Section 01Why a Canadian buyer should care about this document
A Florida condo is a fractional share of a building. When you buy unit 805, you also buy a fractional share of the obligation to keep that building's roof, foundation, plumbing, electrical, waterproofing, and fire safety systems in working order for the next several decades. The SIRS is the document that quantifies that obligation. Before SB 4-D, that obligation was largely invisible: associations could and routinely did vote to waive reserve funding to keep monthly fees low, deferring structural maintenance until a roof failed or, in the worst case, until a tower partially collapsed. The SIRS regime exists precisely because that practice failed catastrophically at Champlain Towers South in Surfside on June 24, 2021. Ninety-eight people died. The Florida legislature responded with SB 4-D, then SB 154, then HB 913, and the cumulative effect is that the deferred-maintenance bill is now visible, quantified, and legally non-waivable.
For a Canadian who has never owned property in Florida, this changes the calculus in two specific ways. First, asking price plus monthly condo fees no longer captures the real cost of owning a unit: you must also price in the SIRS-driven reserve contribution and any special assessments triggered by an underfunded reserve. Second, the resale package you receive at closing now includes a SIRS report (or it should), and you have a legal right to read it before you commit. Skipping that step, or skimming it without understanding the percent-funded ratio, is the most expensive mistake a foreign buyer can make in the current Florida condo market.
Section 02The legal framework: from Surfside to HB 913
The SIRS is the product of three successive Florida laws, each correcting the limitations of the previous one. Understanding them in sequence is the only way to read a SIRS report intelligently, because the report you are reading was almost certainly drafted under one regime and may not yet reflect the next one.
Verified fact (May 2022 / June 2023 / June 2025): SB 4-D was passed during a Florida special session in May 2022 and signed shortly thereafter. It created the SIRS requirement under F.S. § 718.112(2)(g) and the milestone inspection requirement under F.S. § 553.899, both responding directly to the Surfside collapse. SB 154 (2023) refined the SIRS framework, expanded the component list, and clarified the relationship between the SIRS and the milestone inspection. HB 913 was signed by Governor DeSantis on June 24, 2025, took effect July 1, 2025, and is the most consequential of the three for buyers because it changed the threshold for "other items" from 10,000 USD to 25,000 USD (with annual inflation adjustments), extended the initial SIRS deadline to December 31, 2025, and introduced funding flexibility while keeping the no-waiver rule for SIRS structural components in place. [1] [2] [3]
In practical terms, a SIRS report dated 2023 was drafted under the SB 4-D / SB 154 framework with a 10,000 USD catch-all threshold; a SIRS dated 2025 or later should be drafted under HB 913 with a 25,000 USD threshold and a baseline funding plan that keeps the reserve cash balance above zero across the entire funding period. This matters when you read the report: a 2023 SIRS that lists items between 10,000 USD and 25,000 USD as mandatory may overstate the reserve obligation under current law, while a 2026 SIRS that uses the new 25,675 USD inflation-adjusted threshold will be the most current snapshot. [4]
Section 03Who must commission a SIRS, and who is exempt
The SIRS rule is narrower than most Canadian buyers realize. It applies to residential condominiums under F.S. Chapter 718 and cooperatives under F.S. Chapter 719, but only to buildings that are three or more habitable stories in height as defined by the Florida Building Code. HB 913 added the word "habitable" to clarify that purely non-residential floors (open parking garages, mechanical floors, crawlspaces) do not count toward the three-story threshold. A common configuration in South Florida is a building with a ground-level parking garage and three or more residential floors above it: under HB 913, that building counts as three habitable stories and is subject to SIRS. [5]
Three exclusions matter for a Canadian buyer evaluating a Florida property:
- HOAs governed by F.S. Chapter 720 are not subject to SIRS. If the property you are considering is a single-family home in a master-planned community, the community association is almost certainly an HOA, not a COA, and there is no SIRS requirement. The HOA may still maintain reserves, but those reserves can be waived by a member vote, and the legal floor is much lower.
- Single-family, two-family, three-family, and four-family dwellings with three or fewer habitable stories above ground are exempt. A Canadian buying a townhouse or a fourplex unit will typically not be exposed to a SIRS.
- Buildings under three habitable stories are exempt regardless of structure. Two-story garden-style condominiums are exempt.
If you are buying a high-rise, a mid-rise, or a coastal tower, the SIRS rule applies and the report must exist. If the listing broker tells you the association is "still working on it," that is your signal to slow down, not to close faster.
Section 04The structural components a SIRS must evaluate
Under F.S. § 718.112(2)(g) as amended by HB 913, the SIRS must inspect, document the remaining useful life of, and price the replacement of the following structural and life-safety components. The list is exclusive: the board may add non-structural components to the reserve study, but cannot remove anything on this list.
| Component | What it covers |
|---|---|
| Roof | Membrane, structural roof deck, drainage |
| Load-bearing walls and primary structural members | Concrete, steel, columns, post-tensioned cables |
| Floors | Slab structure, post-tensioned tendons where applicable |
| Foundation | Footings, piles, foundation walls |
| Fireproofing and fire protection systems | Sprinklers, alarms, fire pump, standpipes, fire-rated assemblies |
| Plumbing | Risers, main drains, water distribution |
| Electrical systems | Main service, switchgear, distribution |
| Waterproofing and exterior painting | Caulking, balcony coatings, stucco, exterior paint |
| Windows and exterior doors | Including sliding doors and balcony doors |
| Catch-all: any other item exceeding the statutory threshold | Whose failure would affect any of the above |
The catch-all threshold is the moving piece. SB 4-D set it at 10,000 USD. HB 913 raised it to 25,000 USD effective July 1, 2025, and required the DBPR to publish an inflation-adjusted figure annually by February 1, starting in 2026. The 2026 figure has been published at approximately 25,675 USD by industry sources tracking the CPI adjustment. [6] [7]
> Verified fact (HB 913, July 1, 2025): Reserve item threshold raised from 10,000 USD to 25,000 USD, with annual CPI-based inflation adjustments. The DBPR posts the current figure on its website by February 1 each year. [3]
Section 05Methodology: how a SIRS is conducted
The SIRS is two studies stapled together. The first is an engineering study: a Florida-licensed engineer or architect physically visits the building, inspects each structural component, photographs and documents its condition, and assigns a remaining useful life and a current replacement cost. The second is a financial study: a reserve specialist (typically holding the Reserve Specialist or Professional Reserve Analyst designation) or a CPA takes those engineering inputs, layers in inflation assumptions and the existing reserve balance, and produces a funding plan that schedules the contributions needed over a 30-year horizon.
Two technical concepts are worth understanding before you read a report. First, the "baseline funding plan" required by HB 913 is the funding schedule that keeps the reserve cash balance above zero at every point during the funding period. It is the legal minimum: a board can choose a more conservative "threshold funding" plan, which keeps a higher cushion, but cannot fund below baseline. Second, the funding method matters. HB 913 explicitly allows the board to use either pooled accounting (one consolidated reserve fund covering all SIRS components) or straight-line accounting (a separate sub-account per component), and the board can switch between the two without a member vote. Pooled accounting typically produces a lower nominal contribution for the same legal compliance level, which is one reason boards favour it.
> Typical range (industry sources, 2025-2026): A basic SIRS for a small-to-mid-size building costs 5,000 USD to 15,000 USD. A SIRS combined with milestone inspection or with drone-assisted facade documentation runs 8,000 USD to 35,000 USD. The cost is paid by the association, which means it is paid by the unit owners through their condo fees. [8]
Section 06Reading the percent-funded ratio: the single most important number
If you read only one number on a SIRS report, read the percent-funded ratio. It is calculated as the current reserve balance divided by the theoretical balance recommended by the SIRS, expressed as a percentage. It tells you, at a glance, how prepared the building actually is for the structural maintenance it knows is coming.
| Percent funded | Financial health | Assessment risk |
|---|---|---|
| 100 percent or more | Excellent | Very low |
| 70 to 99 percent | Good | Low |
| 40 to 69 percent | Marginal | Moderate |
| 20 to 39 percent | Underfunded | High; special assessment likely |
| Below 20 percent | Critical | Very high; special assessment imminent |
> Opinion (editorial judgment): Industry practitioners use 70 percent funded as the rule-of-thumb floor for a financially sound building, and 30 percent funded as the upper bound of a major red flag. We agree with that benchmark for a buyer's screening purpose, with the caveat that the trend matters more than the absolute number. A condo at 65 percent funded with a board moving toward 100 percent compliance is a different proposition than a condo at 65 percent funded with a board still litigating whether to fully fund.
The percent-funded number alone does not tell you everything. You also need to look at which specific components are at low remaining useful life. A building at 80 percent funded overall but with a roof at 2 years RUL, a fire pump at 0 years RUL, and a 6-million-USD post-tensioned cable replacement scheduled for year 4 is a very different risk than a building at 80 percent funded with no major component due in the next decade. Read the component table.
Section 07Funding rules and the no-waiver regime
The single biggest legal change of the SIRS regime is that, for budgets adopted on or after January 1, 2025, the structural reserves identified by the SIRS cannot be waived or reduced by a unit owner vote. Before SB 4-D, owners routinely voted to waive reserves; in many older buildings, that practice persisted for 10, 20, or 30 years, and is the underlying reason so many Florida condos are now facing six-figure special assessments.
HB 913 introduced one important nuance. While the SIRS structural reserves themselves still cannot be waived, the board now has alternative funding tools available with a majority vote of voting interests:
- Special assessments to cover a one-time funding gap.
- Loans or lines of credit secured by future assessments.
- A two-year temporary pause of reserve contributions, available only for budgets adopted on or before December 31, 2028, and only if a recent milestone inspection has identified urgent repairs that the board wants to prioritize.
Each of these is a tool the board can use to manage the cash-flow shock of suddenly fully funding decades of deferred maintenance. None of them eliminate the obligation. They redistribute it across time. For a Canadian buyer, this means that even a building with a reasonable percent-funded ratio today may be carrying a loan or a special assessment schedule that materially increases your effective monthly cost.
> Verified fact (F.S. § 718.112(2)(g), HB 913): SIRS structural reserves cannot be waived. For budgets adopted on or after January 1, 2025, the association must fund those reserves at the level recommended by the SIRS. The board may use special assessments, loans, or lines of credit (with a majority of voting interests' approval) to meet that obligation. [3]
Section 08Quebec analogue: étude du fonds de prévoyance under Loi 16
Quebec has its own structural reserve regime, and a Canadian buyer who already owns a condo in Quebec will recognize the spirit of the SIRS. The legal vehicles are different, the frequencies are different, and the building scope is different, but the underlying logic is the same: force divided co-ownerships to quantify and fund their long-term capital needs through a professional study, and disclose the result to buyers.
| Dimension | Florida (SIRS) | Quebec (Étude du fonds de prévoyance) |
|---|---|---|
| Statutory level | State (FL) | Provincial (QC) |
| Statutory basis | F.S. § 718.112(2)(g) (condos), F.S. § 719.106 (cooperatives) | Article 1071 C.c.Q. |
| Foundational reform | SB 4-D (2022), SB 154 (2023), HB 913 (2025) | Loi 16 (chapitre 28, 2019); décret 991-2025 in force August 14, 2025 |
| Trigger event | Champlain Towers South collapse, June 24, 2021 | Long-standing pattern of underfunded reserve funds across QC condos |
| Building scope | Condos and cooperatives, 3+ habitable stories | All divided co-ownerships, no story threshold |
| Update frequency | Every 10 years | Every 5 years |
| Funding rule | Mandatory baseline funding; no waiver allowed for SIRS components since January 1, 2025 | Contributions set on basis of study; minimum 0.5 percent of reconstruction value annually before first study |
| Reserve item threshold | 25,000 USD (HB 913, indexed annually) | No statutory threshold |
| Authorized professionals (visual) | FL-licensed engineer or architect | OIQ (engineers), OAQ (architects), OTPQ (technologues professionnels), OEAQ (évaluateurs agréés) |
| Authorized professionals (financial) | Reserve specialist (RS), Professional Reserve Analyst (PRA), or CPA | Same orders, plus CPA |
| Disclosure to buyer | SIRS provided; 7-day buyer review window (HB 913, up from 3 days) | Attestation du syndicat; 15-day delivery window |
| Initial compliance deadline | December 31, 2025 (extended by HB 913) | August 14, 2028 |
| Retention requirement | 15 years for SIRS reports | Filed in the register of co-ownership |
The most important practical delta for a Quebec investor crossing the border is the threshold issue. In Quebec, the étude covers all common parts regardless of replacement cost. In Florida, items below 25,000 USD (CPI-adjusted) are excluded from the SIRS scope, which means the SIRS is not a complete picture of the building's capital needs: it is a structural floor. A well-run Florida association will commission a traditional reserve study covering everything below the threshold (clubhouse furniture, pool equipment, paving, landscape) on top of the SIRS. Many do not. Ask.
> Verified fact (article 1071 C.c.Q., décret 991-2025): Since August 14, 2025, every divided co-ownership in Quebec must obtain an étude du fonds de prévoyance every 5 years, performed by a professional from one of the recognized orders, with a planning horizon of at least 25 years. The compliance deadline for the first study is August 14, 2028. [9] [10]
Section 09Worked example: the buy-side math
Consider an 80-unit Florida condo built in 1995, currently for sale at unit-level asking prices around 425,000 USD. The 2025 SIRS, drafted under HB 913, identifies 6,000,000 USD of structural replacements needed over the next 25 years, with a current reserve fund of 1,500,000 USD against a recommended balance of 2,500,000 USD. The percent-funded ratio is 60 percent: marginal. Under the baseline funding plan, the SIRS recommends an annual contribution of 240,000 USD to the structural reserves, which works out to 3,000 USD per unit per year, or 250 USD per unit per month, on top of operating expenses.
If the existing condo fee was 600 USD per month (covering operating costs, insurance pass-through, management, common-area utilities), the post-SIRS fee will be 850 USD per month. A Canadian buyer underwriting this property at 600 USD per month is mispricing it: they should be underwriting it at 850 USD per month, plus the residual risk of a special assessment if the board chooses to close the 1,000,000 USD gap between the actual and recommended balance through a one-time levy rather than spreading it across the funding period. A 1,000,000 USD gap divided across 80 units is 12,500 USD per unit, levied either as a one-time assessment or as a loan-amortized 5-to-10-year increment to the monthly fee.
> Typical range (industry data, 2024-2026): In buildings that were underfunded for 10 to 20 years before SB 4-D (the Surfside-pattern buildings), the catch-up cost at full funding has typically meant an additional 200 USD to 400 USD per unit per month, or a special assessment of 10,000 USD to 100,000 USD per unit. Several Florida coastal towers have levied special assessments of 50,000 USD to 200,000 USD per unit since 2022.
Section 10Common mistakes a Canadian buyer makes when reading a SIRS
Anticipate these. Each one shows up repeatedly in resale transactions where the buyer later regrets not pushing harder.
- Treating "we have a SIRS" as proof of compliance. A SIRS exists; what matters is whether the board is funding it. Ask for the most recent annual budget and confirm the line-item structural reserve contribution matches the SIRS recommendation.
- Reading only the executive summary. The summary will tell you the percent-funded ratio. The component table will tell you which roof, which fire pump, which set of post-tensioned cables, and which window walls are due in the next 5 years. Scenarios where the summary looks healthy but the next-5-year obligations are concentrated are the most dangerous.
- Confusing the SIRS with a milestone inspection. They are two different documents under two different statutes (§ 718.112(2)(g) for SIRS, § 553.899 for milestone). The milestone inspection asks "is this building safe?". The SIRS asks "is the money in place to keep it safe?". A building can pass milestone and fail SIRS, or vice versa. You need to read both.
- Assuming the 2023 SIRS is current. SB 4-D required the first SIRS by December 31, 2024; HB 913 extended that to December 31, 2025; and any pre-HB 913 study uses the old 10,000 USD catch-all threshold. If the SIRS you are looking at predates July 1, 2025, ask whether the board has commissioned an update.
- Ignoring the delinquency rate. If 12 percent of unit owners are delinquent on their condo fees, the funding plan in the SIRS is built on a number that is not actually being collected. The shortfall lands on the paying owners. Ask for the delinquency rate explicitly.
- Assuming Citizens Insurance will cover a non-compliant building. HB 913 made non-compliance with the SIRS and milestone obligations a disqualifier for state-backed Citizens Property Insurance. A non-compliant building may be uninsurable in the private market and ineligible for Citizens, which means it may also be unfinanceable.
- Skipping the conflict-of-interest disclosure. HB 913 requires the engineer or architect performing the SIRS to disclose in writing if they intend to bid on the follow-up repair work. Read the disclosure. If the same firm wrote the SIRS and is now scheduled to do 2,000,000 USD of waterproofing work, that is a fact you want to know before you close.
Section 11Actionable checklist before signing the purchase contract
- Request the most recent SIRS report (full report, not the summary), the most recent milestone inspection report (if the building is 30 years old or older, or 25 years old or older if within 3 miles of the coast), the current annual budget, and the most recent two annual financial statements.
- Confirm the SIRS date. If older than July 1, 2025, ask whether an updated study has been commissioned.
- Compute the percent-funded ratio yourself: current reserve balance divided by SIRS-recommended balance. Compare to the table above.
- Read the component table and flag any structural component with remaining useful life below 5 years. For each, check whether the funding plan has accumulated enough to cover the replacement.
- Confirm the board is fully funding the SIRS recommendation in the current budget. If not, identify the shortfall and the funding mechanism the board has chosen (special assessment, loan, two-year pause).
- Pull the special assessments history for the past 5 years. Pull the special assessments currently voted or under discussion.
- Pull the unit delinquency rate.
- Pull the master insurance policy, including the hurricane deductible (typically 2 to 10 percent of building value, deductible borne by the association and passed through to owners).
- Confirm the building's milestone inspection status if it is 30 years old or older (25 years if within 3 miles of the coast).
- Use HB 913's extended buyer review window: you have 7 business days from receipt of the SIRS, the milestone report, and the turnover inspection report to review and decide. If the seller refuses to provide these documents, walk.
Section 12FAQ
Does the SIRS apply to single-family homes in a gated Florida community?
No. Single-family homes are governed by F.S. Chapter 720 (HOA law), which has its own reserve requirements but no SIRS. The SIRS rule applies only to condominium and cooperative buildings under F.S. Chapters 718 and 719 that are 3 or more habitable stories tall.
My target condo is 28 years old. Does it need a SIRS yet?
Yes. SIRS applicability is not age-based; it is height-based. Any 3+ habitable-story condo or co-op needs a SIRS regardless of age. The milestone inspection is the age-based document (30 years, or 25 years within 3 miles of the coast).
Can I rely on the SIRS to value the unit?
Partially. The SIRS gives you a structural-reserves number. It does not capture non-structural reserves (clubhouse, pool equipment, landscape), the master insurance pass-through, or the special-assessments history. Use the SIRS as one input in your underwriting, not as the answer.
The seller says they have already paid the special assessment. Am I in the clear?
Maybe. Confirm in writing, with a board-issued estoppel certificate, that no further assessment is voted, contemplated, or under board discussion. Estoppel certificates are routine in Florida closings and explicitly cover this question.
My building's SIRS is at 35 percent funded. Should I run?
Not automatically. Look at the trajectory. A board that has committed to full funding under HB 913 and is using a 5-to-10-year loan to close the gap may be acceptable; a board still litigating whether the SIRS applies to them is not. The trend dominates the snapshot.
What happens if the association does not commission a SIRS?
Failure to complete a required SIRS is a breach of fiduciary duty by the officers and directors under F.S. § 718.111(1). Practically, non-compliance disqualifies the building from Citizens Insurance, may make units unfinanceable, and exposes individual board members to personal liability.
Can I, as an out-of-state buyer, attend the meeting where the board adopts the SIRS-driven budget?
Yes. Florida condo law requires meeting notice and unit-owner attendance rights. Use the proxy mechanism if you cannot attend in person; never give a blanket proxy to the board.
Is the SIRS publicly available, or only in the resale package?
Once completed, the SIRS must be posted on the association's website (associations with 25 or more units, threshold lowered effective January 1, 2026) or available through a member-accessible mobile application. It is part of the official records.
> Editorial team note: Research drawn from primary public sources cited at the bottom of every guide: Florida Statutes, Florida DBPR, the Florida Senate and House bill summaries, the Office of the Florida Governor, the Quebec Civil Code, and the Quebec official Gazette. Every figure, rate, threshold, and deadline in this guide is drawn from a verifiable primary source listed below. The article is updated whenever the underlying rules change, with a fresh review date stamped at the top.
>
> Essential disclaimer: Educational purpose only. This document is reference information. It is not legal, tax, accounting, real estate, immigration, medical, or financial advice and does not create a client-professional relationship. Before any concrete decision, consult a licensed professional in the relevant jurisdiction: a Florida-licensed attorney, a cross-border tax professional, a Florida-licensed insurance broker, or your physician, depending on the question. Treat this content as a research starting point, not as professional advice.
Section 13Disclaimer
This guide is for educational purposes only. The figures, rates, thresholds, deadlines, and rules cited are drawn from public sources at the date of last review and may evolve. The SIRS framework in particular has been amended three times since 2022 (SB 4-D, SB 154, HB 913), and further legislative refinements are likely.
For any concrete decision involving a Florida condominium purchase, sale, or governance issue, consult a Florida-licensed attorney specializing in condominium law, a cross-border tax attorney for the Canada-US tax interaction, and a Florida-licensed insurance broker for the master policy and hurricane deductible exposure. CanadaFlorida is not a substitute for licensed professional advice for your particular situation.
External links are provided for reference and do not constitute an endorsement. Jurisdictional applicability varies: this guide is calibrated to Florida state law (chapters 718 and 719 of the Florida Statutes) and to Quebec civil law (article 1071 C.c.Q.). Equivalent reserve study regimes in Ontario, British Columbia, and Alberta are forthcoming on this site.