SIRS Compliance or Non-Renewal? The 2026 Board Member's Guide to Structural Reserves
By Ricardo Alonso, Founder, Atesa Risk Advisors · March 25, 2026 · Updated September 27, 2026
Key Takeaways
- For any budget adopted on or after December 31, 2024, owners in a Florida condominium association that must obtain a structural integrity reserve study (SIRS) may not vote to waive or reduce reserves for its eight components, with narrow statutory exceptions [1].
- Unit-owner-controlled associations that existed on or before July 1, 2022 had to complete the first study by December 31, 2025, or no later than December 31, 2026 when it is done with a milestone inspection due by that date [1].
- Since January 1, 2025, Citizens requires a current milestone or building-safety inspection report for association buildings that are three or more stories, have more than three units and are at least 30 years old, and private carriers ask for the same documents [3].
- Within 45 days after receiving the study, the association must give owners a copy or a notice that it is available and must report completion to the Department of Business and Professional Regulation (DBPR) [1].
- SIRS reserves may be funded by regular assessments, special assessments, lines of credit or loans; the last three need approval by a majority of the total voting interests, not only the board [1].
- Compliance supports the insurance submission, but nothing in the reserve statute promises a lower premium [1].
SIRS compliance in Florida has three parts: a completed structural integrity reserve study for every condominium building of three or more habitable stories, a budget that funds the reserves the study recommends, and a completion report to DBPR within 45 days [1]. Owners may not vote those reserves away in budgets adopted on or after December 31, 2024 [1]. Non-renewal is an underwriting outcome, not a penalty written into the reserve statute [1]. Citizens requires a current milestone or building-safety inspection report for older association buildings, and private carriers ask for the same documents [3].
The Grace Period Is Over: Mandatory SIRS Funding in 2026
Florida condo SIRS compliance in 2026 is no longer a planning exercise. It is a legal requirement with immediate insurance consequences. The Structural Integrity Reserve Study, created by Senate Bill 4-D in 2022 after the June 24, 2021 collapse of Champlain Towers South in Surfside [2], was designed to ensure that condominium associations set aside enough money to maintain the structural elements that keep buildings standing and residents safe.
For the first few years after the law passed, boards could still put reserve waivers to a unit-owner vote, kicking the financial can down the road. That option is closed for the SIRS components. Under Florida Statute 718.112(2)(f), for any budget adopted on or after December 31, 2024, the members of a unit-owner-controlled association (one the developer has turned over to the owners) that must obtain a SIRS may not vote to provide no reserves, or less reserves than required, for the items the study covers [1]. An association that waived under an earlier budget had to begin funding on January 1, 2026, according to DBPR [2].
HB 913 (chapter 2025-175, effective July 1, 2025) did not create that rule. For unit-owner-controlled associations that existed on or before July 1, 2022, it moved the deadline for the first study from December 31, 2024 to December 31, 2025, and it added ways to pay for the reserves [1][4]. An association with a milestone inspection (the structural inspection owed at 30 years of age, or 25 where the local agency requires it) due on or before December 31, 2026 may complete the study at the same time, but in no event after December 31, 2026 [1][12]. A separate provision lets an association that completes a milestone inspection delay a required study for up to two consecutive budget years while it funds the repairs [1].
The 8 Non-Negotiable Components
Your SIRS must study each of these items, to the extent the association is responsible for maintaining them [1]. The statute names the components; the right-hand column gives examples:
| # | Component | Examples |
|---|---|---|
| 1 | Roof | Full roof system including membrane, flashing, and drainage |
| 2 | Structural Systems | Load-bearing walls and other primary structural members, such as foundations, slabs, beams and columns |
| 3 | Fireproofing & Fire Protection | Sprinkler systems, fire-rated assemblies, alarm systems |
| 4 | Plumbing | Supply lines, drain lines, water heaters, risers |
| 5 | Electrical Systems | Main panels, distribution wiring, emergency generators |
| 6 | Waterproofing & Exterior Painting | Building envelope, sealants, exterior coatings |
| 7 | Windows & Exterior Doors | All common-element windows, sliding doors, entry systems |
| 8 | Other Items Over $25,675 | Any other item above the threshold, if failing to replace or maintain it would negatively affect items 1 to 7 |
The eighth category is the easiest one to miss. HB 913 raised its threshold from $10,000 to $25,000 and directed DBPR to adjust it for inflation each year; DBPR posted $25,675 for 2026 [4][5]. An item above that amount belongs in the study when failing to replace or maintain it would negatively affect the other seven components, as determined by the visual inspection [1]. This could include balcony railings, parking structures, seawalls, or elevator systems depending on your building.
The End of Unit-Owner Votes
The waiver vote is closed for SIRS items in any budget adopted on or after December 31, 2024, with narrow exceptions such as a vote to terminate the condominium [1].
Owners still vote on two things, and each takes a majority of the total voting interests of the association, meaning a majority of all owners' votes and not a board vote [1]. The first is how to pay: SIRS reserves may be funded by regular assessments, special assessments, lines of credit or loans, and the last three need that vote. The second is a temporary pause. For a budget adopted on or before December 31, 2028, an association that completed a milestone inspection within the previous two calendar years may pause or reduce reserve contributions for no more than two consecutive annual budgets to fund the repairs the inspection recommended, and it must obtain a new SIRS before contributions resume [1].
The study sets the amount. The simplest version of the math is the straight-line method in DBPR's reserve rule [6]:
$Annual\ Reserve\ Contribution = \frac{Estimated\ Replacement\ Cost - Current\ Reserve\ Balance}{Remaining\ Useful\ Life}$
For example, if your roof has an estimated replacement cost of $2,000,000, your current roof reserve balance is $400,000, and the remaining useful life is 10 years, your annual contribution for the roof alone would be $160,000. Multiply that calculation across all eight components and you begin to understand why some associations are facing significant budget increases. The law does not require the full replacement cost to be in the bank on day one: at a minimum, the study must recommend a baseline funding plan that keeps the reserve cash balance above zero in every budget year [1][2].
Why Your 2026 Insurance Renewal Depends on Your SIRS Report
If you think SIRS compliance is just a legal formality, consider this: underwriters now ask for your reserve study and your inspection reports when they decide whether to quote the building.
Carriers as Code Enforcers
Citizens enforces this through underwriting, not statute. Since January 1, 2025, Citizens requires the most current milestone or building-safety inspection report at new business, and when a building is added to a policy, for condominium and cooperative association buildings that are three or more stories, have more than three units and are at least 30 years old, and again every 10 years [3]. The enrolled HB 913 contains no Citizens provision [4], and the Citizens statute (FS 627.351) does not mention the SIRS [17]. A building that cannot produce the report has a submission problem with Citizens and with most private carriers.
Private carriers are following the same playbook. Expect a request for the completed SIRS, its funding schedule and, for an older building, the inspection report. DBPR also publishes a searchable list of the associations that have reported a completed study. It shows names and locations, not reserve balances [7].
Rate Mitigation Through Compliance
Here is the upside that many boards miss: a building that funds its reserves on the schedule in its study is an easier risk to place than one carrying deferred maintenance. There is no reliable percentage to attach to that. Nothing in the reserve statute promises a premium credit [1], and what a carrier charges depends on the building, its loss history and the market at renewal.
Think of your SIRS report as a negotiating tool. When your independent agent shops your condo association policy across multiple carriers, a current SIRS with reserves funded on schedule is strong evidence to put in front of an underwriter.
Fiduciary Duty in the Age of HB 1021
The financial stakes of SIRS compliance are significant. The legal stakes for individual board members may be even higher.
Personal Liability for Directors
Under Florida Statute 718.111(1)(a), the officers and directors of a condominium association have a fiduciary relationship to the unit owners [8]. If they willfully and knowingly fail to complete a SIRS, the failure is a breach of that fiduciary relationship, and an officer or director must sign an affidavit acknowledging receipt of the completed study [1].
This matters for your personal exposure. Directors and Officers (D&O) insurance, the liability policy that covers board members for claims made against them, has exclusions; the Insurance Information Institute lists fraud, personal profiting and bodily injury or property damage among the standard ones [10]. If your board knowingly ignores a SIRS requirement, ask how those exclusions would apply before you assume a claim is covered.
HB 1021 (chapter 2024-244) took effect July 1, 2024 [9]. It requires directors to complete at least four hours of education covering milestone inspections and structural integrity reserve studies [1], and since January 1, 2026 an association with 25 or more units must post specified official records on a website or app [8][9]. The message from Tallahassee is clear: board service comes with real legal obligations, and ignorance is not a defense.
The DBPR Digital Oversight Portal
As of July 1, 2024, a condominium association must send a completed SIRS Reporting Form to the Division of Condominiums, Timeshares and Mobile Homes within 45 days after it receives the study, and give each unit owner a copy or a notice that the study is available [1][7]. By October 1, 2025, all associations were required to create an online account with the DBPR, where the form is now filed [7]. Starting October 4, 2026, DBPR's amended reserve rule adds an Affidavit of Acknowledgement (DBPR Form 6000-11) signed by an officer or director [6].
This database is not just a filing cabinet. Lenders, insurers and buyers can search DBPR's public list to see whether your association has reported a completed SIRS [7]. A missing study also surfaces at sale: a sale contract entered into after December 31, 2024 must state that a required study has not been completed, and a buyer is entitled to the most recent study [11].
3 Steps Your Board Can Take This Week
Compliance does not have to be overwhelming. Here are three concrete actions your board can take immediately to protect the association and its members:
| Step | What to Do | Why It Matters | Estimated Time |
|---|---|---|---|
| 1. Verify your DBPR filing | Log into your association's DBPR online account and confirm your SIRS Reporting Form was submitted within 45 days after the association received the study. Check that all data matches your actual study. | DBPR's public database displays only complete submissions, so an incomplete form leaves the building off the list that insurers, lenders and buyers can search [7]. | 30 minutes |
| 2. Run a reserve funding gap analysis | Compare your 2026 adopted budget against the SIRS funding schedule for all 8 components. Identify any shortfalls by component. | Knowing exactly where your gaps are lets you prioritize and create a realistic funding plan before your next insurance renewal. | 2 hours |
| 3. Request a premium impact review | Send your current SIRS report and reserve schedule to an independent insurance agent for a coverage and premium assessment. | A complete, current file lets an agent present the building to more carriers. An agent who specializes in condo and HOA insurance can tell you where the file is thin before an underwriter does. | 15 minutes to send |
Free Download: Download our SIRS Board Meeting Agenda Template (PDF) — a 3-page structured agenda your board can use to ensure every SIRS-related action item is addressed at your next meeting, from DBPR filing verification to reserve funding votes to insurance renewal preparation.
Need help translating your SIRS into an insurance strategy? Call us at (904) 900-5063 or request a free quote — we specialize in Florida condo and HOA insurance.
What's Changing in 2026: Market Trends Affecting Condo Associations
The SIRS mandate does not exist in a vacuum. Several broader market forces are compounding the pressure on Florida condo associations in 2026.
Hurricane Exposure Keeps Underwriting Tight. NOAA counts 121 hurricane direct hits on Florida from 1851 through 2024, about 40% of the national total and more than any other state [13]. Deferred maintenance on the roof, waterproofing and windows is harder to explain to a carrier once a reserve study and an inspection report are on file.
Social Inflation Is Hitting Liability Lines. Social inflation is the industry's term for claim costs that rise faster than general inflation because of litigation. The Insurance Information Institute counts third-party litigation funding among its drivers and names directors and officers liability among the lines that bear the brunt [14].
Fannie Mae and Freddie Mac Are Tightening Standards. For loan applications dated on or after January 4, 2027, both raise the minimum reserve allocation in a condo project's budget, in a full project review, from 10% to 15% of annual budgeted assessment income [15][16]. A lender that relies on a reserve study instead must see the study's highest recommended funding amount in the budget, and a baseline funding plan no longer qualifies [15]. These are lending standards, not statutes, but they sit on top of Florida's SIRS mandate.
Frequently Asked Questions
Q: Can we use a Milestone Inspection in place of a SIRS?
A: No. A milestone inspection is a two-phase structural inspection of the building; a SIRS is a reserve study that sets a funding plan for eight components [1][12]. A milestone inspection performed within the past five years that meets the SIRS requirements may replace only the study's visual inspection [1].
Q: What if our building is only 2 stories tall?
A: The SIRS requirement does not apply to buildings under three stories in height. The budget must still carry reserves for roof replacement, building painting, pavement resurfacing and any item above the reserve threshold, unless the owners vote to waive them. The SIRS test is three habitable stories, as determined by the Florida Building Code [1].
Q: Can we use a loan instead of a special assessment to fund SIRS reserves?
A: Yes. Under HB 913, reserves for SIRS items may be funded by regular assessments, special assessments, lines of credit or loans. A special assessment, line of credit or loan requires approval by a majority of the total voting interests of the association, not only the board [1][4].
Q: What happens if our association does not complete the SIRS by the deadline?
A: A willful and knowing failure to complete the study is a breach of the officers' and directors' fiduciary relationship to unit owners [1]. Citizens requires a current milestone or building-safety inspection report for association buildings that are 30 years or older, and private carriers ask for the same documents [3].
Q: What is the deadline to complete a SIRS in Florida?
A: Unit-owner-controlled associations that existed on or before July 1, 2022 had to complete the study by December 31, 2025. An association with a milestone inspection due on or before December 31, 2026 may complete both together, but in no event after December 31, 2026 [1].
Q: How often does the SIRS need to be updated?
A: At least every 10 years after the condominium's creation. An updated study is also required before the board adopts a budget whose reserve funding does not align with the study's funding plan [1].
Q: Will SIRS compliance actually lower our insurance premiums?
A: Not by itself. Nothing in the reserve statute promises a premium credit [1]. A completed study and reserves funded on schedule keep the building eligible with more carriers, and an independent agent who specializes in condo insurance can use that file to shop the market.
Related Reading
- Small Building, Big Deadlines: The 2026 Survival Guide for 25-50 Unit Condo Boards — Where SIRS fits in the broader compliance and insurance picture for boutique 25-50 unit boards.
- 5 Red Flags Your Association is Overpaying for Insurance in 2026 — The full master-policy audit framework, including how funded SIRS reserves are credited at renewal.
- How to Lower Your Condo HOA Insurance in Duval County: The 2026 Market Guide — the Jacksonville-specific playbook for moving off Citizens to a private admitted carrier in 2026.
- How to Lower Your Condo HOA Insurance in Collier County: The 2026 Post-Ian Market Guide — the Gulf Coast counterpart for Naples, Marco Island, and inland Collier boards navigating the post-Ian admitted market.
- How Much Loss Assessment Coverage Can You Actually Buy in Florida? The $2,000 Reality (2026) — the unit-owner side of the SIRS story: why reserve and structural assessments are uninsurable at any limit.
- Your Condo Association's Master Policy Was Non-Renewed: The Florida Unit Owner's Guide (2026) — what unit owners face when the compliance problem this guide describes reaches the building's insurance.
- Florida Condo Association Fidelity Bonds and Crime Coverage: What the Law Requires in 2026 — the reserves SIRS forces you to accumulate are the balances the fidelity bond has to cover; how to size it.
How Atesa Risk Advisors Can Help
Navigating SIRS compliance and its insurance implications requires more than just completing the study. It requires translating that study into an insurance strategy that protects your building, your residents, and your board members.
As an independent insurance agency with access to 40+ A-rated carriers, Atesa Risk Advisors specializes in Florida condo and HOA insurance. We work every day with carriers that make underwriting decisions based on SIRS data, and our founder, Ricardo Alonso, brings a construction background to insurance, so we read your SIRS report for its structural findings as well as its financial ones. We will review your report and shop those carriers before your next renewal.
Is your 2026 budget SIRS-compliant? Get your free quote and consultation at atesariskadvisors.com/get-quote or call (904) 900-5063.
Sources
[1] Florida Statutes 718.112: Bylaws (annual budget and reserves; structural integrity reserve study)
[2] Florida DBPR, Condominium Information and Resources: FAQs
[4] The Florida Senate: CS/CS/HB 913 (2025), chapter 2025-175
[5] Florida DBPR: Reserve Threshold
[6] Florida Administrative Code, Rule 61B-22.005: Reserves
[7] Florida DBPR: SIRS Reporting and Database
[8] Florida Statutes 718.111: The association
[9] The Florida Senate: CS/CS/CS/HB 1021 (2024), chapter 2024-244
[10] Insurance Information Institute: Directors and Officers insurance
[12] Florida Statutes 553.899: Mandatory structural inspections for condominium and cooperative buildings
[13] NOAA Atlantic Oceanographic and Meteorological Laboratory: Hurricane FAQ
[14] Insurance Information Institute: How legal system abuse drives social inflation
[15] Fannie Mae: Lender Letter LL-2026-03 (March 18, 2026)
[16] Freddie Mac: Guide Bulletin 2026-C
[17] Florida Statutes 627.351: Insurance risk apportionment plans
Ricardo Alonso is the Founder of Atesa Risk Advisors, a Florida independent insurance agency specializing in commercial and condo/HOA insurance. Licensed 2-20 General Lines Agent and 2-15 Health & Life Agent, with a construction background that brings unique insight to structural reserve and compliance-related insurance challenges.