is the doctor's visit that finds out if you have a problem. The SIRS is the treatment plan that makes sure you stay healthy long term.

Both are required for Florida residential condominium and cooperative buildings that are three habitable stories or taller. They do not apply to single-family homes, duplexes, triplexes, or quadplexes, and they do not apply to HOA communities that do not include condominium buildings of that height.

Milestone Inspection: Who, When, and What

Every Florida residential condo or cooperative building three stories or taller must complete a milestone inspection at a prescribed age and then repeat it every ten years.

The age trigger is 30 years based on the date the certificate of occupancy was issued. However, local governments have the authority to require the initial inspection at 25 years if local conditions warrant it. If your building is in a coastal jurisdiction, check with your local building department about whether they have adopted the 25-year trigger.

For buildings that were already old when these laws passed, the first milestone inspection deadlines were phased in based on when the building hit the age threshold. Buildings that reached 30 years before July 1, 2022 had a deadline of December 31, 2024. Buildings reaching 30 years between July 1, 2022 and December 1, 2024 had a deadline of December 31, 2025. If your building is in one of those categories and has not completed its milestone inspection, you are currently non-compliant.

The inspection itself must be performed by a licensed Florida engineer or architect. It has two phases.

Phase one is a visual inspection of the building's load-bearing elements and primary structural members. The inspector walks the building, looks at everything accessible, and makes a judgment about whether substantial structural deterioration exists. If the inspector finds the building is in satisfactory condition, the phase one inspection is complete and nothing further is required until the next inspection cycle in ten years.

If the phase one inspector finds evidence of substantial structural deterioration, a phase two inspection is required. Phase two goes deeper. It involves destructive testing, material sampling, and a detailed analysis of the specific areas of concern identified in phase one. The phase two inspection must be completed within 180 days of submitting the phase one report.

If phase two finds repairs are required, the association must commence those repairs within 365 days of receiving the phase two report, unless the local governing body requires an earlier start. Once repairs are complete, a licensed professional must reinspect and provide an amended report confirming the building is safe for continued occupancy.

After receiving the milestone inspection report, the association must do three things within 45 days. Distribute a copy of the inspector-prepared summary to every unit owner by mail or email to those who have consented to electronic notice. Post a copy of the summary in a conspicuous place on the property. Publish the full report and summary on the association's website if the association is required to have one.

The association must also electronically submit the report to the DBPR through the association's online account within 45 days of receiving it.

The SIRS: Who, When, and What

The Structural Integrity Reserve Study is required for the same population of buildings: Florida residential condo and cooperative buildings three habitable stories or taller.

The SIRS must be completed at least every ten years after the condominium's creation. For associations that existed on or before July 1, 2022 and are unit-owner controlled rather than developer-controlled, the deadline for the initial SIRS was December 31, 2025 under the current law as amended by HB 913.

There is an important extension available for some associations. If your building is required to complete a milestone inspection on or before December 31, 2026, you may complete the SIRS simultaneously with that milestone inspection. In that case the deadline for the SIRS extends to December 31, 2026. But under no circumstances can the SIRS be completed after December 31, 2026 regardless of any other deadline or circumstance.

The SIRS must cover eight specific structural components at minimum: the roof, the load-bearing structure including walls and primary structural members, the fire protection systems, the plumbing, the electrical systems, the waterproofing and exterior painting, the windows and exterior doors, and any other item with a deferred maintenance or replacement cost above the statutory threshold. Under the 2025 changes from HB 913, that threshold is $25,000, adjusted annually for inflation starting February 1, 2026.

The SIRS must be performed by a qualified professional, which includes a licensed engineer, architect, or certified reserve specialist meeting specific qualifications. The professional must conduct a visual inspection, estimate the remaining useful life of each covered component, estimate the replacement or deferred maintenance cost, and produce a reserve funding schedule.

There is also a new conflict of interest rule that came out of HB 913 that boards should know. Any engineer, architect, or contractor bidding to perform a milestone inspection or SIRS must now disclose in writing if they also intend to bid on any repair work that comes out of their report. A firm that tells you your building needs $3 million in structural repairs cannot simultaneously be the firm you hire to do those repairs without disclosing that relationship upfront. This protects associations from the obvious conflict of interest that existed previously.

Once the SIRS is completed, the association must submit a SIRS Reporting Form to the DBPR electronically through the association's online account within 45 days of receiving the study. The SIRS report must be kept in the official records for at least 15 years and must be made available to prospective buyers who are under contract to purchase a unit.

Reserve Funding: The Part That Changes Your Budget Forever

This is where the milestone inspection and SIRS requirements connect to your annual budget in a way that cannot be ignored.

For any Florida condo association budget adopted on or after January 1, 2025, the reserves for the eight SIRS structural components must be included and fully funded. They cannot be waived by a vote of the owners. They cannot be reduced. They cannot be used for other purposes. This is a hard legal requirement.

What fully funded means in practice depends on what the SIRS recommends. The study produces a baseline funding plan that calculates how much the association needs to set aside each year for each covered component based on its remaining useful life and estimated replacement cost. The association's annual budget must reflect that funding plan.

For associations that have been waiving reserves for years or decades, this transition is painful. The gap between what they have been collecting and what the SIRS says they should have been collecting can be enormous. Some associations have had to levy significant special assessments just to get their reserve balances to a legally compliant level, before any actual structural work was funded.

This is the financial reality driving many of the large special assessments that Florida condo owners have been reading about. At the Cricket Club in North Miami, owners received assessments as high as $134,000 per unit. At Mediterranean Village in Aventura, some owners were assessed up to $400,000. Those numbers reflect decades of deferred reserve funding that the new law has forced associations to confront all at once.

The earlier an association completes its SIRS and begins funding to the study's recommendations, the more manageable the transition is. Every year of delay compresses the timeline and increases the annual contribution required.

What Happens If You Miss the Deadlines

Non-compliance with milestone inspection and SIRS requirements creates several serious problems simultaneously.

DBPR enforcement. The Division can impose fines and take administrative action against non-compliant associations. Boards have a fiduciary duty to comply with state law and failure to do so creates personal exposure for individual directors.

Insurance problems. Some Florida insurers are now asking associations to document their milestone inspection and SIRS compliance status as part of the underwriting process. An association that cannot demonstrate compliance may face higher premiums or difficulty obtaining coverage at all.

Financing problems for buyers. Prospective buyers of units in your building may have difficulty obtaining financing if the association cannot produce a completed SIRS. Lenders are increasingly asking for this documentation and its absence can kill deals, which depresses property values for every owner in the community.

Increased liability. If a structural problem emerges in a building that missed its milestone inspection deadline, the board members who failed to comply are in a much more exposed legal position than they would have been with a clean compliance record.

What to Do Right Now

If you are on the board of a Florida condo building three stories or taller, here is your action list.

Determine your building's age from the certificate of occupancy date, not the year it was built. The certificate of occupancy is the statutory trigger.

Confirm whether your milestone inspection has been completed. If it has, confirm the report was distributed to owners and submitted to the DBPR within 45 days. If it has not been completed and your building has passed the age threshold, commission it immediately.

Confirm whether your SIRS has been completed. If you are in the extension category where your milestone inspection is due by December 31, 2026, you may complete both simultaneously. If not, your initial SIRS deadline was December 31, 2025.

Confirm your DBPR online account is active and current. The SIRS reporting form must be submitted through that account.

Review your current reserve budget against the SIRS funding schedule. If your budget does not reflect the SIRS recommendations, it needs to be corrected in the next budget cycle. Reserves for SIRS components may not be waived.

Verify the conflict of interest disclosures for any firm performing your inspection or study. Any firm that will also be bidding on repair work must disclose that in writing before being engaged.

The consequences of getting this right are a compliant, properly funded association that can document its structural safety to owners, buyers, lenders, and insurers. The consequences of getting it wrong are fines, insurance problems, financing problems, and personal liability for board members. The choice is straightforward even if the process is not.

For a complete guide to running a Florida condo or HOA association including reserve funding, compliance calendars, structural requirements, and the decisions every board faces, pick up a copy of Run the Board. Written by a Florida board president who has been through the post-Surfside legislative landscape firsthand.