What a SIRS must actually contain

A study delivered before 1 July 2025 may no longer be compliant, because HB 913 rebuilt the content requirements. A SIRS must now:

• cover the roof; structure; fireproofing and fire protection; plumbing; electrical; waterproofing and exterior painting; windows and exterior doors; and any other item whose deferred maintenance or replacement cost exceeds the indexed threshold;
• recommend a funding schedule based on a baseline funding plan;
• separately identify any recommended reserves for items where reserves are not required;
• account for how the association is actually funding — assessments, loan or special assessment; and
• be updated before the association adopts a budget that departs from the study's plan.

The visual inspection may only be performed by specified design professionals or licensed contractors, and an officer or director must sign an affidavit acknowledging receipt of the completed study — which is itself now an official record.

The catch-all threshold is no longer a flat number. HB 913 raised it from $10,000 to $25,000 and required the Division to index it annually to the Consumer Price Index. DBPR has now published the first adjustment: the 2026 threshold is $25,675, against $25,000 for 2025, with the 2027 figure due by 1 February 2027. A study or budget still working from a flat $25,000 is using a superseded number.³

The consequences of missing each deadline are different

Missing the SIRS is a fiduciary matter first. Section 718.112(2)(g)10 provides that a willful and knowing failure “is a breach of an officer's or director's fiduciary relationship to the unit owners under s. 718.111(1).” It also has two collateral effects that boards routinely miss: it disqualifies the association from applying for a My Safe Florida Condominium inspection or grant, because s. 215.55871(2)(b) conditions eligibility on compliance with s. 553.899 and s. 718.112(2)(g) and (h); and DBPR may demand the study through the association's online account “within 5 business days of a request.”

Missing the milestone is a building-official matter. Where a phase two report exists and repairs have not been scheduled or commenced within 365 days, the local enforcement agency “must review and determine if the building is unsafe for human occupancy.”

The engineer bottleneck, and the disclosure rule that governs it

OPPAGA recorded 1,587 extensions granted across 2024 and 2025, largely because associations could not find available engineers. A board contracting now should know two things about how that market is regulated.

First, the extension under s. 553.899(3)(c) is available only where the owner “has entered into a contract with an architect or engineer.” The signed engagement is the precondition.

Second, s. 553.899(12) now requires a licensed architect or engineer bidding to perform a milestone inspection to disclose in writing any intent to bid on services arising from it. A design professional or licensed contractor bidding on the resulting repair work may not have a direct or indirect interest in the inspecting firm, or be a relative within the third degree of consanguinity of someone who does, unless disclosed in writing. Failure to disclose makes the services contract voidable, terminable on the association's written notice, and exposes the professional to discipline. The same regime applies to SIRS providers.

Put the disclosure in the RFP and obtain it before award. It is the association's unilateral exit if the relationship surfaces later.

If the deadline cannot be met

Being blunt: there is no statutory relief from the 31 December 2026 SIRS wall. What exists is relief on the funding side, and it is worth using rather than confusing with an extension.

Reserves for SIRS items may be funded by regular assessments, special assessments, lines of credit or loans, with a majority of the total voting interests. A SIRS-obligated association “may secure a line of credit or a loan to fund capital expenses required by a milestone inspection… or a structural integrity reserve study,” and once funded the board may draw without further member approval. Note the sizing trap: the facility “must be sufficient to fund the cumulative amount of any previously waived or unfunded portions” as well as the current study — which for a long-waiving association is a much larger number than the repair estimate.

Separately, s. 718.112(2)(g)9 lets an association delay a required SIRS for no more than the two consecutive budget years immediately following a milestone inspection. Read that against the 31 December 2026 wall before relying on it.

What to watch next

Nothing is coming from Tallahassee before the deadline. The 2026 session amended s. 553.899 not at all — its text is identical to 2025's — and SB 722, which would have exempted shorter buildings and restored a reserve waiver, died in committee. The 2027 session convenes 2 March 2027, three months after the wall.

The near-term variable is the rule rather than the statute: Rule 61B-22.005, F.A.C., which would implement s. 718.112(2)(f) and incorporate two new DBPR forms — the SIRS form 6000-10 and the Affidavit of Acknowledgement 6000-11 — is still in rulemaking, with a Notice of Change published 31 July 2026.