A live trap: the state's own free course does not count

The Division publishes a free, self-paced online course on its education page. Its own text says:

“this course is made available as a resource and does not satisfy the Board Member Certification course requirements under Florida Statute.”²

Directors who took the state's free course in the reasonable belief that a course published by the regulator would satisfy the regulator's requirement are not certified. Under the rule above, the board must suspend them.

The Division maintains separate published lists of approved providers for certification and for continuing education. Those lists, not the free resource, are the place to verify.

The parallel condominium rule, rewritten four days earlier

Rule 61B-19.001, “Board Member Certification and Continuing Education Courses,” was amended effective 3 September 2026 — its first substantive change since 2015.³

For condominiums, the certification course is a Division-created course covering “milestone inspections, reserve studies, elections, recordkeeping, financial literacy, fines, and meeting requirements.” Continuing education focuses “primarily… on recent statutory changes to Chapter 718, F.S., and applicable rules of the Division during the previous education [year].” Providers apply on DBPR Form CO 6000-12, approval runs two years, and renewal must be filed within 90 days of expiry — with the consequence that “providers who fail to renew their provider status on a timely basis… shall not offer or advertise an approved BMC or CE course.”

Condominium and homeowners' association education now run on two parallel rules, a common form family, and a common 1 July to 30 June education year.

What a board can do this month

1. Re-verify every sitting director's certification against the approved-provider list, not against a certificate. Provider approval now lapses on a two-year clock, and a certificate issued by a provider whose status had lapsed is the obvious failure mode.
2. Ask specifically whether anyone relied on the free DBPR course. It is the single most likely source of an unwitting gap.
3. Decide, in advance and in the minutes, how a suspension will be handled. The rule directs suspension and permits the board to fill the vacancy temporarily. Working that out at the meeting where it first arises is how a compliance question becomes a governance fight.
4. Diarise the education year. It runs 1 July to 30 June, which is not the fiscal year most associations use.

Why a rule, when DBPR has almost no HOA jurisdiction

There is a genuine irony here worth naming. Six months before this rule took effect, the Division repealed Rule 61B-85.001 — its only other homeowners' association rule — effective 5 March 2026, on the stated ground that “the reporting requirement in 720.303(13) was repealed in 2017.” Chapter 61B-85 became an empty chapter.⁴

The Division's own position is that it “does not have authority to investigate complaints under Chapter 720.” Its Chapter 720 role is arbitrating election and recall disputes — and now approving the courses that certify directors.

So Florida's regulatory posture toward homeowners' associations is, at present, that the state will accredit the training of your board but will not investigate what your board does. The bill that would have changed that — SB 906, creating an HOA ombudsman with a toll-free hotline — died in committee this session without a hearing, as did SB 908, the per-parcel fee that would have funded it.

What to watch next

Two things. First, whether DBPR publishes an approved-provider list for HOA certification of any real depth — a rule requiring board members to take approved courses works only if approved courses exist in useful numbers, and provider approval under this rule opened in August 2026.

Second, the enforcement side for condominiums. A rule proposed on 31 July 2026 would give the Division citation authority with a penalty schedule that includes a new line item for “failure to complete board member education requirements.” That rule is proposed, not adopted. If it lands, condominium director education stops being a governance obligation enforced by the board and becomes an administrative penalty assessed per unit.