What a board can change before the next application arrives

This is a paperwork problem more than a policy one, and the paperwork is where non-compliance will show up.

• The application form. Any ARC submission checklist listing “copy of your building permit” among the items required for the application to be considered complete is now unenforceable as a gating condition. Move it, if you want it at all, to a condition of final approval or of commencing work.
• The completeness letter. Template correspondence returning an application as incomplete for want of a permit should be withdrawn. A refusal to review is exactly what the statute prohibits.
• Published guidelines. Architectural guidelines and community handbooks that recite the permit-first sequence need the same edit. These are the documents owners rely on, and they will outlive the form.
• Review clocks. Where governing documents give the committee a fixed period to act, confirm that period now runs from a submission that contains no permit. An association that treats the clock as never having started because the permit is missing has effectively reimposed the prerequisite.

What else is in HB 803, and why associations are still affected

The rest of the act is building-permit process law rather than community-association law: permit expiration under ss. 125.56 and 553.79, uniform permit applications under s. 553.77, and private-provider inspections under s. 553.791. Associations are touched by that machinery not as regulators but as applicants — most obviously when the association itself pulls permits for milestone-driven structural repairs.

That connection is more than incidental this year. Section 553.899(11), as amended in 2025, now requires every county and municipality to adopt an ordinance obliging repairs for substantial structural deterioration to be commenced “within 365 days” of the local enforcement agency receiving a phase two milestone inspection report — with an unsafe-occupancy review if proof is not submitted. An association working that clock is a permit applicant on a deadline.

The wider context: this is the only one

Something worth stating plainly, because it is easy to assume otherwise from the volume of coverage. This single paragraph is the only substantive amendment to Chapter 720 — Florida's Homeowners' Association Act — enacted in either the 2025 or the 2026 regular session.

The 2025 session produced no substantive Chapter 720 legislation at all; the only 2025 citations across the entire chapter come from the reviser's bill, which made editorial corrections. The 2026 session produced three chapter laws touching associations: this one, the Chapter 617 nonprofit rewrite (Ch. 2026-168), and a reviser's bill (Ch. 2026-14). The complete 2026 Laws of Florida index — 241 chapters — contains no chapter titled “Condominium,” “Cooperative,” “Homeowners' Associations” or “Community Associations.”

The marquee HOA bill of the session, HB 657, passed the House 108-2 and died in Senate Rules. So for homeowners' associations specifically, the 2026 session amounts to this one sentence about permits.

What to watch next

Two adjacent restrictions failed this session and are worth knowing about, because owners may cite them as though they had passed. HB 657 would have barred an HOA or its architectural committee from requiring “that a specific type of material be used on the building or rebuilding of a roof,” conditioned on the result appearing “substantially identical in shape and color” and the materials meeting ASCE 7-22 standards. It died. So did the statewide accessory-dwelling-unit mandate in SB 48, which passed the Senate 38-0 and expired in House Messages — and the ADU language was stripped from the affordable-housing bill that did become law.

Architectural authority over roofing materials and ADUs therefore remains where it was: in the recorded covenants.