Important: This article is general information, not legal advice. Deadlines and requirements depend on each building's facts and on changes in Florida law. Associations should confirm their obligations with their association attorney, community association manager, local building department and the Florida DBPR Division of Condominiums, Timeshares and Mobile Homes.
What is the December 31, 2026 condo deadline?
After the 2021 Surfside collapse, Florida created two related requirements for older residential condominium and cooperative buildings: milestone inspections and structural integrity reserve studies. According to the DBPR inspections guidance:
- Buildings that reached 30 years of age before July 1, 2022 were required to have a milestone inspection by December 31, 2024. Buildings that reached 30 years between July 1, 2022 and December 31, 2024 must have their initial milestone inspection before December 31, 2025.
- Unit-owner-controlled associations existing on or before July 1, 2022 must have had a SIRS completed by December 31, 2025.
- If an association must complete a milestone inspection on or before December 31, 2026, it may complete the SIRS at the same time. A SIRS completed in conjunction with a milestone inspection must be completed by December 31, 2026.
The local enforcement agency, usually the city or county building department, notifies associations by certified mail when a milestone inspection is required, and it can extend the initial deadline in some circumstances, such as when the association has already contracted with an architect or engineer.
What is a milestone inspection?
DBPR describes a milestone inspection as a structural inspection of an aging building to determine whether substantial structural deterioration exists. It applies to residential condominium and cooperative buildings, including mixed-ownership buildings, that are three or more habitable stories tall, at 30 years of age and every 10 years after (or 25 years if the local agency requires it).
- Phase 1 is a visual assessment of the building's structure.
- Phase 2 is required only if Phase 1 finds substantial structural deterioration, and it may include destructive testing and a repair program.
It must be performed by a licensed architect or engineer, or a team with a licensed architect or engineer acting as the registered design professional in responsible charge. The signed and sealed report goes to the local enforcement agency, and the association must distribute the summary to unit owners.
What is a structural integrity reserve study (SIRS)?
A SIRS is a type of reserve study that makes sure associations set aside money for major repairs and replacement of eight structural elements: roof, structural systems, fireproofing and fire protection, plumbing, electrical, waterproofing and exterior painting, windows and exterior doors, and other qualifying items over $25,000 (adjusted annually) that affect structural integrity. It includes a visual inspection and a recommended funding schedule, and it must be performed or verified by a licensed engineer, architect, certified reserve specialist or professional reserve analyst. Associations must report a completed SIRS to DBPR within 45 days.
Why a PCA is not a milestone inspection
A Property Condition Assessment and a milestone inspection can sound similar because both involve a professional walking a building and writing a report. They are different services with different purposes:
| Milestone inspection / SIRS | Property Condition Assessment | |
|---|---|---|
| Purpose | Required by Florida law for qualifying residential condo and co-op buildings | Voluntary due diligence for a buyer, owner, investor or lender |
| Who performs it | Licensed architect or engineer (MI); engineer, architect, certified reserve specialist or professional reserve analyst (SIRS) | Commercial inspection and due diligence professionals, per the agreed scope |
| Focus | Structural deterioration (MI); reserve funding for specified structural elements (SIRS) | Overall observed condition, immediate repair cost opinions and capital reserve outlook |
| Reporting | Filed with the local enforcement agency or DBPR, with owner notice requirements | Delivered to the client who ordered it |
| Satisfies the condo law? | Yes, when done by a qualified professional | No |
If your association received a milestone notice or still needs a SIRS, contact a Florida-licensed engineer or architect, or a qualified reserve professional for the SIRS. DBPR's inspections page links to license verification tools for each. Our team does not perform milestone inspections or SIRS, and we will tell you so if you call us about one.
Where a commercial inspection or PCA does fit
Commercial due diligence still has an important role. It just answers different questions for different properties:
- Commercial properties outside the condo law. Office buildings, retail centers, warehouses, churches, medical offices and apartment complexes under single ownership are not covered by the condo milestone requirements. For a purchase, refinance or budget, a Scope 4 — Property Condition Assessment or Scope 3 — Commercial Inspection + Five-Year Capital Planning provides condition findings and cost planning.
- Buyers and investors. If you are buying a building or a commercial unit in a mixed-use property, ask for the association's milestone inspection and SIRS reports as part of your document review. They are important records, but they were written for the association's legal obligations, not for your purchase decision.
- Items outside the structural focus. Owners sometimes want a broader look at systems, site features and finishes for their own budgeting. That work is separate from, and does not replace, any required MI or SIRS.
We serve commercial clients across Jacksonville, St. Augustine, Tallahassee, Gainesville, Ocala, Lake City and throughout Florida, Georgia and Alabama. For refinance timing, see why to find repair costs before your lender does.
Frequently asked questions
Can a Property Condition Assessment replace a Florida milestone inspection?
No. A milestone inspection must be performed by a Florida-licensed architect or engineer under Florida law. A PCA is a voluntary due diligence report and cannot satisfy the milestone requirement.
Can a PCA count as a structural integrity reserve study (SIRS)?
No. A SIRS must be performed or verified by a licensed engineer or architect, a certified reserve specialist or a professional reserve analyst, and it must follow the statutory SIRS requirements. A PCA does not satisfy them.
What is due by December 31, 2026?
According to DBPR, a SIRS completed in conjunction with a milestone inspection that is required on or before December 31, 2026 must be completed by December 31, 2026. Other deadlines depend on the building's age. Confirm your association's dates with your attorney, manager and local building department.
Which buildings need a milestone inspection?
Residential condominium and cooperative buildings, including mixed-ownership buildings, that are three or more habitable stories tall, at 30 years of age and every 10 years after, or at 25 years if the local enforcement agency requires it.
When does a commercial PCA make sense?
When you are buying, refinancing or budgeting for a commercial property such as an office, retail center, warehouse, church or apartment complex, or when you want a condition and cost picture for your own decision-making.
Buying, refinancing or budgeting for a commercial property? Tell us about it and we'll recommend the right scope. For milestone inspections or SIRS, contact a licensed engineer or architect.
Sources
Images in this article are AI-generated illustrations, not actual High Mark inspections or client properties. This article is general information and does not replace the written scope in your inspection agreement.