This page is current through the 2026 regular session and reflects the 2026 Florida Statutes as of July 1, 2026. Reserve law for Florida condominiums and cooperatives was rebuilt in three steps: SB 4-D created mandatory structural reserves and the study in 2022, SB 154 refined them in 2023, and HB 913 raised the threshold, restricted waivers, allowed borrowing and added a temporary pause in 2025. The 2026 session changed none of it.
The arc in four sessions
This subject has a clean history, which is unusual. Four sessions did the work, and only three of them matter now.
| Session | Vehicle | Chapter law | What it did to reserves |
|---|---|---|---|
| 2026 | none | — | No reserve or SIRS bill passed. SB 104, Chapter 2026-14, is a reviser's bill whose only effect on § 718.112 is a citation. |
| 2025 | CS/CS/HB 913 | 2025-175 | Threshold to $25,000; waiver restricted for SIRS items; lines of credit and loans; the pause with a December 31, 2028 sunset; pooling confirmed; the receipt affidavit and the two 45-day duties. |
| 2023 | SB 154 | 2023-203 | Refined the study and the milestone requirement; adjusted thresholds and deadlines. |
| 2022 | SB 4-D | 2022-269 | Created the structural integrity reserve study at § 718.112(2)(g) and restricted the ability to waive reserves for the items it covers. |
Say the 2026 answer plainly, because boards ask it every June: nothing changed. The history line of section 718.112 in the 2026 edition ends with section 43 of Chapter 2026-14, the reviser's bill. There is no substantive 2026 amendment to the reserve or SIRS provisions.
2022: SB 4-D created the obligation
Chapter 2022-269 is the post-Surfside statute. For reserves it did two things at once. It created the structural integrity reserve study at section 718.112(2)(g), and it took away the tool most associations had been using to keep assessments flat, which was the annual reserve waiver.
The SIRS is not a reserve study in the ordinary sense. It is a specific, structurally focused inventory. Under section 718.112(2)(g)1., a residential condominium association must have a study completed at least every 10 years after the condominium's creation for each building on the property that is three habitable stories or higher as determined by the Florida Building Code, covering the roof; the structure, including load-bearing walls and other primary structural members and systems; fireproofing and fire protection systems; plumbing; electrical systems; waterproofing and exterior painting; windows and exterior doors; and any other item with a deferred maintenance expense or replacement cost above the threshold whose failure would negatively affect one of the listed items. Our page on the structural integrity reserve study goes through each component.
The study is based on a visual inspection of the property, and it must be performed or verified by an engineer licensed under Chapter 471, an architect licensed under Chapter 481, or a person certified as a reserve specialist or professional reserve analyst by the Community Associations Institute or the Association of Professional Reserve Analysts. At a minimum it must identify each item inspected, state the estimated remaining useful life and the estimated replacement cost or deferred maintenance expense of each, and provide a funding plan with a recommended annual amount that reaches the estimated cost by the end of the estimated remaining useful life.
2023: SB 154 adjusted the edges
Chapter 2023-203 refined both the milestone inspection requirement and the study, and adjusted thresholds and deadlines. It is the least dramatic of the three bills and the one boards remember least, which is appropriate. Nothing in it changed the basic architecture SB 4-D built: a mandatory study on a ten-year cycle, tied to buildings of three habitable stories or more, with reserves for the items it covers largely beyond the reach of a waiver vote.
The one SB 154 item worth a calendar note has nothing to do with reserves. It added section 718.1255(1)(d) and amended subsection (5) of that section with an effective date of July 1, 2027, not now. A board reading the current arbitration and presuit mediation provisions is reading a section that has a scheduled change already on the books.
2025: HB 913, the bill that changed the numbers
Chapter 2025-175 was approved June 23, 2025 and took effect July 1, 2025. It is the bill that governs your current budget.
The threshold moved. Under section 718.112(2)(f)2.a., reserves are required for roof replacement, building painting and pavement resurfacing regardless of the amount of deferred maintenance expense or replacement cost, and for any other item with a deferred maintenance expense or replacement cost exceeding $25,000, or the inflation-adjusted amount determined by the Division, whichever is greater. The old figure was $10,000. Raising it took a number of smaller components off the mandatory list, which is a real benefit and also a real risk: an item removed from the reserve schedule does not stop aging.
The waiver was restricted, not abolished. Section 718.112(2)(f)2.b. lets the members of a unit-owner-controlled association determine by a majority vote of the total voting interests to provide no reserves or less reserves than required. But for a budget adopted on or after December 31, 2024, the members of an association that must obtain a structural integrity reserve study may not do that for the items listed in paragraph (g). A multicondominium association may still do so if an alternative funding method has been approved by the Division. So the general waiver survives for non-SIRS items; it is the structural items that are locked.
Borrowing became an option. Section 718.112(2)(f)2.c.(I) provides that reserves for the paragraph (g) items may be funded by regular assessments, special assessments, lines of credit or loans, and that a special assessment, line of credit or loan under that sub-subparagraph requires the approval of a majority vote of the total voting interests. Sub-subparagraph (II) then addresses the specific case: an association that must have a study may secure a line of credit or loan to fund capital expenses required by a milestone inspection under section 553.899 or by the study, the facility must be sufficient to cover the cumulative previously waived or unfunded portions plus the most recent study, and the funding must be immediately available to the board without further member approval. The borrowing and the related details must appear in the annual financial statement delivered under section 718.111(13) and in the resale disclosure under section 718.503.
The pause is temporary. Section 718.112(2)(f)2.e. permits a board, for a budget adopted on or before December 31, 2028, where the association has completed a milestone inspection under section 553.899 within the previous two calendar years, and on the approval of a majority of the total voting interests, to temporarily pause reserve contributions or reduce the amount of reserve funding for no more than two consecutive annual budgets, for the purpose of funding repairs recommended by the milestone inspection.
Pooling was confirmed. Reserve accounts may be pooled, and a board may switch between pooled and straight-line accounting without a member vote. Our page on reserve funding requirements covers how the two methods behave in a funding plan.
The deadlines, and why they differ by chapter
This is the table to put in front of the board.
| Condominium | Cooperative | HOA | |
|---|---|---|---|
| SIRS required | Yes, buildings 3 habitable stories or higher | Yes, buildings 3 habitable stories or higher | No |
| Authority | § 718.112(2)(g) | § 719.106(1)(k) | § 720.303(6) |
| Completion deadline for associations existing on or before July 1, 2022 | December 31, 2025 | December 31, 2024 | n/a |
| Outside date | December 31, 2026 | December 31, 2026 | n/a |
| Study cycle | At least every 10 years | At least every 10 years | n/a |
| Reserve funding | Mandatory for listed items | Mandatory for listed items | Voluntary, established by member vote |
| Item threshold | $25,000 or the inflation-adjusted amount | $25,000 or the inflation-adjusted amount | n/a |
Section 718.112(2)(g)7. reads that associations existing on or before July 1, 2022 which are controlled by unit owners other than the developer must have a study completed by December 31, 2025 for each building three stories or higher; that an association required to complete a milestone inspection on or before December 31, 2026 may complete the study simultaneously with the inspection; and that in no event may the study be completed after December 31, 2026. The cooperative provision at section 719.106(1)(k) sets the corresponding date a full year earlier, at December 31, 2024, while keeping the same December 31, 2026 outside date. A cooperative board working from a condominium checklist has been working from the wrong date since 2024.
There is one lawful way to be late. Under section 718.112(2)(g)9., an association that completes a milestone inspection required by section 553.899, or an inspection completed for a similar local requirement, may delay performance of a required study for no more than the two consecutive budget years immediately following the milestone inspection, so it can put its financial resources into the repair and maintenance recommendations of that inspection. That is a delay of the study, not of the reserve obligation, and it does not move the December 31, 2026 outside date. Our page on SIRS for cooperatives covers the cooperative sequence.
What happens after the study arrives
HB 913 attached duties to the delivery of the report, and they run on short clocks.
- An officer or director must sign an affidavit acknowledging receipt of the completed structural integrity reserve study, under section 718.112(2)(g)10. That affidavit is an official record.
- Within 45 days after receiving the study, the association must distribute a copy to each unit owner, or deliver a notice that the completed study is available for inspection and copying on written request. Section 718.112(2)(g)11.
- Within 45 days after receiving the study, the association must provide the Division a statement that the study was completed and was provided or made available to owners. Section 718.112(2)(g)12.
- The study goes on the association's website or mobile application if the association is required to have one, and it is on the posting list at section 718.111(12)(g)2.
Section 718.112(2)(g)10. also states the consequence for skipping the study altogether: if the officers or directors willfully and knowingly fail to complete a study, that failure is a breach of the fiduciary relationship to the unit owners under section 718.111(1). That is a personal exposure sentence, and it is the reason this deadline gets treated differently from other budget deadlines. Our guide to budgeting for structural repairs covers how boards sequence the study, the budget and the assessment.
Where this leaves homeowners associations
Almost everything above is condominium and cooperative law. Chapter 720 does not require a structural integrity reserve study and does not mandate reserve funding for any category.
What Chapter 720 does is make reserves a creature of the membership. Under section 720.303(6), an association is deemed to have provided for reserve accounts upon the affirmative approval of a majority of the total voting interests, and upon that approval the board must include the reserve accounts in the budget for the next fiscal year. While a developer is in control, the developer may but is not required to include reserves. Once reserves exist in that form, section 720.303(6) provides that the funds and any interest accruing on them remain in the reserve accounts and are used only for authorized reserve expenditures unless their use for other purposes is approved in advance by a majority vote at a meeting at which a quorum is present.
The practical difference: a condominium board that underfunds structural reserves is out of compliance with a statute. An HOA board that underfunds is usually out of step with its own budget policy and its fiduciary duty, which is a different problem with a different remedy. Neither is comfortable, and neither goes away by being deferred. Our page on annual budget planning covers the sequence for both.
Frequently Asked Questions About Reserve and SIRS Legislation
Did the reserve rules change in 2026?
No. No reserve or SIRS bill passed the 2026 regular session. The only 2026 citation on section 718.112 is from SB 104, Chapter 2026-14, the reviser's bill, which is technical. Your reserve obligations are the ones HB 913 set on July 1, 2025.
Is the reserve threshold $10,000 or $25,000?
$25,000, or the inflation-adjusted amount determined by the Division, whichever is greater. HB 913 raised it from $10,000 in 2025. Roof replacement, building painting and pavement resurfacing are reserved regardless of amount, so the threshold only governs the other items.
Our cooperative missed the SIRS deadline. Which date applied to us?
December 31, 2024, under section 719.106(1)(k), if the cooperative existed on or before July 1, 2022 and is under owner control. That is a year earlier than the condominium date of December 31, 2025. The outside date is the same for both: no study may be completed after December 31, 2026. A missed deadline should go to counsel rather than be quietly caught up.
Can our members still vote to waive reserves?
For items not covered by the structural integrity reserve study, yes, by a majority of the total voting interests. For the items listed in section 718.112(2)(g), no: for a budget adopted on or after December 31, 2024, members of an association required to obtain a study may not vote to provide no reserves or less reserves for those items. A multicondominium may still do so with a Division-approved alternative funding method.
How long can we pause reserve contributions?
No more than two consecutive annual budgets, and only for a budget adopted on or before December 31, 2028, only where the association completed a milestone inspection within the previous two calendar years, only on the approval of a majority of the total voting interests, and only to fund repairs the milestone inspection recommended. The 2028 sunset is the condition most often left out of summaries.
Can the association borrow to fund structural work?
Yes. Reserves for the listed items may be funded by regular assessments, special assessments, lines of credit or loans, with a special assessment, line of credit or loan requiring a majority vote of the total voting interests. An association required to have a study may secure a line of credit or loan for milestone or study capital expenses, sized to cover previously waived or unfunded amounts plus the most recent study, and the funding must be immediately available to the board without further member approval.
Does our HOA need a structural integrity reserve study?
No. Chapter 720 requires no study and mandates no reserve funding. Under section 720.303(6) reserves exist once a majority of the total voting interests approves them, and after that the funds may be used only for authorized reserve expenditures unless the members approve another use in advance by majority vote at a quorate meeting.
Contact Hamilton Mikes
Hamilton Mikes advises condominium, cooperative and homeowners association boards in Lee, Collier and Charlotte Counties on reserve budgeting, structural integrity reserve study compliance, waiver and pause votes, and financing structural repairs. If your association is approaching a deadline or has already missed one, call 239-594-7227 or visit our Budgeting and Financial Reporting page.
Statutes and authorities referenced
- § 718.112(2)(f)2.a., Fla. Stat. (reserve items; the $25,000 or inflation-adjusted threshold; roof, painting and paving regardless of amount)
- § 718.112(2)(f)2.b., Fla. Stat. (waiver by majority of total voting interests; restriction for SIRS items for budgets adopted on or after December 31, 2024; multicondominium alternative funding)
- § 718.112(2)(f)2.c.(I), Fla. Stat. (funding by assessments, lines of credit or loans; majority of total voting interests)
- § 718.112(2)(f)2.c.(II), Fla. Stat. (line of credit or loan for milestone or SIRS capital expenses; sizing; immediate availability; disclosure under §§ 718.111(13) and 718.503)
- § 718.112(2)(f)2.e., Fla. Stat. (pause or reduce reserve contributions; budget adopted on or before December 31, 2028; milestone inspection within the previous 2 calendar years; no more than 2 consecutive annual budgets)
- § 718.112(2)(g)1., Fla. Stat. (SIRS required every 10 years; buildings three habitable stories or higher; the component list)
- § 718.112(2)(g)2.-4., Fla. Stat. (visual inspection; who may perform or verify; minimum contents and funding plan)
- § 718.112(2)(g)7., Fla. Stat. (December 31, 2025 completion; simultaneous completion with a milestone inspection; December 31, 2026 outside date)
- § 718.112(2)(g)9., Fla. Stat. (delay of up to 2 consecutive budget years after a milestone inspection)
- § 718.112(2)(g)10., Fla. Stat. (fiduciary breach for willful failure; officer or director affidavit acknowledging receipt)
- § 718.112(2)(g)11.-12., Fla. Stat. (45 days to distribute to owners; 45 days to report to the Division)
- § 718.111(12)(g)2., Fla. Stat. (the SIRS on the website posting list)
- § 718.111(13), § 718.503, Fla. Stat. (disclosure of borrowing in the financial statement and to purchasers)
- § 719.106(1)(k), Fla. Stat. (cooperative SIRS; December 31, 2024 completion; December 31, 2026 outside date)
- § 719.106(1)(j), Fla. Stat. (cooperative reserves and threshold)
- § 720.303(6), Fla. Stat. (HOA reserves established by majority of total voting interests; use restricted to authorized reserve expenditures)
- § 553.899, Fla. Stat. (milestone inspections, referenced throughout the reserve provisions)
- § 718.1255, Fla. Stat. (arbitration and presuit mediation; SB 154 change effective July 1, 2027)
- Session laws: Ch. 2022-269 (SB 4-D); Ch. 2023-203 (SB 154); Ch. 2025-175 (CS/CS/HB 913); Ch. 2026-14 (SB 104)