Milestone inspections and SIRS: what Florida condo boards should know before repainting

A structural inspection by a licensed engineer or architect, required for condominium and cooperative buildings of three habitable stories or more at 30 years — 25 within three miles of the coast in Broward and Palm Beach [1][6][7]. Phase Two repairs must start within 365 days [1]. Waterproofing and exterior painting are a named SIRS reserve line [5].

Key numbers and dates

• Applies to condominium and cooperative buildings of three habitable stories or more; buildings of three or fewer stories serving one to four families are exempt [1]
• Inspection at 30 years from the certificate of occupancy, then every 10 years; a local agency may require 25 where salt water warrants it [1][2]
• Palm Beach County (unincorporated): 25 years within three miles of the coast, 30 elsewhere [6]
• Broward County: 25 years for condominiums and cooperatives of three or more stories within three miles of the coastline, 30 for general buildings [7]
• Phase One must be completed within 180 days of the written notice [1]
• Association notifies unit owners within 14 days of receipt, and distributes the report summary within 45 days [1]
• Repairs from a Phase Two report: commence within 365 days [1]
• SIRS: at least every 10 years; associations existing on or before July 1, 2022 had to complete one by December 31, 2025 [5][3]
• SIRS covers any item with a deferred-maintenance or replacement cost over $25,000 that affects structural integrity [5]
• Reserve waivers for SIRS items ended for budgets adopted on or after December 31, 2024; funding had to begin January 1, 2026 [5][2]

What a milestone inspection is

Section 553.899 defines it as a structural inspection of a building, by a licensed architect or engineer, to attest to the life safety and adequacy of the structural components of the building [1]. Two things follow from that wording, and boards get both wrong.

It is not a code-compliance inspection. The building is not being re-judged against today's code; it is being examined for whether its structure is sound.

And what the inspector is looking for is defined narrowly. "Substantial structural deterioration" means substantial structural distress or weakness that negatively affects the building's general structural condition and integrity, and the statute expressly excludes surface imperfections such as cracks, distortion, sagging, deflection, misalignment, signs of leakage or peeling of finishes — unless the inspector determines those signal deeper deterioration [1].

That last clause is where painting and waterproofing meet the statute. A stained, cracked, peeling wall is not itself substantial structural deterioration. It is frequently the visible end of something that is.

Who has to do one, and when

The statutory trigger is age: by December 31 of the year the building reaches 30 years, and every 10 years after that [1]. Age runs from the certificate of occupancy [2]. A local enforcement agency may set the first inspection at 25 years where environmental conditions, including proximity to salt water, warrant it [1] — and in South Florida that is not hypothetical.

Broward's Building Safety Inspection Program, adopted by the Board of Rules and Appeals in August 2024, states that the county inspection serves as compliance with the milestone inspection requirements of section 553.899, exempts one- and two-family dwellings, fee-simple townhouses and buildings under 3,500 sq ft, and explicitly includes parking garages, elevated decks, docks and guardrails [7][8]. Older municipal pages in Broward still describe the pre-2022 "40-year" recertification program; those thresholds no longer apply.

Phase One and Phase Two

Phase One is a visual examination of habitable and non-habitable areas, including the major structural components, and it has to be completed within 180 days of the written notice [1]. If the inspector finds no substantial structural deterioration, there is no Phase Two [1].

Phase Two is the invasive stage. It may use destructive or non-destructive testing, and it must include a timeline for the repairs it recommends [1]. The report itself has to bear the seal and signature — or electronic signature — of the licensed engineer or architect who performed it [1].

Around both sit the notice obligations that decide how much time a board actually has: the local enforcement agency notifies the association by certified mail, the association notifies unit owners within 14 days of receiving it, and distributes a summary within 45 days of receiving the inspection report [1].

The 365-day clock

Repairs recommended by a Phase Two report must be commenced within 365 days of the association receiving it [1]. If they are not, the local enforcement agency must review and determine whether the building is unsafe for human occupancy — and HB 913 (2025) requires county commissions to adopt ordinances enforcing that rule [1][3].

Broward runs a tighter schedule for its own program: owners have 90 days to submit the reports and a total of 180 days from the date of the Building Safety Inspection Report to complete repairs, with extensions possible [7].

For a board, the practical consequence is sequencing. Concrete restoration comes first, waterproofing and coatings follow it, and both have to fit inside a window that started when the report arrived — not when the budget was approved.

SIRS, and why painting is in it

The structural integrity reserve study is a separate requirement, in section 718.112(2)(g). It applies to residential condominium buildings of three habitable stories or higher, at least every 10 years, and it must cover [5]:

• the roof
• the structure, including load-bearing walls and primary structural members
• fireproofing and fire protection systems
• plumbing
• electrical
• waterproofing and exterior painting
• windows and exterior doors
• any other item with a deferred-maintenance or replacement cost over $25,000 that affects structural integrity [5]

Exterior painting and waterproofing are a named component of the study, with their own estimated useful life and their own reserve line. That is worth sitting with, because it changes the conversation from "when can we afford to repaint?" to "what does the reserve schedule already say about this component, and does the scope we are being quoted match it?"

Associations in existence on or before July 1, 2022 had to complete a SIRS by December 31, 2025, extended from the previous year by HB 913; where a SIRS is performed alongside a milestone inspection, DBPR guidance allowed completion by December 31, 2026 [5][3][2]. Since July 1, 2024, associations have had to e-file a SIRS reporting form with DBPR within 45 days, and by October 1, 2025 every condominium and cooperative association was required to have an online DBPR account [2].

Reserves after HB 913

For budgets adopted on or after December 31, 2024, members may no longer vote to provide no reserves or reduced reserves for SIRS components, and associations that had previously waived them were required to begin funding from January 1, 2026 [5][2].

HB 913, effective July 1, 2025, added flexibility rather than removing the obligation: a majority of total voting interests may vote to pause or reduce SIRS reserve funding for up to two consecutive annual budgets in order to fund repairs recommended by a milestone inspection, and reserves may be funded by special assessment, line of credit or loan with majority approval [3]. The same bill widened who may perform or verify the studies to licensed engineers, architects or certified reserve specialists [4].

Conflicts of interest and bids

Section 553.899(12) requires inspectors and the contractors who perform the recommended work to disclose financial relationships, and makes contracts voidable where they do not [1]. HB 913 sharpened it: where a conflict exists and the bid exceeds $2,500, multiple bids are required, and professionals bidding on work must disclose financial or familial ties in writing [3][4].

If your engineer recommends a contractor, that is not improper — but the relationship has to be on paper, and the board has to see more than one number.

What the work usually turns out to be

Phase Two findings in this market are consistent: spalling concrete on balconies, walkways and garages; post-tension and rebar repair; deck waterproofing membranes; sealant and caulk replacement at windows and control joints; stucco crack repair; and the exterior coating system itself, which is also the SIRS line item [5].

Permits matter here in a way they do not for a repaint. Structural concrete repair and waterproofing carried out under a Phase Two plan require building permits, usually with engineer-sealed drawings — both counties require all applicable permits to be obtained [6][7]. Repainting alone does not. Many municipalities and associations do require color approval for multifamily buildings before painting.

What a board should ask a contractor

• Is the contractor state-certified — a CGC or CBC — so it can pull permits for the structural work? A certified general contractor's license is unlimited as to the type of work, and a certified contractor may contract in any jurisdiction in the state [10]. Check the number yourself on the DBPR register [9].
• Has it disclosed, in writing, any financial or familial relationship with the inspecting engineer [1][3]?
• Will the work commence within 365 days of the Phase Two report, and does the schedule align with the engineer's timeline [1]?
• Does the coating scope match the SIRS "waterproofing and exterior painting" component and the estimated useful life the reserve schedule assumes [5]?
• Is the coating being applied to the manufacturer's specification — film thickness, number of coats, substrate cure and pH — and is that in the scope rather than in a conversation?

How Smart Coat handles this

Smart Coat is a Florida certified general contractor, which is the license class that matters here: the same contract can carry the concrete restoration, the waterproofing and the coating, so a board is not coordinating three trades around one statutory deadline. Painting alone requires no state license in Florida — the structural work behind it does.

We bid to the engineer's report line by line, so the board can lay our number beside the report and see which item each line answers. Where the report and the reserve study disagree about scope, we say so before pricing rather than after.

More on waterproofing, concrete restoration and HOA and community painting, or ask us to walk the building. We work from Miami to West Palm Beach, including Miami, Fort Lauderdale, Pompano Beach, Deerfield Beach and Boca Raton.

This guide describes the statute and county programs as published on the dates in the sources below. It is general information about a fast-changing area of Florida law, not legal advice; your association's attorney and engineer are the people who apply it to your building.