New Requirements for Condominium Associations from Florida House Bill 913: SIRS, Milestone & Reserves
Starting July 1, 2025, the new Florida House Bill 913 legislative updates for condominium associations will go into effect. These new changes are an “update” to last year’s Senate Bill 154 which legislated the Milestone Structural Inspections and Structural Integrity Reserve Study requirements mandated by the state of Florida for all condominium associations. The bill focuses on structural safety, transparency, and oversight in condominium associations. This new bill significantly impacts how condominium associations will plan for and fund major capital improvement projects. Outlined below are the relevant changes your association needs to know regarding the SIRS (Structural Integrity Reserve Study), Milestone inspections and Reserves, as well as The Falcon Group’s professional opinion/recommendations for the new requirements.
Building Applicability & Deadlines
- Applies only to buildings with three or more “habitable” stories (defined as spaces for living, sleeping, eating, or cooking).
- Exempts four‑unit dwellings with three or fewer habitable stories
- Deadline extended from December 31, 2024, to December 31, 2025, for existing, owner-controlled associations (pre‑July 1, 2022).
Enhanced SIRS Requirements
- Must include a baseline funding plan ensuring the reserve cash balance never drops below zero over the study period.
- Required to distinguish between mandatory reserve items (core structural components) and optional items.
Reserve Funding Flexibility
- Associations may fund reserves via special assessments, lines of credit or loans—with majority owner approval.
- Pooling of reserve accounts across multiple SIRS items is now allowed.
- Investment of reserve funds in CDs or deposits at banks/credit unions permitted without a vote.
Threshold Update & Inflation Adjustments
- The trigger for non-core “other items” inclusion is raised from $10,000 to $25,000, adjusted annually for inflation.
- Starting in 2026, and every year after, the Florida Division of Condominiums (within the DBPR) must publish online the inflation-adjusted cost threshold for any other item that has a deferred maintenance expense or replacement cost that exceeds $25,000 or the inflation adjusted amount determined by the division.
Milestone Inspection Coordination
- Allows associations that have completed the required milestone inspection to delay the SIRS for two consecutive budget years following a milestone inspection in order to prioritize funding for repairs and maintenance required from the milestone inspection. In other words, a temporary suspension.
- If reserve contributions are paused or reduced due to Milestone‑related repairs for up to two years, a new SIRS must be completed before resuming regular reserve funding.
Accountability & Compliance
- Conflict-of-interest disclosures are required: professionals bidding SIRS must disclose any intent to bid on related repair work; any undisclosed conflict makes the contract voidable
- Affidavit requirement: officers/directors must sign confirming receipt of the SIRS report.
From our perspective, there are a number of practical impacts of the new regulation.
1 - Completing the SIRS (Structural Integrity Reserve Study) can be delayed. Associations should be aware that delaying the SIRS will probably require higher funding requirements after the pause.
2 – Delaying funding the SIRS for Milestone related repairs may offer temporary relief; however, it may put more of a financial burden on the Association later on (see item 1)
3 – Habitable floor does not include any garage levels – these parts of the structure are exposed to environment and are vulnerable. Although not required to fund SIRS if you only have two habitable floors and a garage – it is in the Association’s best interest to consider funding as this is a critical component of the building.
4 – Some jurisdictions require that the same Engineer/Architect who performed the Milestone be in charge of the design and repairs. Although the law requires an Engineer to provide a notice of intent, it may be difficult for the Association to select a different engineer regardless of such notice.
5 – The new law provides for alternative funding. Even though this was not explicit in the law before, many Associations took the route of special assessments to assist with SIRS funding. Please note that many (if not all) banks at this point do not offer long term credit lines, or loans on projects that may start several years in the future.
The Falcon Group agrees that the new law does provide relief as well as alternatives to complying with the new requirements. However, the new changes may not be as much of a relief as has been written to be. Associations will still have to carefully approach how they meet these requirements and to consider the long-term financial impact of their decisions on their communities. The Falcon Group is committed to assisting these associations in navigating these new changes as well as complying with the requirements in a financially sustainable manner.
