Florida SIRS Compliance 2026: The Critical Guide to Non-Waivable Condo Reserves

Updated October 2026. This guide reflects Chapters 718 and 719, Florida Statutes (2026), as amended through HB 913 (Ch. 2025-175), and the Division of Florida Condominiums, Timeshares and Mobile Homes' amended Rule 61B-22.005, F.A.C., effective October 4, 2026. The 2026 legislative session did not change the SIRS law: the SIRS bills filed in 2026 (including SB 722) died in committee. This is a plain-language summary, not legal advice. Confirm your association's obligations with Florida counsel.

The rules for managing condominiums and cooperatives in Florida have changed for good. If your association governs a building that is three habitable stories or more, the state now requires a Structural Integrity Reserve Study (SIRS) and reserve funding for the structural items it identifies, and owners can no longer vote to waive that funding.

This guide explains who must comply, when the deadlines hit, what changed in 2026, and why board members face personal liability for non-compliance.

Looking for a partner on your SIRS or reserve plan? See how SmartProperty’s Florida team helps condominiums and HOAs plan and fund their reserves.

What's New in Florida (2026)

DBPR's SIRS Rule Is Now in Effect (Rule 61B-22.005, Effective October 4, 2026)

The Division adopted an amended reserves rule that turns the SIRS statute into day-to-day requirements. The main changes:

Mandatory state form. Every SIRS, including updates and amendments, must be completed on the current DBPR Form 6000-10, Structural Integrity Reserve Study (SIRS) Form (effective August 2026). Studies prepared in a firm's own format alone no longer meet the rule.
Three kinds of study. The rule recognizes a Full SIRS, an Update with Site Visit, and a Financial Update Without Site Visit. Only a Full SIRS covering every statutory item satisfies the 10-year requirement.
When an update can skip the site visit. An association may update the reserve schedule without a new visual inspection if the last SIRS with a visual inspection was completed within the preceding 36 months and the update only changes funding amounts or replacement costs. A change in funding method (special assessment, line of credit or loan) also does not need a new inspection.
When a site visit is required. A new visual inspection is required after any incident or disaster that may reasonably affect the building's structure or life-safety systems. An item whose remaining useful life changed because it was repaired or replaced must be inspected in the next SIRS.
Triggers for an updated SIRS. The association must get an updated study if its projected year-end reserve balance differs from the SIRS projection by 50% or more of its most recent annual reserve contributions, or if any repair or replacement happens more than two years earlier or later than the SIRS schedule.
What counts as "completed." A SIRS is complete when it is signed, dated and delivered by the professional or firm that performed it. Drafts circulated for board review do not count. Material amendments restart the owner distribution and Division notice requirements.
Online filing. The association files the notice of completion and the Affidavit of Acknowledgement (DBPR Form 6000-11) through its DBPR online account, and submits the SIRS Reporting form for every initial and amended study.
No editing the findings. The association must fund reserves according to the most recent SIRS and may not alter the study's remaining useful lives, costs or other determinations.
Funding formulas and accounting changes. The rule spells out the straight-line and pooled formulas, bans balloon payments and back-loaded pooled schedules, and lets a board switch between pooled and straight-line accounting without an owner vote only if no reserves are reduced, repurposed or waived.

Still moving: On October 22, 2026, the Division proposed a further amendment to Rule 61B-22.005 clarifying adjustments to the annual reserve funding amount and switches between pooled and straight-line accounting. Comments are open through November 12, 2026.

2026 Reserve Threshold: $25,675

HB 913 raised the threshold for "other" reserve items from $10,000 to $25,000 and indexed it to inflation. The Division's posted threshold for 2026 is $25,675. Items whose deferred maintenance or replacement cost exceeds the threshold must be reserved for.

Final SIRS Deadline: December 31, 2026

Unit-owner-controlled associations that existed on or before July 1, 2022 had to complete their first SIRS by December 31, 2025. An association whose milestone inspection is due by December 31, 2026 may complete the SIRS together with it, but in no event may the SIRS be completed after December 31, 2026.

1. Is a Reserve Study Required or Recommended in Florida?

The answer depends entirely on the type of association and the structure you manage.

➡️ Condominium & Cooperative Associations (COA/Co-op)

STATUS: Required and Non-Waivable

For buildings of three habitable stories or more, the Structural Integrity Reserve Study (SIRS) is mandatory under Florida Statutes Chapters 718 and 719 (s. 718.112(2)(g) for condominiums). The association must have a SIRS completed at least every 10 years.

For budgets adopted on or after December 31, 2024, unit owners can no longer waive or reduce reserve funding for the structural components identified in the SIRS. The only exception is a multicondominium association using an alternative funding method approved by the Division.

Exempt buildings: buildings under three habitable stories, residential buildings of one to four family dwellings with three or fewer habitable stories, and portions of a building not submitted to condominium ownership or maintained by someone other than the association.

➡️ Homeowners Associations (HOA)

STATUS: Recommended (Traditional Reserves)

Homeowners Associations (HOAs) governed solely by Chapter 720 are not subject to the SIRS requirements. A traditional reserve study is still the best way to avoid large, unpredictable special assessments.

HOAs retain the ability to waive or reduce reserves by a majority vote of the membership.

2. Key Deadlines and Study Cadence

Boards and property managers should track these dates. Willfully and knowingly failing to complete a required SIRS is a breach of the board's fiduciary duty.

Action item	Requirement
First SIRS completion	December 31, 2025 for unit-owner-controlled associations existing on or before July 1, 2022 (extended by HB 913)
Combined with milestone inspection	Allowed if the milestone inspection is due by December 31, 2026. No SIRS may be completed after December 31, 2026
SIRS waivers end	Budgets adopted on or after December 31, 2024
Full SIRS cadence	At least every 10 years. Updates without a site visit only within 36 months of the last visual inspection
Annual budget	Reserve funding for SIRS items must match the most recent SIRS
Owner distribution	Within 45 days of receiving the completed SIRS, deliver a copy to each owner or notify owners it is available
DBPR notice and affidavit	Within 45 days, file notice of completion and the Affidavit of Acknowledgement (Form 6000-11) through the DBPR online account, plus the SIRS Reporting form
Rule 61B-22.005	Effective October 4, 2026. All studies on DBPR Form 6000-10

3. Scope of the SIRS: What Elements Must Be Covered?

The SIRS is based on a visual inspection of the property. A full SIRS requires a site visit. Under Rule 61B-22.005, only limited financial updates within 36 months of the last visual inspection can be done without one. A milestone inspection completed within the previous five years can substitute for the SIRS visual inspection.

The SIRS covers the following items whose failure would affect the safety and integrity of the building:

Component	What it covers
Roof	Roofing systems and components
Structure	Load-bearing walls and primary structural members and systems
Fireproofing & fire protection	Fireproofing and fire protection systems
Plumbing	Plumbing systems
Electrical systems	Electrical systems
Waterproofing & exterior painting	Exterior envelope waterproofing, sealants and painting
Windows & exterior doors	Windows and exterior doors
Other major items	Any other item with a deferred maintenance or replacement cost above the reserve threshold ($25,675 in 2026) whose failure would negatively affect the items above

For each item, the study must state the estimated remaining useful life and the estimated replacement cost or deferred maintenance expense, and provide a recommended annual reserve amount. At a minimum, the funding schedule must be a baseline plan that keeps the reserve balance above zero, and it must reflect the association's actual funding method (assessments, line of credit or loan).

4. Who Is Qualified to Perform Your SIRS? (Independence Rules)

The SIRS must be performed or verified by:

Licensed Engineer (under Chapter 471, F.S.).
Licensed Architect (under Chapter 481, F.S.).
Certified Reserve Specialist (RS) from the Community Associations Institute (CAI).
Professional Reserve Analyst (PRA) from the Association of Professional Reserve Analysts (APRA).

⚠️ Critical Independence Requirement

HB 913 added conflict-of-interest rules for anyone who performs a SIRS or milestone inspection.

A design professional or licensed contractor who bids to perform a SIRS must disclose in writing if they intend to bid on any repair or replacement work the study recommends.
Anyone with a direct or indirect interest in the firm performing the study, or a relative of such a person, must disclose it to the association in writing. An undisclosed conflict makes the contract voidable and can lead to professional discipline.

Boards and property managers should collect these disclosures during the RFP process.

5. Funding Compliance: Non-Waivable Reserves & Financial Restructuring

The funding rules are the most consequential part of the law.

Non-Waivable SIRS Funding

For budgets adopted on or after December 31, 2024, reserve funding for SIRS items cannot be waived or reduced by owner vote and must follow the most recent SIRS. The statutory floor is a baseline funding plan that keeps the reserve balance above zero. SIRS reserves may be used only for their authorized purposes.

Curing Deficits: Special Assessments, Loans and Lines of Credit

Reserves may be funded by regular assessments, special assessments, lines of credit or loans. Special assessments, lines of credit and loans require approval by a majority of the total voting interests.
An association may secure a line of credit or loan for milestone inspection or SIRS work. The funds must be immediately available to the board for those purposes.
Any change in funding method must be reflected in an updated SIRS. Under Rule 61B-22.005, an update that only changes the funding method does not need a new site visit.
These options are not available to developer-controlled associations, associations within their first year of owner control, or associations controlled by a bulk assignee or bulk buyer.

Temporary Pause After a Milestone Inspection

For budgets adopted on or before December 31, 2028, an association that completed a milestone inspection in the prior two calendar years may, with approval of a majority of the total voting interests, pause or reduce reserve contributions for up to two consecutive annual budgets to pay for the repairs the inspection recommended. A SIRS must be performed before reserve contributions resume.

Separately, if the local building official declares the building uninhabitable after a natural emergency, the board may pause reserve contributions without an owner vote until the building is habitable again.

Pooled Reserves

SIRS reserves may be funded using the pooled method, and the board may switch between pooled and straight-line accounting without an owner vote. Rule 61B-22.005 adds the guardrails: no reserve balance may be reduced, repurposed or waived in the switch, and pooled schedules cannot use balloon payments or defer contributions to keep current assessments low.

6. The Ultimate Risk: Fiduciary Duty and Marketability

Non-compliance affects both the board's liability and the property's financial health.

Board Member Fiduciary Breach

Willfully and knowingly failing to complete a required SIRS is a breach of the officers' and directors' fiduciary duty to unit owners. Officers and directors must also sign an affidavit acknowledging receipt of the completed SIRS.

Board members usually have protection under the Business Judgment Rule, but a knowing failure to comply with this specific mandate can expose them to personal liability. Since 2024, DBPR also has broader enforcement powers over condominium associations.

The Fannie Mae / Freddie Mac Impact (Market Risk)

Compliance is essential to keeping units financeable. Fannie Mae and Freddie Mac review condominium budgets and reserves closely.

Fannie Mae's New 15% Reserve Rule (Lender Letter LL-2026-03)

This is a federal lending rule, not a Florida law, but it decides whether buyers of condominium units in Florida can get conventional financing. Fannie Mae issued Lender Letter LL-2026-03 on March 18, 2026, and Freddie Mac made matching changes.

15% reserve minimum. For loan applications dated on or after January 4, 2027, the association's budget must allocate at least 15% of assessment income to replacement reserves, up from the long-standing 10%.
A stricter reserve study alternative. An association below the minimum can still qualify with a reserve study completed or updated within the past three years, but only if its budget funds the study's highest recommended contribution. Baseline funding is no longer accepted.
Full project reviews. For loan applications dated on or after August 3, 2026, lenders can no longer use the streamlined Limited Review, so most condo loans now get a full review of the budget and reserves.

Boards that want owners to keep access to conventional financing should plan to budget at least 15% of assessment income for reserves, or fund the highest plan in a current reserve study. Read more: New Fannie Mae & Freddie Mac Rules Are Coming. Is Your Community Ready?

Associations that fail to complete the SIRS or fail to fund the required reserves may be flagged as ineligible for conventional financing. That can limit sales to cash buyers and push unit values down.

7. Action Plan: Your 2026 Compliance Checklist

Confirm your SIRS is complete, or will be by December 31, 2026 at the latest, and that it is on DBPR Form 6000-10.
File with DBPR through your online account within 45 days: notice of completion, the Affidavit of Acknowledgement (Form 6000-11), and the SIRS Reporting form.
Distribute the SIRS to owners, or notify them it is available, within 45 days.
Fund the 2027 budget to the SIRS. SIRS items cannot be waived, and the amounts must match the study.
Watch the update triggers: a 50% gap between actual and projected year-end reserves, a project more than two years off schedule, or a disaster affecting the building.
Check the 15% lender test. For loan applications on or after January 4, 2027, budget at least 15% of assessment income for reserves or fund the highest plan in a current reserve study.
Plan for the next full SIRS within 10 years of the last one.

Florida Reserve Law FAQ

Did the 2026 Florida legislative session change the SIRS requirement?

No. The SIRS bills filed in 2026, including SB 722, died in committee. The most recent statutory changes are from HB 913 (Ch. 2025-175), effective July 1, 2025. The 2026 change came from DBPR's amended Rule 61B-22.005, effective October 4, 2026.

What is the deadline to complete a SIRS in Florida?

The first SIRS was due December 31, 2025 for unit-owner-controlled associations existing on or before July 1, 2022. Associations combining the SIRS with a milestone inspection due by December 31, 2026 may finish with it, but no SIRS may be completed after December 31, 2026.

Can a SIRS be updated without a site visit?

Yes, in limited cases. Under Rule 61B-22.005, a financial update without a site visit is allowed if the last visual inspection was within 36 months and the update only changes funding amounts or replacement costs, or only reflects a new funding method. The 10-year requirement can only be met by a full SIRS.

Do Florida SIRS reports have to use a state form?

Yes. Since Rule 61B-22.005 took effect on October 4, 2026, every SIRS, update and amendment must be completed on DBPR Form 6000-10.

What is the Florida condo reserve threshold for 2026?

$25,675. Items whose deferred maintenance or replacement cost exceeds the threshold must be reserved for. The Division adjusts it each year for inflation.

Can Florida condo owners still vote to waive reserves?

Not for SIRS items in budgets adopted on or after December 31, 2024. Owners can still waive or reduce reserves for non-SIRS items by a majority of the total voting interests. A temporary two-budget pause after a milestone inspection is available for budgets adopted through December 31, 2028.

Does Fannie Mae's 15% reserve rule apply in Florida?

Yes. It is a federal lending rule, so it applies to Florida condominiums alongside the SIRS law. For loan applications dated on or after January 4, 2027, the budget must allocate at least 15% of assessment income to reserves, or fund the highest recommended contribution in a reserve study completed or updated within three years.

Need help with your Florida association? SmartProperty has Florida-based staff and years of experience with Florida condominiums and HOAs. Learn how we can help, or request a proposal.