Florida's 2022 condominium safety legislation — enacted in response to the Champlain Towers South collapse — created two new mandatory requirements that every HOA board and property manager needs to understand: the milestone inspection and the Structural Integrity Reserve Study (SIRS). These are separate requirements with different scopes, different timelines, and different consequences for non-compliance. Here's a practical guide to both.
Requirement 1: The Milestone Inspection (FS 553.899)
The milestone inspection is a structural assessment of the building performed by a Florida-licensed architect or engineer. It is required for all residential condominium and cooperative buildings three or more stories tall. The first inspection is triggered at 30 years of building age — or 25 years for buildings within three miles of a coastline, or in Miami-Dade or Broward County. After the first inspection, it's required every 10 years.
The inspection has two potential phases. Phase 1 is a visual inspection of all major structural components. If Phase 1 finds no substantial structural deterioration, the process is complete. Phase 2 is required only if Phase 1 finds substantial deterioration, and involves physical testing of structural components. Most buildings require Phase 1 only.
The inspecting engineer prepares a written report and an "inspector-prepared summary" in plain language. The association must distribute the summary to all unit owners within 45 days and post it on the association's website. The report must be submitted to the local building department.
Requirement 2: The Structural Integrity Reserve Study (FS 718.112)
The SIRS is a comprehensive assessment of the building's major structural and common area components, combined with a financial reserve funding analysis. It is required for all condominium associations with buildings three or more stories tall, and must be completed every 10 years. The structural component must be performed by a Florida-licensed engineer or architect. The financial component is typically performed by a reserve specialist or CPA.
The SIRS covers 11 statutory components: roof, load-bearing walls, floors, foundation, fireproofing systems, plumbing, electrical, waterproofing and exterior painting, windows, balconies and elevated structures, and any other item with a deferred maintenance cost exceeding $10,000 that affects structural integrity.
The Reserve Funding Rule Change — This Is the Big One
Before 2022, condominium associations could vote to waive or reduce reserve funding requirements. Under the new law, associations that do not have a current SIRS on file cannot waive reserve funding for the components covered by the SIRS. This is a major financial and governance change. Many associations that previously operated with minimal reserves are now required to fund reserves at the levels specified in the SIRS. This affects unit owner assessments and association budgets significantly.
Deadlines and Enforcement
The first SIRS was required to be completed by December 31, 2024 for existing buildings. Associations that missed this deadline are out of compliance. For the milestone inspection, the deadline depends on your building's age and location — if your building has reached its trigger age and has not had an inspection, contact a licensed engineer immediately. Local building departments are actively enforcing these requirements, and non-compliance can result in fines and building closure orders.
Can the Same Engineer Do Both?
Yes. A Florida-licensed engineer or architect can perform both the milestone inspection and the structural component of the SIRS. Pineland Engineering offers combined-scope engagements that cover both requirements in a single mobilization, reducing total cost and minimizing disruption to residents. The financial component of the SIRS must be performed by a reserve specialist or CPA.
Miami-Dade's Additional 40-Year Recertification
Miami-Dade County has a separate 40-year building recertification program administered by Miami-Dade's Department of Regulatory and Economic Resources (RER). This covers both structural and electrical components and is separate from the statewide milestone inspection. Many Miami-Dade buildings are subject to all three requirements simultaneously: the milestone inspection, the SIRS, and the 40-year recertification. Pineland Engineering coordinates all three in a single engagement for Miami-Dade clients.
What Should Your HOA Board Do Right Now?
First, determine your building's age and whether it has reached its milestone inspection trigger. Second, confirm whether a current SIRS is on file. If either is missing or overdue, engage a licensed engineer immediately. Third, review your association's reserve funding plan to ensure it aligns with the new SIRS requirements. Pineland Engineering can assess your building's compliance status and provide a timeline and cost estimate for completing both requirements.
Pineland Engineering serves condominium associations throughout Florida:
Get a free quote from Pineland Engineering — milestone inspections and SIRS for Florida condominium associations.
Get a Free Quote