What Property Managers Need to Know About SIRS Requirements in 2026

If you manage a condo or co-op in Miami-Dade or Broward, SIRS is no longer a "coming soon" problem. The initial study deadline has already passed, full reserve funding is kicking in for 2026 budgets, and HB 913 reshaped a handful of rules that property managers thought they understood last year.

This post walks through what actually changed, what you're on the hook for in 2026, and where most buildings are quietly slipping out of compliance.

Quick Answer: The 2026 SIRS Snapshot

For Florida condominiums and cooperatives with buildings three or more habitable stories:

• The initial SIRS had to be completed by December 31, 2025 (extended from the old 2024 deadline by HB 913).

• Any budget adopted on or after that date must fully fund SIRS reserves. No waivers, no borrowing from these reserves for other purposes.

• The reserve threshold for required items is now $25,000 (up from $10,000), and starting February 1, 2026, it adjusts annually for inflation.

• Boards can now use special assessments, loans, or lines of credit to meet reserve obligations, with owner approval.

• A new SIRS is required every 10 years for the life of the building.

If any of those bullets caught you by surprise, keep reading.

What SIRS Actually Is (And Why It's Not Just Another Reserve Study)

A Structural Integrity Reserve Study is a visual inspection plus a long-term funding plan. It's narrower than a traditional reserve study because it only looks at the building components that affect structural safety, and it's stricter because you can't vote your way out of funding it.

Florida Statute 718.112(2)(g) lists eight components every SIRS must cover:

#	Component	What Property Managers Should Be Watching
1	Roof	Membrane condition, flashing, drainage
2	Load-bearing walls and primary structural systems	Cracking, spalling, rebar exposure
3	Fire protection systems	Sprinklers, standpipes, alarms
4	Plumbing	Risers, mains, pressure issues
5	Electrical systems	Service panels, feeders, grounding
6	Waterproofing and exterior painting	Coatings, sealants, membrane integrity
7	Windows and exterior doors	Frames, glazing, weatherproofing
8	Any other item over $25,000 whose failure affects the items above	Plaza decks, balconies, expansion joints, etc.

The last row is where a lot of buildings get caught off guard. A failing plaza-deck waterproofing system, for example, often costs well over $25,000 and directly threatens the load-bearing slab below. It has to be in the study.

The SIRS vs. Milestone Inspection Mix-Up

Property managers confuse these two all the time. They're different documents with different purposes, even though the same engineer often handles both.

	SIRS	Milestone Inspection
Governing statute	Fla. Stat. 718.112(2)(g)	Fla. Stat. 553.899
Purpose	Funding plan for structural reserves	Structural safety check
Trigger	3+ habitable stories, any age	Building reaches 30 years old (25 near coast in some jurisdictions)
Frequency	Every 10 years	Every 10 years after the first
Who performs it	Engineer, architect, or certified reserve specialist	Licensed Florida engineer or architect
Can they be combined?	Yes, if milestone is due by Dec 31, 2026	Yes, same date rule

If your building was due for a milestone inspection by December 31, 2026, the law let you do both at once. But the SIRS still could not be pushed past that date under any circumstances.

What HB 913 Changed (And Why It Matters in 2026)

HB 913 was signed in June 2025 and took effect July 1, 2025. A few changes are specifically relevant now:

1. "Three habitable stories," not just "three stories." A ground-level parking garage doesn't count as a habitable story. So a building with open parking below and two residential floors above may sit outside SIRS requirements. Worth double-checking with counsel before assuming, because ground-floor amenity space or a lobby can flip the calculation.

2. The $25,000 threshold. Items with a replacement cost under $25,000 are no longer required to be in the SIRS. Boards can still reserve for them, and many should, but the mandatory list got shorter. The Division of Condominiums indexes this threshold for inflation starting February 2026, which is estimated at roughly $25,675 for the year.

3. Alternate funding paths. Reserves don't have to come purely from monthly assessments anymore. With majority owner approval, associations can use special assessments, loans, or lines of credit. This doesn't reduce the obligation, it just gives boards options.

4. Conflict-of-interest disclosures. If the engineer performing your SIRS also wants to bid on the repair work that comes out of it, they now have to disclose that in writing. Contracts signed without this disclosure can be voidable.

5. Seven-year document retention, 15 years for SIRS and milestone reports. These two document types get a longer retention window than most association records.

The 2026 Funding Reality

Here's where it gets uncomfortable. Most Florida condos completed their first SIRS in late 2025, and reports came back with funding recommendations that are, in a lot of cases, two to four times higher than what the building had been collecting. That's the gap you're now closing.

A few things worth knowing:

• Funding cannot be waived. This is the rule property managers forget most often. Non-SIRS reserves can still be waived by majority vote. SIRS reserves cannot.

• Pooled reserves are still allowed, but SIRS items must sit in a structural pool that can't be cross-used for, say, clubhouse furniture.

• Temporary pauses exist but are narrow. If a building is declared uninhabitable after a natural emergency, or if the association is actively funding milestone-identified repairs, contributions can be paused for up to two budgets (through Dec 31, 2028) with proper approval.

• Board signature required. Under 2026 rules, board officers must sign an affidavit confirming receipt of the SIRS. That shifts transparency liability directly onto the board.

Missing a deadline or underfunding is now explicitly treated as a breach of fiduciary duty. Local building officials can declare a building "unsafe" for non-compliance.

Where Most Buildings Are Underprepared (Based on What We See)

Mersco Miami works on buildings across Miami-Dade and Broward that are right in the middle of post-SIRS reality. A few patterns we see repeatedly:

• Waterproofing listed as "fair" when it's actually failing. A visual SIRS inspection can miss moisture intrusion that's already past the coating and into the substrate. If your study flagged waterproofing as needing replacement in 7 to 10 years, it's worth a second look sooner rather than later.

• Stucco cracking treated as cosmetic. In South Florida's salt-air climate, hairline cracks on a high-rise are entry points for chloride intrusion. Once rebar starts corroding, you're no longer in repair territory. You're in structural restoration.

• Expansion joints left out of the plan. Joint sealants are often overlooked because individually they're cheap. Collectively, across a large building, they exceed $25,000 and they absolutely affect waterproofing and structural integrity.

• Painting deferred because "we just painted." Painting in a SIRS context isn't aesthetic. The exterior coating system is the first line of defense against moisture. A 10-year-old paint job that looks fine can still be letting water into the wall assembly.

If any of those sound familiar, it's worth getting a contractor's eyes on the building before the next budget cycle, not after.

A Practical 2026 Checklist for Property Managers

Use this as a quick audit:

• SIRS completed and filed in official association records

• SIRS distributed to unit owners (within 45 days of receipt)

• 2026 budget includes full SIRS reserve funding, unwaived

• Structural reserves accounted for separately from general reserves

• Board officer affidavit confirming SIRS receipt has been signed

• Document retention plan accounts for 15-year SIRS hold

• Any engineer or contractor quoting on SIRS-identified repairs has provided a conflict-of-interest disclosure

• Milestone inspection status confirmed (separate from SIRS, but linked)

• Funding source strategy documented (assessments, loan, line of credit)

• Next 10-year SIRS tentatively calendared

Miss two or more of those, and you should probably have a conversation with the board this quarter.

How Mersco Miami Fits Into SIRS Compliance

We're not the people who write your SIRS. That's an engineer's or reserve specialist's job. But four of the eight SIRS-covered components are directly in our wheelhouse:

• Waterproofing and exterior coatings for roofs, plaza decks, balconies, and exterior walls

• Concrete repair for spalling, structural slabs, columns, and load-bearing systems

• Stucco repair for exterior envelope restoration before coatings go back on

• Expansion and control joint sealants for the smaller line items that still cross the $25K threshold when bundled

When a SIRS lands on a property manager's desk with a long list of structural items needing attention over the next 10 years, the execution falls to contractors who know South Florida's climate, Miami-Dade and Broward building codes, and how to sequence work across occupied buildings.

FAQs

Does SIRS apply to HOAs? No. SIRS is only for condominiums and cooperatives governed by Chapters 718 and 719. HOAs under Chapter 720 follow general reserve study rules, not SIRS.

What happens if our building missed the December 31, 2025 deadline? You're non-compliant and exposed to fiduciary liability, fines, and potential action from the local building official. The practical fix is to commission a SIRS immediately and document the board's efforts to come into compliance.

Can we use our old reserve study to satisfy SIRS? Usually not. A standard reserve study doesn't meet the statutory requirements of SIRS, which has specific language, a specific component list, and a specific funding schedule. That said, a milestone inspection performed within the past five years that meets the statutory requirements can replace the visual inspection portion.

Who can perform a SIRS? A licensed Florida engineer, licensed architect, or a person certified as a reserve specialist or professional reserve analyst by the Community Associations Institute or the Association of Professional Reserve Analysts.

How much does a SIRS cost? Ranges vary widely. Smaller associations may land in the $5,500 to $11,000 range, while larger buildings or those with complex systems push into the $16,000+ territory. Coastal risk factors add cost.

Do we have to reserve for items with more than 25 years of useful life? Not for replacement cost, no. But if deferred maintenance is expected on that item, that amount should still be reserved.