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SIRS and Milestone Inspection Checklist: The Structural Compliance Calendar for Condominiums and Cooperatives

The structural compliance calendar for Florida condominiums and cooperatives: milestone inspection triggers, SIRS components and deadlines, and what follows.

Two separate obligations run on two separate clocks. The milestone inspection is a building safety inspection under § 553.899, tied to the building's age and enforced by the local building official. The structural integrity reserve study is a budgeting exercise under § 718.112(2)(g) or § 719.106(1)(k), tied to a fixed statutory date. They interact, but missing one does not excuse the other.

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Work the milestone questions first, because a completed milestone inspection changes what the association may do about the reserve study and about reserve funding. Then work the SIRS section. For background on the underlying rules see our pages on milestone inspection requirements, the structural integrity reserve study, and SIRS for cooperatives.

Does the building need a milestone inspection, and when

  • Habitable stories, not floors. A ground-level parking level that is not habitable may not count, and the answer changes the entire obligation. Get it from the engineer in writing.§ 553.899(3)(a)
  • Section 553.899 reaches buildings under Chapter 718 or Chapter 719. An HOA-governed building is outside it.§ 553.899(3)(a)
  • § 553.899(3)(a)
  • § 553.899(3)(a)
  • The local enforcement agency may make that determination based on local circumstances including environmental conditions such as proximity to salt water. In Lee, Collier and Charlotte Counties that question is not theoretical. Do not assume 30 years applies to a coastal building.§ 553.899(3)(b)
  • Buildings that reached 30 years before July 1, 2022 were due by December 31, 2024. Buildings reaching 30 years between July 1, 2022 and December 31, 2024 were due by December 31, 2025. An association that has done nothing is already late, not merely approaching a deadline.§ 553.899(3)
  • Phase one must be completed within 180 days after the owner receives that written notice. The clock starts on receipt, not on the deadline year.§ 553.899(6)

Phase one and phase two

  • A general contractor, a roofer or a reserve specialist may not perform the milestone inspection.§ 553.899(7)(a)
  • § 553.899(7)(a)
  • Phase two is required if any substantial structural deterioration is identified in phase one. Boards that price only phase one find themselves procuring again under time pressure.§ 553.899(7)(b)
  • The definitions in § 553.899(2) matter here. Ask the engineer to use the statutory terms rather than adjectives.
  • § 553.899(7)(b)
  • § 553.899(7)(b)
  • § 553.899

Repairs, distribution and reporting

  • Commence, not complete. But 365 days is not long once design, permitting and procurement are counted, and the funding vote has to happen inside it.§ 553.899(11)
  • § 553.899(9)
  • § 553.899(9)
  • This is the milestone report specifically. It is a separate obligation from the general 30-day website posting rule for official records.§ 553.899(9)
  • § 718.111(12)(a)15.
  • The association is not the reporting party for this, but the data the county sends is the data a regulator will hold about your building.§ 553.899(13)(a)
  • All condominium associations were required to create and maintain an online account with the Division on or before October 1, 2025. Among the information the Division may require is a copy of any structural integrity reserve study, within 5 business days after a request.§ 718.501(3)

The structural integrity reserve study

  • § 718.112(2)(g); § 719.106(1)(k)1.
  • § 718.112(2)(g)
  • Seven named components. A study missing one of them is not a compliant study, whatever the vendor calls it.§ 718.112(2)(g); § 719.106(1)(k)1.
  • The threshold is $25,000, raised from $10,000 by HB 913 in 2025, or the Division's inflation-adjusted amount if greater. A study built to the old $10,000 figure sweeps in items the statute no longer reaches; one built to a higher number may miss items it does.§ 718.112(2)(g); § 719.106(1)(k)1.
  • § 718.112(2)(g)8.
  • This is an express statutory requirement in both chapters and it is the item most often missed. It sits in the same subparagraph that makes a willful and knowing failure to complete the study a breach of fiduciary duty.§ 718.112(2)(g)10.; § 719.106(1)(k)10.
  • § 718.112(2)(g)11.; § 719.106(1)(k)11.
  • Two separate 45-day obligations run from the same date: one to the owners and one to the Division.§ 718.112(2)(g)12.; § 719.106(1)(k)12.
  • § 718.111(12)(a)11.d.; § 719.104(2)

The deadlines, and the one that differs by chapter

Condominium (Ch. 718)Cooperative (Ch. 719)
SIRS deadline for associations existing on or before July 1, 2022 and under owner controlDecember 31, 2025December 31, 2024
Outside date, no SIRS may be completed afterDecember 31, 2026December 31, 2026
Authority§ 718.112(2)(g)7.§ 719.106(1)(k)7.
Delay after a milestone inspectionUp to 2 consecutive budget yearsUp to 2 consecutive budget years
Officer or director affidavit of receiptRequiredRequired
Statement to the Division within 45 daysRequiredRequired
  • The cooperative date is a full year earlier than the condominium date. A cooperative board working from a condominium article or a vendor's condominium calendar is already past its deadline.§ 719.106(1)(k)7.
  • § 718.112(2)(g)7.
  • The outside date is the same for both. It is the one date on this checklist with no exception attached to it.§ 718.112(2)(g)7.; § 719.106(1)(k)7.
  • § 718.112(2)(g)7.
  • The delay exists so the association can put its money into the repairs the milestone inspection recommended. It is a choice the board makes and should minute, not something that happens automatically. It does not move the December 31, 2026 outside date.§ 718.112(2)(g)9.; § 719.106(1)(k)9.
  • A willful and knowing failure by the officers or directors to complete a structural integrity reserve study is a breach of fiduciary duty to the unit owners. Evidence of diligence is what distinguishes late from willful.§ 718.112(2)(g)10.

What the study does to the budget

  • For a budget adopted on or after December 31, 2024, the members of a unit-owner-controlled association that must obtain a structural integrity reserve study may not vote to provide no reserves, or less reserves than required, for the items listed in the SIRS paragraph. The old majority waiver no longer reaches those items.§ 718.112(2)(f)2.; § 719.106(1)(j)
  • Use for other purposes requires approval in advance by a majority vote of all the total voting interests of the association.§ 718.112(2)(f)2.
  • § 718.112(2)(f)2.c.(I)
  • The loan must be sufficient to fund the cumulative amount of previously waived or unfunded reserve contributions plus the most recent study, must be immediately available to the board without further member approval, and must be disclosed in the annual financial statement and to prospective purchasers.§ 718.112(2)(f)2.c.(II)
  • It requires approval of a majority of the total voting interests, runs no more than two consecutive annual budgets, and may be used only to fund repairs recommended by the milestone inspection.§ 718.112(2)(f)2.e.
  • The numbers in the study drive the reserve line items. A budget adopted without them will have to be amended.

Statutes and authorities referenced

  • § 553.899, Fla. Stat. (milestone inspections: triggers, phases, repairs, distribution and reporting)
  • § 553.899(3)(a), (3)(b), Fla. Stat. (three habitable stories, the 30-year deadline, the 25-year coastal determination)
  • § 553.899(7), Fla. Stat. (phase one and phase two)
  • § 553.899(9), Fla. Stat. (45-day distribution, posting and website publication)
  • § 553.899(11), Fla. Stat. (repairs commenced within 365 days)
  • § 718.112(2)(g), Fla. Stat. (condominium structural integrity reserve study, components and $25,000 threshold)
  • § 718.112(2)(g)7., 8., 9., 10., 11., 12., Fla. Stat. (deadlines, substitution, delay, affidavit, distribution, Division statement)
  • § 719.106(1)(k), Fla. Stat. (cooperative structural integrity reserve study and the December 31, 2024 deadline)
  • § 718.112(2)(f)2., Fla. Stat. (reserve funding, the waiver bar for SIRS items, lines of credit and the reserve pause)
  • § 719.106(1)(j), Fla. Stat. (cooperative reserves and the waiver bar for SIRS items)
  • § 718.111(12)(a)11.d., § 718.111(12)(a)15., § 719.104(2), Fla. Stat. (15-year retention of studies and inspection reports)
  • § 718.501(3), Fla. Stat. (Division online account)

Contact Hamilton Mikes

Hamilton Mikes advises Southwest Florida condominium and cooperative boards on milestone inspection and structural integrity reserve study compliance, engineering engagements, and the reserve and assessment decisions that follow a report. Call 239-594-7227 or visit our Regulatory Compliance page.

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