Florida SIRS Compliance Guide (2026): HB 913, the 8 required components, and the December 31, 2025 deadline.

Florida's Structural Integrity Reserve Study (SIRS) requirement was the legislative answer to Surfside. Three years and one amendment later, the rules are clearer — and the deadline is real. Here's what every condo board needs to know going into 2026.

1. The post-Surfside rule, in one paragraph

After the 2021 collapse of Champlain Towers South in Surfside, the Florida legislature passed Senate Bill 4-D, codifying a new flavor of reserve study specifically for the structural systems that, when neglected, can fail catastrophically. The rule lives at Florida Statutes § 718.112(2)(g) for condominiums and § 719.106(1)(k) for cooperatives. It applies to buildings of three or more habitable stories, mandates an inspection of eight specific structural components, prescribes how reserves for those components must be funded, and locks the resulting balances away from being waived by a vote of unit owners.

HB 913, signed into law in 2025, refined the original rule — but it did not soften it. The deadline moved, the documentation requirements grew, and the funding floor became stricter.

2. What HB 913 changed (the 2025 amendments)

If you read a SIRS guide written before mid-2025, several details are now stale. Here's what changed:

The deadline extension was the headline change, but the substantive shift is the baseline funding plan requirement. Before HB 913, an association could legally show a funding schedule where the SIRS balance dropped to zero in year 7 because a major replacement was scheduled in year 8 and the next assessment would refill the pot. That's no longer allowed. The reserve cash for SIRS components must remain positive at every point in the projected funding period.

3. Who needs a SIRS in 2026

The applicability test is simple but easy to misread:

• Residential condominium associations with buildings of three or more habitable stories.
• Cooperative associations with buildings of three or more habitable stories (mirror requirement under F.S. § 719.106(1)(k)).
• The three-story threshold counts habitable floors only. A building with two residential floors stacked over a parking deck and a mechanical penthouse is not a three-story building for SIRS purposes — under HB 913's clarified definition.

Three categories of property are outside the SIRS rule entirely: standalone single-family HOAs (governed by Chapter 720, which has its own reserve rules), commercial-only condos, and timeshare associations. If you're a Florida property manager juggling a mixed portfolio, the cleanest sorting question is "is this a residential condo or co-op with at least three floors of living space?" — if yes, SIRS applies.

4. The 8 required components

Every SIRS must cover the same eight structural categories, plus any other component over $25,000 that affects those systems. Here's the list with practical notes on what each one captures:

1. Roof — the entire roofing assembly: membrane or tile, underlayment, drainage, flashing, parapets. Reserve funding tracks the eventual full replacement, not annual repairs.
2. Load-bearing walls and primary structural members — the columns, beams, slabs, and bearing walls that carry the building. Includes concrete repair, steel corrosion remediation, post-tensioning.
3. Floor and roof framing systems — joists, trusses, slabs. Often packaged with the load-bearing assessment.
4. Plumbing systems — supply lines, drain/waste/vent, hot-water risers, common-area fixtures. Pipe replacement at end-of-life is the typical big-ticket item.
5. Electrical systems — the primary service, distribution panels, common-area circuits, life-safety wiring.
6. Fire protection systems — sprinkler systems, alarm panels, smoke control, standpipes. Includes the eventual replacement of the wet-pipe sprinkler system itself, not just inspection costs.
7. Waterproofing and exterior painting — joint sealants, exterior coatings, the entire weather barrier of the building.
8. Windows and exterior doors — all glazing and entry assemblies on the building envelope.

The catch-all clause — "any other item required to be inspected by the engineer that costs more than $25,000" — sweeps in things like cooling towers, elevators in some configurations, and parking garage repairs that didn't fit neatly into the eight named buckets.

5. The SIRS funding "lockbox"

This is where SIRS departs most sharply from traditional condo reserves. Under the standard Chapter 718 reserve rules, unit owners can vote to waive or reduce reserve contributions — and many associations historically did, deferring the expense to future owners. SIRS reserves cannot be waived.

For budgets adopted on or after December 31, 2024, the association must:

• Track SIRS reserve balances separately from any other reserves or operating funds.
• Use SIRS funds only for the eight structural components they were designated to repair or replace. A roof reserve cannot be redirected to plumbing without an affirmative re-categorization that itself complies with the statute.
• Fund the SIRS components at least to the level recommended in the most recent SIRS study, subject to the new baseline-positive constraint added by HB 913.

If a board attempts to under-fund SIRS reserves below the study's recommendation — even with unit-owner approval — they expose themselves to the same enforcement and fiduciary risks as skipping the study entirely.

6. The baseline funding plan

HB 913's most consequential addition. Every SIRS must now include a "baseline" funding plan showing that the projected reserve balance for SIRS components stays above zero throughout the recommended funding period. In practice, that usually means a 30-year projection.

Before HB 913, an engineer could write a SIRS that showed the reserve dipping to negative $200,000 in year 12 — assuming a special assessment would cover the gap. That's no longer compliant. The baseline plan has to demonstrate continuous solvency, which generally requires either:

• Higher annual contributions than would otherwise be modeled, or
• A pre-scheduled special assessment that lands before the cash balance hits zero, not after.

For boards using software to model their SIRS, the practical implication is that the projection engine has to enforce the baseline-positive constraint when it solves for a recommended funding plan. Apex Reserve Studio handles this automatically when the Compliance Jurisdiction is set to Florida SIRS — the funding solver rejects any plan that drops below zero in any year of the projection.

7. New documentation: designer disclosure + board affidavit

Two paperwork additions that boards frequently overlook in the first year.

Designer / contractor disclosure

Any engineer, architect, or licensed contractor who performs a SIRS must disclose in writing — before they're hired — whether they also intend to bid on the repair or replacement work the SIRS identifies. The rule is meant to deter the obvious conflict of interest where a designer over-scopes findings to generate downstream work for themselves.

This doesn't prohibit the designer from bidding. It just requires written disclosure up front, and gives the association the opportunity to insist on independent bidders for the construction work.

Board affidavit

Once the SIRS is delivered, the association's directors and officers must sign an affidavit acknowledging their receipt of the completed report. The affidavit doesn't say "we agree with the findings" — it says "we received the document and acknowledge it." But it formalizes the moment at which the board's fiduciary clock starts: from the date of the affidavit forward, no director can credibly claim they didn't know about a flagged deficiency.

Best practice is to record the affidavit in the official records and reference it in the meeting minutes where the SIRS is reviewed.

8. The December 31, 2025 deadline — what happens if you miss it

The honest answer is that the immediate consequences of missing the deadline are administrative, not catastrophic. Florida's Department of Business and Professional Regulation (DBPR) doesn't sweep through and issue overnight fines. But the downstream exposure is real:

• Fiduciary liability. Directors who knew the deadline existed and failed to commission the study expose themselves to a breach-of-fiduciary-duty claim from unit owners. If a structural failure occurs after a missed SIRS, that claim becomes a serious case.
• Sale and refinance friction. Buyers' lenders and title insurers are increasingly demanding evidence of a current SIRS as part of condominium loan underwriting. Missing the study can functionally lock the building out of the resale market.
• Insurance underwriting. Property insurance carriers are using SIRS compliance as a signal of governance quality. A missed SIRS can drive premium increases or trigger non-renewal in the post-Surfside hardened market.
• DBPR investigation. Complaints from owners or third parties can trigger an investigation, and the resulting administrative orders are part of the building's public record.

9. Practical compliance checklist for 2026

If you're checking SIRS off as a board agenda item this year, here's the minimum work in order:

1. Confirm applicability. Is this a residential condo or co-op of three or more habitable stories? If yes, proceed. If no, you're not subject to SIRS (but Chapter 718's standard reserve rules still apply).
2. Retain a qualified engineer or architect. The SIRS must be performed by a licensed Florida engineer or architect. Get the HB 913 designer-disclosure statement in writing before the contract is signed.
3. Cover all 8 components plus any $25k+ catch-all items. Cross-check the engineer's scope against the list above; missing a category is the most common rejection ground.
4. Insist on a baseline-positive funding plan. If the engineer's recommended plan shows the reserve dipping to zero or negative at any point, push back. That plan no longer complies with HB 913.
5. Record the board affidavit. Sign and file the receipt affidavit, reference it in the next board meeting minutes, and add the document to the association's official records.
6. Update the reserve schedule. Move SIRS components into a tracked-separately reserve account. For budgets adopted on or after December 31, 2024, these dollars cannot mingle with general reserves.
7. Calendar the 10-year update. SIRS must be refreshed at least every ten years. Set a recurring board agenda item for the 9-year mark.