Milestone inspection findings

What a milestone inspection is, and what it is not

A milestone inspection is a structural inspection performed by a licensed engineer or architect at defined points in a building's life, to determine whether it has experienced deterioration that threatens its structural integrity.

It is none of the following, and confusing it with them causes most of the misunderstanding: a reserve study, a financial planning exercise built on component condition and remaining life; a facade inspection, limited to the exterior wall; a home inspection, a generalist visual survey for a buyer; or a property condition assessment, a commercial due-diligence product.

Florida's statute is the model most other states have looked to, and its two-phase structure is the best framework for explaining what these inspections involve. The engineering generalises even where the statutes do not — several states have adopted milestone-style requirements since 2021, and what an engineer looks at is the same everywhere.

Be explicit about what it does not do, because expectations here are routinely wrong. It does not assess whether the building meets current code; existing buildings are not required to. It does not assess plumbing, electrical, HVAC or elevators except where they bear on structure. It does not price the repairs, it does not fund anything, and it is not a warranty.

Which buildings, and when

In Florida, a milestone inspection is required for residential buildings three habitable stories or more in height as determined by the Florida Building Code, held under condominium ownership under Chapter 718 or cooperative ownership under Chapter 719. The word habitable arrived with HB 913, effective 1 July 2025; before that the test was simply three or more stories. That is a real narrowing, and whether a parking podium counts is a design professional's determination.

The age trigger, and the point most secondary coverage still gets wrong. A building must undergo a milestone inspection by 31 December of the year in which it reaches 30 years of age, measured from the date the certificate of occupancy was issued, and every 10 years after that.

The original 2022 legislation put buildings within three miles of a coastline on a 25-year clock. That blanket coastal rule was removed by SB 154, signed and effective 9 June 2023. Since then the statewide trigger is 30 years, and a local enforcement agency may determine that local circumstances — proximity to salt water among them — justify inspection at 25 years instead. Any page still repeating the three-mile formulation is describing law that has not been in force for three years, and the correct instruction for a coastal building is to check with the local building department.

Once a report exists the association must distribute its summary to unit owners within 45 days, and county boards must adopt an ordinance requiring repairs to commence within 365 days of a phase two report identifying substantial structural deterioration.

Phase one and phase two

Under Fla. Stat. §553.899, phase one requires a licensed architect or engineer to perform a visual examination of habitable and nonhabitable areas of a building, including the major structural components.

Visual examination. Phase one is non-destructive. The engineer looks. They do not open walls, take cores or perform testing. This is deliberate: phase one is a screening instrument meant to be performed across an entire building stock. It follows that a report finding nothing is not a certificate that nothing is wrong — it is a statement that nothing visible warranted escalation.

What is examined. The inspection is not confined to common areas; access to units may be required. The engineer looks at foundations, columns and bearing walls, slabs and beams, balconies and stairs and their connections back to the building, the roof structure, parking structures, the envelope as it affects structure, evidence of prior repairs, and evidence of movement.

Phase two is required only if any substantial structural deterioration is identified during phase one; where it is, a progress report is due within 180 days of the phase one report. The statutory scope is deliberately open-ended: it may involve destructive or nondestructive testing at the inspector's direction, and may be as extensive or as limited as necessary to fully assess areas of structural distress.

In practice that means sounding to map delamination, half-cell potential survey for corrosion probability, ground-penetrating radar, thermography, and monitoring of deflection and crack width over time — a crack that is not moving is a different problem from one that is. Invasive work includes selective removals to expose reinforcement, coring, chloride profiling, and test cuts in walls and waterproofing. What converts observation into conclusion is a structural evaluation of residual capacity against demand. Because the engineer scopes it, phase two cost is unbounded at the outset; the right response is not to constrain the investigation but to stage it.

Nobody fails a milestone inspection

This is the most important passage in the scheme and the one most often misrepresented. Fla. Stat. §553.899 defines substantial structural deterioration as substantial structural distress or weakness that negatively affects a building's general structural condition and integrity — and then says this:

The term does not include surface imperfections such as cracks, distortion, sagging, deflections, misalignment, signs of leakage, or peeling of finishes unless the licensed engineer or architect performing the phase one or phase two inspection determines that such surface imperfections are a sign of substantial structural deterioration.

• A crack is not automatically a finding. Neither is a sag, a deflection, a stain or peeling paint; the statute's default is that these are surface imperfections.
• But the engineer can decide otherwise. The determination turns entirely on professional judgement — whether the surface condition is a sign of substantial structural deterioration.
• Two engineers can therefore differ on the same building, and both be defensible, which is why associations sometimes seek a second opinion.
• The threshold is substantial. The scheme is not designed to catch every deficiency, but conditions that negatively affect the building's general structural condition and integrity.

This definition is also why the phrase heard most often in the market — my building failed its milestone inspection — describes something that does not exist. There is no pass and there is no fail. There is a report, and it either identifies substantial structural deterioration or it does not, and either way it may contain recommendations.

The statute requires the report to identify any substantial structural deterioration, describe its extent, recommend repairs, state whether unsafe conditions were observed, recommend preventive repairs for items damaged but not yet substantially deteriorated, and identify items requiring further inspection. That last requirement is under-discussed. An item flagged for further inspection is neither a finding nor a clearance — it is an open question the engineer could not resolve.

The four outcomes

1. No substantial structural deterioration, no significant recommendations

The association files the report and moves on. This is a good result and should be read as one — but not as a certification that the building is sound in every respect.

2. No substantial structural deterioration, but preventive repairs recommended

The most common genuinely useful outcome. The engineer has seen conditions that are not yet structural but will become so: failed waterproofing, deteriorating sealants, corroding railings, ponding, spalling that has not yet reached the reinforcement. This is a gift to a competent board — a prioritised, engineer-backed list of what to do before the problem becomes expensive. Boards that file the report and do nothing are choosing the expensive path knowingly and on the record, and a buyer can see that in the minutes.

3. Substantial structural deterioration identified; phase two required

The building now has a documented structural finding. Phase two must be commissioned; the cost of remediation is unknown until it concludes; the finding will be disclosed in every subsequent transaction; and the association's reserve and assessment planning is now driven by an external schedule rather than its own.

4. Unsafe conditions observed

The most serious outcome and the fastest moving. Unsafe conditions generally trigger notification of the local building official, protective measures such as shoring, netting or closure of the parking structure, and in extreme cases evacuation. Interim measures start before any repair is designed and continue through design, permitting, bidding and construction — and associations are routinely surprised by how long they pay for shoring that produces nothing.

For the board, a finding creates an obligation to act on a timeline, with fiduciary exposure for not acting: once it exists in writing, discretion narrows sharply, because that is documented notice.

What it means for financing, and what to ask for

Current project standards inquire directly into whether a required inspection has been performed, what it found, and whether the findings have been addressed — and the rules are permanent, not emergency measures. Fannie Mae folded its post-2021 requirements into the Selling Guide by announcement issued 5 July 2023, effective for loan applications dated on or after 18 September 2023, and Freddie Mac's parallel policies sit in its Guide. Under them, projects in need of critical repairs are ineligible, and both apply the same trigger: unfunded repairs exceeding $10,000 per unit expected within 12 months. Freddie Mac's definition of critical repairs expressly reaches any project that failed to pass a state, county or other jurisdictional mandatory inspection specific to structural safety, soundness and habitability, with a three-year lookback — and a milestone inspection is exactly such an inspection.

The distinction that decides the outcome is between a finding that exists and a finding that has been addressed. A structural finding with a completed repair, or with an engineer-scoped repair contracted, scheduled and funded within the per-unit limit, is a manageable underwriting fact. The same finding sitting in a filed report with no scope, no funding and no schedule is the condition these rules were written for.

• The phase one report in full rather than the summary distributed to owners, and any phase two report and progress report.
• The engineer's repair recommendations, including preventive ones, the items flagged as requiring further inspection, and the board minutes discussing all of it.
• The contracts, schedule and funding source for any repair work, the reserve study, and the record of any assessment levied or contemplated.

A phase one report on its own, without the board's response, is half the story. Read it alongside the reserves: a structural inspection tells you what is wrong; a reserve study tells you whether the association can pay for it. An association with a finding and a well-funded reserve is in far better shape than its report first suggests.

Name the boundary. Whether a condition is substantial structural deterioration is a licensed engineer's or architect's determination and nobody else's. Whether a project remains eligible is a question for the buyer's own lender. And in Florida, whether a building is on a 30-year or 25-year clock is a question for the local enforcement agency, because since June 2023 that decision is made locally.

Common questions

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