What a SIRS is, and how it differs from a reserve study
A Structural Integrity Reserve Study is a study of the reserve funds required for future major repair and replacement of the common areas, based on a visual inspection of the property. It must identify the covered items, state each one's estimated remaining useful life and replacement cost or deferred maintenance expense, and provide a recommended annual reserve amount. It sits at Fla. Stat. §718.112(2)(g), created by SB 4-D effective 26 May 2022 and amended in every regular session through 2025.
It is not a general reserve study, and treating it as one is the first mistake most readers make. A conventional study covers whatever components the preparer and the association decide to include; a SIRS covers a prescribed statutory list, and none of it can be left out. Non-structural components remain governed by the ordinary reserve rules at §718.112(2)(f), and an association subject to a SIRS should still reserve for them separately.
The visual-inspection basis is the study's defining characteristic and should not be softened. The SIRS does not open walls, sound concrete, core or test. Where a component's condition cannot be determined by looking — plumbing inside chases, reinforcement inside concrete, wet insulation inside a roof assembly — the study carries a planning allowance, not a measured requirement. A SIRS is a funding instrument, not a condition investigation. The milestone inspection is the instrument for determining structural condition.
Which buildings, and who may perform it
The requirement applies to residential condominium buildings three habitable stories or higher in height as determined by the Florida Building Code. As with the milestone inspection, the word habitable arrived with HB 913 effective 1 July 2025; before that the test was simply three or more stories. Parking podiums, storage levels and utility floors may not count where they are not designed for living, sleeping, eating or cooking — a determination for a design professional rather than a board. Excluded are single-family through four-family dwellings with three or fewer habitable stories above ground, and portions of a building maintained by a party other than the association. Cooperatives are covered by the parallel provision in Chapter 719.
The visual inspection portion must be performed or verified by an engineer licensed under Chapter 471, an architect licensed under Chapter 481, or a holder of the reserve specialist (RS) or professional reserve analyst (PRA) designation from CAI or APRA respectively. The statute deliberately admits both design professionals and reserve-study credential holders, because the exercise has an engineering dimension and a financial one.
There is also an efficiency route: a milestone inspection completed within the past five years that satisfies the study's requirements may substitute for the SIRS visual inspection, which is how an association subject to both regimes avoids paying twice.
The mandated components
A SIRS must at minimum address the following. Items one through seven are mandatory regardless of cost — the threshold below applies only to the eighth, catch-all category.
- Roof. The complete assembly: covering, flashings, edge metal and copings, drainage, insulation. Where a building has several roof areas of different ages, each is properly a separate line. What most affects remaining life — wet insulation within the assembly — is invisible from the surface.
- Structure, including load-bearing walls and other primary structural members and systems. This is where balconies, walkways, stairs and the parking structure are addressed, and where the visual basis bites hardest: delamination is invisible until concrete spalls, and cover depth, chloride content and carbonation depth cannot be observed at all.
- Fireproofing and fire protection systems. Two distinct things. Fireproofing is passive: protection on structural steel, rated assemblies and shafts, firestopping, fire doors. Fire protection systems are active: sprinklers, standpipes, fire pump, alarm, emergency power. For those the testing and maintenance record is the best proxy for condition — a document rather than an observation.
- Plumbing. Supply risers and mains, drain, waste and vent stacks, hot water production, pumps. Significant piping is concealed and the deterioration mechanisms are internal to the pipe, so the study should weight the leak history heavily and build the line from a project scope including restoration and access, not from a pipe price.
- Electrical systems. Service entrance and switchgear, meter banks, house panels, feeders, emergency power, grounding. Meaningful assessment requires de-energised inspection with covers removed, infrared thermography under load, or load monitoring — none of which is a visual walkthrough.
- Waterproofing and exterior painting. Coatings, sealant joints, balcony and terrace waterproofing, plaza decks, traffic coatings. This is the preventive component, and its neglect creates the structure component's problem. Funding it properly is the cheapest structural insurance an association can buy.
- Windows and exterior doors. Frames, glazing, insulating glass units, hardware, perimeter seals, sliding and balcony doors. The reserve number is a unit cost multiplied by a quantity, so the count and type mix are most of the accuracy.
- Any other item whose deferred maintenance expense or replacement cost exceeds the statutory threshold and whose failure to be maintained negatively affects the items above.
The catch-all item, and the threshold that moved
The eighth category is the flexible one, and its test is causal: does failure of this item negatively affect the roof, the structure, the fire protection, the plumbing, the electrical, the waterproofing, or the windows and doors? Common examples: parking structure traffic coatings, expansion joints and drainage; seawalls; retaining walls; foundation drainage; elevators; balcony railings, whose anchorages penetrate the structure; and plaza decks over occupied space.
HB 913 raised the threshold for that category from $10,000 to $25,000, effective 1 July 2025, so fewer items are pulled into the mandatory study — one of the mechanisms people mean by reserve fund relief.
The statute also requires the amount to be adjusted annually for inflation using the Consumer Price Index, with the Department of Business and Professional Regulation posting the revised amount by 1 February each year. The operative figure is $25,000 or the adjusted amount, whichever is greater. This page states no current adjusted figure, and any page that does should be checked: the number for a given year comes from DBPR's condominium portal, not from a secondary source repeating last year's.
The deadlines, and where they stand now
Three separate timing rules operate, and they are easily conflated.
The recurring requirement. A SIRS at least every 10 years after the condominium's creation, for each qualifying building.
The initial deadline for existing associations. An association existing on or before 1 July 2022 and controlled by unit owners other than the developer had to complete a SIRS by 31 December 2025 — originally 31 December 2024, extended a year by HB 913.
The milestone-concurrent carve-out. An association required to complete a milestone inspection on or before 31 December 2026 may complete the SIRS simultaneously with that inspection. The statute is explicit that in no event may the SIRS be completed after 31 December 2026.
One further deferral: an association that has completed a milestone inspection may delay the required SIRS for no more than the two consecutive budget years following it, to prioritise the repairs the inspection identified.
Where that leaves matters as of August 2026: the general deadline of 31 December 2025 has passed. The only remaining statutory runway is the milestone-concurrent route, and it closes on 31 December 2026. A qualifying association with no SIRS and no milestone-concurrent or post-milestone-deferral basis is out of compliance now, not prospectively. For a buyer, "we are working on it" is a materially different answer in August 2026 than it was in 2024, and the date of the milestone inspection determines which category the association is in.
What happened to reserve waivers
This is the heart of the regime and the point most often garbled, so it is worth setting out in two steps.
The general Florida rule, which predates all of this and still applies, is at §718.112(2)(f). Reserves must be included in the proposed annual budget, but a majority of the total voting interests may vote to provide no reserves, or less reserves than required, or to use reserve funds for other purposes. Only the voting interests of units subject to assessment for a given item may vote on it, and any proxy or ballot must carry a statutory warning in substantially this form:
"WAIVING OF RESERVES, IN WHOLE OR IN PART, OR ALLOWING ALTERNATIVE USES OF EXISTING RESERVES MAY RESULT IN UNIT OWNER LIABILITY FOR PAYMENT OF UNANTICIPATED SPECIAL ASSESSMENTS REGARDING THOSE ITEMS."
The structural carve-out is the post-Surfside change. For budgets adopted on or after 31 December 2024, an association required to obtain a SIRS may not vote to waive or reduce reserves for the items on the SIRS component list, and may not use those reserves for any other purpose. In plain terms: non-structural reserves remain waivable by majority vote with the statutory warning; SIRS structural reserves are not waivable and cannot be raided.
Two narrow exceptions exist. Members may vote to waive maintenance of the reserves recommended by the most recent SIRS if the association votes to terminate the condominium. And the board may pause contributions without prior member approval where a local building official determines the building is uninhabitable due to a natural emergency — complementing the rule added by HB 1021 in 2024 permitting reserve funds to be spent to make a building habitable again without a member vote, with contributions resuming immediately once it is.
Neither is a general relief route. No amount of funding flexibility introduced in 2025 changed the position: the structural reserve obligation is not waivable.
Contents, distribution, and a conflict still sitting in the statute
HB 913 added two content requirements that make the document more useful to a buyer. A SIRS must now include a reserve funding plan on a baseline funding basis, ensuring the projected cash balance never falls below zero during the study period; and it must differentiate between mandatory reserve items and other reserve items. That second requirement makes the non-waivable structural portion legible on the face of the document rather than something to reconstruct from the statute.
Distribution. Since HB 1021, effective 1 July 2024, the association must give each unit owner a copy of the completed SIRS within 45 days of receiving it, or notify owners it is available for inspection, and must notify the Division within 45 days.
The drafting conflict. Developers must provide a turnover inspection report including a SIRS before transferring control, under §§718.301(4)(p) and 719.301(4)(p). Those turnover provisions apply to buildings regardless of height, while the related SIRS provisions carry the three-habitable-story threshold. That inconsistency has not been fixed: CS/SB 1498 (2026), which would have resolved it, died in the Appropriations Committee on Agriculture, Environment and General Government on 13 March 2026, and its House companion died the same day. In a newly turned-over project of fewer than three habitable stories it is a live question for a Florida attorney rather than a settled rule. The statute is at flsenate.gov.
Common questions
What is a Structural Integrity Reserve Study?
It is a Florida statutory reserve study covering a prescribed list of structural and life-safety components, based on a visual inspection of the property, required at Fla. Stat. §718.112(2)(g). It identifies each covered item, its estimated remaining useful life and estimated replacement cost or deferred maintenance expense, and a recommended annual reserve amount. It is a funding instrument rather than a condition investigation, and it does not replace a structural inspection.
Which buildings need a SIRS?
Residential condominium buildings three habitable stories or higher in height as determined by the Florida Building Code, with cooperatives covered by the parallel Chapter 719 provision. Single-family through four-family dwellings with three or fewer habitable stories above ground are excluded, as are portions of a building maintained by a party other than the association. The habitable-stories test replaced a simple three-story test on 1 July 2025.
What was the SIRS deadline?
31 December 2025 for associations existing on or before 1 July 2022 and controlled by unit owners — extended by one year from the original 31 December 2024 by HB 913. That date has passed. The only remaining route is the carve-out allowing an association required to complete a milestone inspection on or before 31 December 2026 to complete the study simultaneously, and the statute states that in no event may it be completed after 31 December 2026.
Can Florida owners still vote to waive reserves?
For non-structural reserves, yes, by a majority of the total voting interests and with the statutory warning on the proxy or ballot. For the components on the SIRS list, no. For budgets adopted on or after 31 December 2024, an association required to obtain a SIRS cannot vote to waive or reduce those reserves or use them for other purposes. The narrow exceptions are a vote to terminate the condominium, and a building determined uninhabitable by a local building official after a natural emergency.
Is the reserve item threshold $10,000 or $25,000?
$25,000 since 1 July 2025, raised from $10,000 by HB 913, and adjusted annually for inflation using the Consumer Price Index with the Department of Business and Professional Regulation publishing the revised figure by 1 February each year. The operative amount is $25,000 or the adjusted figure, whichever is greater. The threshold applies only to the catch-all component category — roof, structure, fire protection, plumbing, electrical, waterproofing and painting, and windows and exterior doors are mandatory regardless of cost.
Can a milestone inspection be used as the SIRS?
Partly. A milestone inspection completed within the past five years that satisfies the study's requirements may substitute for the SIRS visual inspection, which is the main efficiency route for associations subject to both regimes. It does not replace the study itself: the SIRS must still produce remaining useful lives, replacement cost or deferred maintenance estimates, a recommended annual reserve amount, a baseline funding plan and the split between mandatory and other reserve items.