The Structural Integrity Reserve Study — SIRS — is one of two new obligations Florida's SB 4-D created for condominium and cooperative associations in buildings of three stories or higher. The other is the milestone inspection. The two requirements are connected: the milestone inspection tells the board what structural deficiencies exist today, and the SIRS tells the board what it will cost to address them over the next maintenance cycle — and requires the association to actually fund those reserves. House Bill 913 extended the original SIRS completion deadline from December 31, 2025 to December 31, 2026. No further extensions have been enacted. The reserve-funding obligations that the SIRS establishes, however, began January 1, 2026 regardless of whether a given association had completed its study.
What a SIRS is and who must get one
A Structural Integrity Reserve Study is a formal reserve analysis, performed by a licensed engineer or architect, that identifies the primary structural components of a building, estimates the remaining useful life of each component, and calculates the funding required to repair or replace them on schedule. Under Florida Statute § 718.112(2)(g), condominiums and cooperatives in buildings of three stories or higher must have a SIRS completed and must fund reserves in accordance with it. Single-family communities, two-story buildings, and associations governed by Chapter 720 (homeowners associations for single-family homes) are not subject to the SIRS requirement. If the building is a condominium or co-op at three stories or higher, the requirement applies.
What the study must cover
Florida statute specifies the components that must be included in the SIRS: the roof; load-bearing walls and primary structural members; floors; the foundation; fireproofing and fire protection systems; plumbing; electrical systems; waterproofing and exterior painting; windows; and any other item with a deferred maintenance or replacement cost that exceeds a threshold set in the statute (currently $10,000). The study must include a visual inspection of the building, a component-by-component condition assessment, a projected replacement or repair schedule, and a calculated reserve amount for each component. A reserve study that does not include the structural envelope — concrete, post-tensioning, waterproofing — does not satisfy the SIRS requirement. Many associations have older reserve studies that predate SB 4-D; those studies are almost certainly not SIRS-compliant and cannot substitute for the required study.
The reserve-funding obligation that is already in effect
The obligation to fund reserves in accordance with the SIRS began January 1, 2026 — regardless of whether the SIRS is finished. Florida law no longer permits condominium associations subject to the SIRS requirement to vote to waive or reduce reserves for the structural components the study covers. That vote — which many associations used for decades to keep annual assessments low — is no longer an option for covered components. Associations that have not completed their SIRS are currently required to fund structural reserves but have no completed study telling them what the correct funding level is. The December 31, 2026 deadline exists so that situation is resolved. Missing it does not suspend the funding obligation; it just leaves the association without the study that should be driving it.
What happens if the SIRS is not completed by December 31, 2026
Failure to complete the SIRS by the statutory deadline exposes the association and its individual board members to civil liability and potential enforcement action by the Florida Department of Business and Professional Regulation. Associations that complete milestone inspections but fail to complete the SIRS are in partial compliance only — the milestone inspection and the SIRS are separate requirements. Boards should consult their association attorney on the specific liability exposure applicable to their building and governing documents. This is not a scenario where the practical risk is low and the consequence is a paperwork fine.
What boards should be doing right now
- Confirm whether the building is subject to the SIRS requirement (three stories or higher, condominium or cooperative)
- Determine whether the association already has a SIRS on file — and whether it was completed to the SB 4-D statutory standard (many pre-2022 reserve studies are not)
- If no SIRS or a non-compliant study: commission a licensed engineer or architect to perform the SIRS now — eight months is enough time if you start today, but not if you wait until October
- Confirm with the association's CPA or financial advisor whether the current reserve-funding schedule reflects the SIRS obligations that began January 1, 2026
- If the milestone inspection Phase 1 or Phase 2 has already been completed: share those findings with the SIRS preparer — the inspection report and the reserve study should be aligned