Florida SB 4-D (Ch. 2022-269): Condo Milestone Inspections and Reserve Study Law

Quick Answer

Senate Bill 4-D (2022 Special Session D), "Building Safety," is the post-Surfside law that created milestone inspections and the structural integrity reserve study (SIRS) framework for Florida condominium and cooperative buildings of three or more stories. It became Chapter 2022-269, Laws of Florida, after the Governor approved it on May 26, 2022, and the bill page lists that date as its effective date. Several of its original deadlines and thresholds were later changed by SB 154 (2023) and HB 913 (2025), so read it as the starting point, not the current rule.

At a Glance

What the Law Says

We read the Senate bill page, bill history and citations table, and the Appropriations Committee bill summary for SB 4-D. We did not read the full enrolled text, so the points below follow the official summary.

Roofs

The bill directs the Florida Building Code to provide that when 25 percent or more of a roofing system or roof section is repaired, replaced or recovered, "only the portion of the roofing system or roof section undergoing such work" must meet the current code. The summary says this applies only to roofs built, repaired or replaced under the 2007 Florida Building Code or later editions.

Milestone inspections

As summarized, condominium and cooperative buildings three or more stories tall must have a "milestone inspection" of structural integrity by an architect or engineer:

• At 30 years of age, and every 10 years after; or
• At 25 years of age, and every 10 years after, if the building is within three miles of a coastline.

Other points in the summary:

• If the certificate of occupancy was issued on or before July 1, 1992, the initial inspection was due before December 31, 2024.
• A phase one inspection must begin within 180 days after the association gets written notice from the local enforcement agency.
• A phase two inspection is required if phase one finds evidence of "substantial structural deterioration."
• Results go to local building officials and the association, and an inspector-prepared summary goes to unit owners by mail, and by email to owners who consented to email notice.
• The management contract between a covered association and a community association manager must require compliance with these requirements as directed by the board.
• If an association does not show that repairs for substantial deterioration were scheduled or begun within 365 days after the local agency receives a phase two report, the local agency must review and determine whether the building is safe for human occupancy.
• Associations were to report to the Division of Condominiums, Timeshares, and Mobile Homes, on or before January 1, 2023, the number of buildings three stories or higher and the total units in them.
• Sellers, both developers and non-developer owners, must give prospective buyers the inspector-prepared summary.

Official records

Unit owners gain the right to inspect and copy, as official records, the milestone inspection report and all other inspection reports relating to structural or life safety. Renters may inspect milestone reports. The developer's turnover inspection report must also comply with the milestone requirements.

Structural integrity reserve study

The summary says condominium and cooperative associations must complete a SIRS every 10 years for each building three stories or taller. Associations existing on or before July 1, 2022, and controlled by non-developer owners were to complete one by December 31, 2024. The SIRS is "a study of the reserve funds required for future major repairs and replacement of the common elements based on a visual inspection of the common elements." As enacted, the study covers the estimated remaining useful life and replacement cost of the roof, load-bearing walls or other primary structural members, floor, foundation, fireproofing and fire protection systems, plumbing, and any item with a deferred maintenance or replacement cost over $10,000. An engineer or architect performs the visual inspection. A developer must complete a SIRS before turning over control.

The bill also bars certain associations and members from waiving or reducing reserves for the covered items after a specified date. The bill title says this, but we did not read the date.

What This Means in Practice

This is the original version, not today's rules

Later Senate bill summaries that we read show these changes. SB 154 (2023) deleted the automatic 25-year coastal rule and let local agencies set 25 years by choice, let associations with a milestone inspection due by December 31, 2026 complete the SIRS at the same time (with a December 31, 2026 outside date for the SIRS), and dropped "floor" and "foundation" from the SIRS list in favor of building structure. HB 913 (2025) limited both programs to buildings with three or more "habitable" stories, moved the SIRS deadline from December 31, 2024 to December 31, 2025, and raised the reserve-item threshold from $10,000 to $25,000. See the sibling pages for each. Our reading: for any current question, use the 2026 statute text and the later bills, not this bill alone.

For boards

• Know which law version your milestone or SIRS obligation comes from. A 2022 description may no longer match.
• Keep inspection and structural reports, because owners may inspect and copy them as official records.
• Check that your management agreement requires compliance with the milestone and SIRS requirements, as the bill requires for covered associations.
• Treat the fiduciary-duty language seriously. The summary calls a willful and knowing failure to complete a milestone inspection or SIRS a breach of duty.

For owners

You have a record-access right to structural and life safety inspection reports, and a right to receive the inspector-prepared summary. If you are selling, the summary must be provided to the buyer. Renters may inspect milestone reports.

What we did not verify

• The exact date after which reserves for the covered items cannot be waived or reduced.
• Any dates inside the enrolled text that differ from May 26, 2022. Confirm with counsel.
• How the bill's Chapter 720 changes (§ 720.303, § 720.311) work. The bill page lists the sections, but we did not read the changes.

Timeline

Related Florida Law

• SB 154 (2023): refinements to milestone inspections and reserves
• HB 913 (2025): SIRS deadline, reserves and meetings
• Section 553.899: milestone inspections
• Section 718.112: reserves and the SIRS
• HB 1021 (2024): condominium association reform
• Florida HOA law changes 2021 to 2025
• Florida HOA laws complete guide

Board Checklist

• Confirm whether each building is three or more habitable stories and condominium or cooperative owned.
• Find any local enforcement agency notice and calendar the 180-day phase one start and the 14-day owner notice rule if it applies to you under later law.
• Confirm the status of your SIRS and keep the report, plus the milestone report, available as official records.
• Review reserve waivers or reductions against the current § 718.112 text.
• Check the management contract for the required compliance language.
• Give the inspector-prepared summary to owners as the law requires and to buyers through sellers.
• Ask your attorney which later bills changed your obligations.

Frequently Asked Questions

When did SB 4-D take effect?

The Senate bill page lists May 26, 2022, the date the Governor approved it. The Senate summary says the provisions take effect upon becoming law. We did not read the enrolled text for later-dated parts.

Which buildings did the original bill cover?

Condominium and cooperative buildings three or more stories in height. HB 913 (2025) later limited this to three or more "habitable" stories.

What is a milestone inspection?

A structural integrity inspection by an architect or engineer, first at 30 years (or 25 near the coast under the original bill) and every 10 years after. Phase two follows if phase one finds substantial structural deterioration.

What is a SIRS?

A structural integrity reserve study: "a study of the reserve funds required for future major repairs and replacement of the common elements based on a visual inspection of the common elements."

Are directors personally at risk?

The summary says a willful and knowing failure by an officer or director to have a milestone inspection performed, or to complete a SIRS, is a breach of fiduciary duty. What that means for a specific director is a question for counsel.

Can owners see the reports?

Yes. The summary says owners may inspect and copy the milestone report and other structural or life safety inspection reports as official records.

Does it apply to HOAs?

The inspection and reserve provisions are in Chapters 718 and 719 and § 553.899, which cover condominiums and cooperatives. The bill's citations table also lists two HOA sections, but we did not read those changes.

Where This Comes From

We read the Florida Senate bill page for SB 4-D (2022 Special Session D), including its history, vote records and statute citations, and the Appropriations Committee bill summary, at flsenate.gov. We did not read the full enrolled text of Chapter 2022-269, so details such as the reserve-waiver date are not stated here.

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Legal disclaimer: This article is general information, not legal advice. Laws change and associations differ. Confirm the current statute text and how it applies to your governing documents with a licensed Florida attorney before acting.