Florida condo milestone & SIRS reserve rules for 2026

Last updated 2026-08-14

What changed for Florida condo boards heading into 2026

Nothing new dropped on January 1, 2026 in the sense of a fresh statute, but 2026 is the year the 2022-2023 reforms stop being theoretical for a lot of buildings. The SIRS (Structural Integrity Reserve Study) funding requirement kicked in for the fiscal year beginning on or after December 31, 2024, which for calendar-year associations means the 2025 budget was the first one that had to reflect full reserve funding, and 2026 is the year boards get held to it in practice, at annual meetings, in owner disputes, and in lender underwriting ^[1]. If your building is at or past its 30-year mark (25 years if you're within three miles of the coastline), you should already have your milestone inspection Phase 1 report in hand or scheduled. If you're not there yet, 2026 is a good year to lock in an engineer, because qualified firms are booked out in a lot of Florida markets, especially South Florida and the Tampa Bay coast. The short version for a board packet: milestone inspections are about the physical building. SIRS is about the money to fix what the inspection (and other required assessments) find. They're linked but they're not the same law, and boards that treat them as one task tend to miss deadlines on the other.

What is a milestone inspection and when is it due?

A milestone inspection is a structural review of a condominium or cooperative building performed by a licensed Florida architect or engineer, required once a building reaches 30 years of age, with a follow-up every 10 years after that ^[2]. If the building is within three miles of the coastline, the trigger drops to 25 years, because salt air accelerates concrete and rebar deterioration. The statute, Fla. Stat. 553.899, applies to buildings that are three stories or more in height. The local enforcement agency (your county or city building department) sends the notice of when the inspection is due, using the certificate of occupancy date, but boards shouldn't wait for that letter. Track your own CO date. The inspection happens in two phases. Phase 1 is a visual examination; if the engineer finds "substantial structural deterioration," the building moves to Phase 2, which involves more invasive testing (core sampling, load testing) and a more detailed report with repair recommendations and timelines ^[2]. DBPR's milestone inspection guidance page confirms the same 30-year/25-year coastal trigger and the three-story threshold for applicability ^[3]. DBPR states the statute's purpose plainly: milestone inspections exist "to ensure the safety of aging buildings" following the 2021 Champlain Towers South collapse in Surfside ^[3]. That event is the reason this whole framework exists, and it's why enforcement has real teeth: local building officials can require repairs on a timeline, and failure to comply can affect a building's certificate of occupancy status. For the deeper mechanics of scheduling, extensions, and what counts as "substantial structural deterioration," see our milestone inspections hub coverage.

What is a SIRS (structural integrity reserve study) and how is it different from a regular reserve study?

A SIRS is a specific, statutorily defined reserve study required for Florida condominiums (and cooperatives) three stories or higher, covering ten structural components: roof, load-bearing walls, primary structural members, floor, foundation, fireproofing/fire protection, plumbing, electrical, waterproofing, and windows/exterior doors ^[1]. It must be performed, or the visual inspection portion must be performed, by a licensed engineer or architect, at least every 10 years ^[1]. A regular (non-structural) reserve study, sometimes called a "full reserve study," is broader. It covers everything the association is financially responsible for maintaining, repairing, or replacing, roads, pools, elevators, painting, landscaping features, in addition to the structural items. Florida doesn't mandate a full reserve study by statute the way it mandates SIRS, but most professionally run associations get one anyway because SIRS alone won't tell you if you're underfunded on the clubhouse roof or the parking garage striping. The critical difference that trips boards up: starting with the fiscal year beginning on or after December 31, 2024, SIRS reserve line items cannot be waived, pooled below full funding, or used for anything other than their designated structural component, and the association must budget to reach full funding based on the current SIRS ^[1]. Non-structural reserve items can still be waived or underfunded by a majority membership vote, same as before the 2022 reforms. See our companion explainer on SIRS reserve study requirements if you want the component-by-component funding math.

What is a reserve study for HOA and condo associations?

A reserve study is a professional assessment of an association's major common-area assets (roofs, paving, painting, structural components, pools, elevators) that estimates each item's remaining useful life and the cost to repair or replace it, then calculates how much money the association needs to set aside each year to cover those future costs without a surprise special assessment. Most reserve studies have two parts: a physical analysis (site inspection, component inventory, useful-life estimates) and a financial analysis (current reserve fund balance, funding plan, recommended annual contribution). A good study gets updated every few years, or right away after a major event like a hurricane or a new inspection finding. Florida HOAs (homeowners' associations governed by Fla. Stat. ch. 720, meaning single-family and townhome communities, not condos) are not required by state law to get a formal reserve study, though the HOA statute does require reserve accounting if reserves are established, and many HOA declarations require one regardless. Condo associations under ch. 718 are increasingly required to, specifically through the SIRS mandate described above ^[1]. For a walkthrough of what a reserve study actually contains and how to read one, our reserve study guide and HOA reserve study guide cover the mechanics in more depth than statute citations alone can.

How much does a reserve study cost?

A reserve study for a condo or HOA in Florida typically runs somewhere between $3,000 and $15,000+, depending on the number of buildings, number of units, site complexity, and whether it's a Level 1 (full, with on-site inspection), Level 2 (update with site visit), or Level 3 (desktop update, no site visit) study. A SIRS specifically, because it requires a licensed architect or engineer and covers structural components with defined inspection protocols, tends to run higher than a generic reserve study for a comparable building, often in the $5,000 to $20,000+ range depending on building size and complexity; larger high-rises with more structural systems and parking garages push toward the top of that range or beyond. There's no statewide fee schedule, and DBPR doesn't publish average pricing, so get at least two or three quotes from Florida-licensed engineers or reserve specialists and treat any number you see online (including ranges in this article) as a starting point, not a quote. The cost of the study is trivial compared to the cost of getting the funding plan wrong. A $2,500 line saved by skipping a proper SIRS update, in a building with a decade-old figure, that turns into a six-figure special assessment. Boards routinely underestimate how much cheaper it is to fund small and steady than to catch up all at once.

How much should an HOA (or condo association) have in reserves?

70% or higher	Strong; low special assessment risk
30-70%	Moderate; monitor closely, plan increases
Under 30%	Weak; special assessment risk elevated
0% (baseline)	No reserves beyond legal minimums; high risk	For Florida condos specifically, the statute doesn't set a percentage target for non-structural items (those can still be waived by vote), but for the ten SIRS structural components, the law requires funding to reach 100% of the amount the study calculates, phased in starting with the fiscal year after December 31, 2024, with no waiver option [1]. That's a harder floor than most other states set. For HOAs under ch. 720, there's no statewide mandatory funding percentage; each declaration and board sets its own policy, though prudent boards generally aim for 70%+ funded to avoid frequent special assessments.

The honest answer is: enough to reach 100% of the funded amount your reserve study calculates for each component, which is a number specific to your building, not a percentage rule of thumb. That said, funding levels are commonly described in industry shorthand as a percent of "fully funded" (the ratio of actual reserve balance to the ideal balance for where each component sits in its life cycle), a framework the Community Associations Institute uses in its own reserve fund education materials ^[4]. Reserve studies generally sort associations into these rough tiers, though these aren't statutory categories, just how the reserve-study industry and CAI describe funding health: | Funding level | General description |

What is an HOA assessment (and how is it different from a special assessment)?

An HOA assessment is the regular fee owners pay to fund the association's budget, operating expenses like landscaping, insurance, management, and utilities, plus reserve contributions for future major repairs. It's usually billed monthly, quarterly, or annually and is set by the board based on the approved budget. A special assessment is a separate, additional charge levied outside the regular budget cycle, usually to cover an unexpected or underfunded cost: a major repair, a milestone inspection's Phase 2 findings, storm damage not fully covered by insurance, or a reserve shortfall the board didn't catch in time. Special assessments are the mechanism boards reach for when reserves weren't sufficient, which is exactly the scenario SIRS is designed to reduce for the ten covered structural components. For condo associations under ch. 718, the board generally has authority to levy special assessments without a membership vote unless the declaration says otherwise, though notice requirements apply under Fla. Stat. 718.112(2)(c) ^[1]. For details on process and owner rights, see HOA special assessment and, for insuring against the risk before it hits your unit owners, condo special assessment insurance.

Are HOA and condo special assessments tax deductible?

Generally, no, not for the individual unit owner, at least not as a straightforward personal deduction. Special assessments used for capital improvements (a new roof, structural repairs, elevator replacement) typically get added to the owner's cost basis in the property rather than deducted in the year paid, which can reduce capital gains tax when the unit is eventually sold. The IRS explains this basis treatment for improvements and assessments in Publication 523, which covers what increases the basis of a home you sell ^[5]. That's a basis question, not a deduction question, and it depends on the specific expenditure and the owner's tax situation. There are narrow exceptions. If the unit is a rental property, a portion of special assessments allocable to repairs (versus capital improvements) may be currently deductible as a rental expense, and capital improvement portions get depreciated; IRS Publication 527 covers rental property expense and depreciation rules ^[6]. If the assessment funds something with no capital improvement character (a lawsuit settlement, an operating deficit), tax treatment shifts again. This is genuinely a case where you need a CPA, not a blog post. Assessment tax treatment turns on how the money is spent, how it's characterized on the association's books, and whether the unit is a primary residence, second home, or rental. Don't rely on this article, or any other, to file your return on this one.

Which buildings actually fall under the milestone and SIRS requirements?

Milestone inspections under Fla. Stat. 553.899 apply to buildings that are three stories or more in height. Fla. Stat. 718.112, which governs SIRS, applies to condominium associations, but the SIRS requirement is specifically tied to buildings within the condo that are three stories or higher, per DBPR guidance implementing the 2022-2023 legislative changes ^{[1] [3]}. Single-family homes, duplexes, and low-rise HOA properties under three stories are outside the milestone/SIRS framework entirely, though nothing stops a prudent HOA board from commissioning a voluntary reserve study anyway; it's just not mandatory under these two statutes. Cooperatives (co-ops) are treated similarly to condos for these purposes; Fla. Stat. 719.106 incorporates comparable reserve and structural inspection obligations for cooperative associations ^[7]. Timeshares and some other ownership structures have their own quirks; ask your association's counsel if your building has a mixed-use or unusual ownership structure, because edge cases (a three-story building with a two-story wing, phased developments, buildings converted from apartments) genuinely do come up and the statute's application isn't always obvious from the plain text.

What should a board actually do in 2026: a practical checklist

Start with your CO date. If your building hit 30 years (or 25, if coastal) any time before now and you don't have a completed or scheduled milestone inspection, that's priority one; contact your local building department to confirm your exact filing deadline, because counties vary in how they notice buildings ^[3]. Next, get or update your SIRS. If your last structural reserve study is more than 10 years old, or you've never had one, you're more than risking a compliance gap, you're budgeting blind for the fiscal year that's already locked in full SIRS funding as a legal requirement ^[1]. Boards sometimes commission a combined milestone-plus-SIRS engagement with the same engineering firm, which can save time and money since a lot of the site work overlaps. Then work the numbers into your budget honestly. If full SIRS funding means a meaningful assessment increase, tell owners now, in writing, with the study attached, not at the annual meeting when it's already a done deal. Boards that communicate early get less pushback and fewer emergency special assessment fights later. Finally, know that legislative relief has been debated in Tallahassee session after session; some bills have proposed phasing SIRS funding in more slowly or allowing limited borrowing against future reserves for qualifying associations. None of that changes your obligations until it's signed into law. Check our Florida condo reserve fund relief tracker for the current legislative status, and confirm with your association's counsel before assuming any relief bill applies to your building. For boards juggling both deadlines on a tight volunteer schedule, a $199 one-time Board Compliance Kit (boarddeadline.com/board-kit-builder) organizes your building's specific milestone and SIRS deadlines, tracks documents, and schedules owner communication. It doesn't replace your licensed engineer or your association's attorney; nothing should. It just keeps the paperwork from becoming its own crisis.

What happens if a building misses its milestone inspection or SIRS deadline?

Local building officials enforce milestone inspection deadlines, and consequences vary by county but can include being placed on a non-compliance list, required corrective action plans, and in serious cases, restrictions tied to the certificate of occupancy. DBPR's guidance frames the requirement as safety-driven, not a paperwork formality, precisely because Surfside is the reason it exists ^[3]. For SIRS, the consequence is less about a building department citation and more about legal and financial exposure: a board that fails to obtain or fund a required SIRS can face owner lawsuits, difficulty selling units (many mortgage lenders and title companies now ask for SIRS status before closing), and a much bigger emergency assessment later when deferred structural problems finally surface. Either way, "we didn't know" isn't a great answer to give 200 unit owners at an emergency meeting. Track your dates now.

Frequently asked questions

What is a reserve study?

A reserve study is a professional analysis of an association's major common-area components (roofs, paving, structural systems, elevators, pools) that estimates remaining useful life, replacement cost, and the annual funding needed to pay for those repairs without a surprise special assessment. Florida condos must get a structural version, SIRS, covering ten specific components at least every 10 years.

What is a reserve study for an HOA?

For an HOA (a community governed by Fla. Stat. ch. 720, not a condo), a reserve study estimates the cost and timing of replacing shared assets like roads, clubhouses, pools, and fencing, then recommends an annual reserve contribution. Florida doesn't mandate HOA reserve studies by statute, but many declarations require one and it's considered best practice.

What is an HOA assessment?

An HOA assessment is the regular fee (monthly, quarterly, or annual) owners pay to fund the association's operating budget and reserve contributions. It's distinct from a special assessment, which is an extra, one-time charge levied to cover an unexpected cost or funding shortfall outside the normal budget.

How much should an HOA have in reserves?

There's no single dollar figure; it depends on your reserve study's calculation for your specific components. Industry shorthand generally considers 70%+ funded (actual balance versus the ideal for each component's age) as low-risk, 30-70% as moderate, and under 30% as high risk for a special assessment.

How much does a reserve study cost in Florida?

A general reserve study typically runs $3,000 to $15,000+, and a Florida SIRS, because it requires a licensed engineer or architect and covers structural components, often runs $5,000 to $20,000+ depending on building size and complexity. Get multiple quotes; there's no statewide fee schedule.

Are HOA or condo special assessments tax deductible?

Usually not as a direct deduction for the unit owner. Special assessments for capital improvements typically get added to your cost basis in the property (reducing capital gains tax at sale) rather than deducted the year you pay them, per IRS Publication 523. Rental property owners have different rules under Publication 527. Talk to a CPA about your specific situation.

When is a milestone inspection required in Florida?

At 30 years from the certificate of occupancy date, or 25 years if the building is within three miles of the coastline, and every 10 years after that, per Fla. Stat. 553.899. It applies to buildings three stories or more in height.

What is a SIRS and who has to get one?

A Structural Integrity Reserve Study (SIRS) is a Florida-mandated study of ten structural components (roof, load-bearing walls, primary structural members, floor, foundation, fireproofing, plumbing, electrical, waterproofing, and windows/doors) required for condo and co-op buildings three stories or higher, at least every 10 years, under Fla. Stat. 718.112.

Can a condo association waive SIRS reserve funding?

No. Starting with the fiscal year beginning on or after December 31, 2024, associations cannot waive or reduce funding below 100% for the ten SIRS structural components, and that money can't be repurposed for other uses. Non-structural reserve items can still be waived or underfunded by membership vote.

What's the difference between a milestone inspection and a SIRS?

A milestone inspection (Fla. Stat. 553.899) is a physical structural examination of the building performed by a licensed engineer or architect. A SIRS (Fla. Stat. 718.112) is a reserve funding study that determines how much money the association must save for the same categories of structural components. One is about the building's condition; the other is about the money to fix it.

Does Florida require reserve studies for all HOAs?

No. Florida statute doesn't mandate reserve studies for HOAs (ch. 720 communities) the way it mandates SIRS for condos (ch. 718). Many HOA governing documents require one anyway, and it's widely considered prudent financial practice even where not legally required.

What happens if a Florida condo building fails its milestone inspection?

If the engineer finds substantial structural deterioration during Phase 1, the building moves to a more invasive Phase 2 inspection. Depending on findings, the local building official can require a repair timeline; noncompliance can affect the building's standing with the county and, in serious cases, its certificate of occupancy status.

Sources

1. Florida Senate, Florida Statutes Chapter 718.112: SIRS requirements, ten structural components, no-waiver funding rule starting the fiscal year after Dec 31, 2024
2. Florida Senate, Florida Statutes Chapter 553.899: Milestone inspection 30-year/25-year coastal trigger, three-story threshold, Phase 1/Phase 2 process
3. Florida DBPR, Milestone Inspections guidance: Purpose of milestone inspections following Surfside, 30/25-year trigger, enforcement role of local building officials
4. Community Associations Institute, Reserve Funds fact sheet: Industry framework describing reserve funding health as a percent of fully funded
5. IRS Publication 523, Selling Your Home: Capital improvement assessments generally increase the cost basis of a home rather than being deducted the year paid
6. IRS Publication 527, Residential Rental Property: Rental property expense and depreciation treatment for repairs versus capital improvements
7. Florida Senate, Florida Statutes Section 719.106: Cooperative associations are subject to comparable reserve and structural obligations as condominiums