The short answer (September 2026): Florida condominium buildings three habitable stories or taller need a structural milestone inspection at 30 years (earlier where the local building official requires 25) and a Structural Integrity Reserve Study (SIRS) at least every 10 years. The roof is the first item the SIRS must cover, and reserves for it can no longer be waived.
This guide explains what the laws require, where the roof fits, and what a board can do now so its roof numbers are defensible. It is written from a roofing contractor’s perspective. It is not legal advice, and it does not replace the engineer, architect or reserve specialist the law requires.
The three laws, in order
SB 4-D (2022). Created section 553.899, Florida Statutes (milestone inspections), and the SIRS requirement in section 718.112 [3]. As originally written, a building within 3 miles of a coastline needed its first milestone inspection at 25 years; others at 30 years. Buildings with a certificate of occupancy issued on or before July 1, 1992, had to complete the initial inspection before December 31, 2024 [3].
SB 154 (2023). Removed the automatic 3-mile coastal rule. Instead, the local enforcement agency may require the inspection at 25 years if local environmental conditions justify it [4]. It also allowed certified reserve specialists to perform SIRS visual inspections and let associations complete the SIRS together with the milestone inspection by December 31, 2026 [4].
HB 913 (2025). Effective July 1, 2025, except where otherwise provided [5]. Among other changes, it:
- Applied both requirements to buildings three habitable stories or more [5].
- Extended the SIRS deadline from December 31, 2024, to December 31, 2025 [5].
- Required a “baseline” funding plan in the SIRS [5].
- Raised the dollar threshold for additional SIRS items from $10,000 to $25,000, adjusted for inflation [5].
- Required design professionals and contractors bidding on milestone inspections or SIRS to disclose in writing whether they intend to bid on the resulting repair work [5].
- Allowed a temporary pause or reduction of reserve funding for no more than two consecutive annual budgets after a milestone inspection, through December 31, 2028 [5].
The current text of both statutes is on the Florida Senate website [1][2]. Check it, not a summary, before your board acts.
Milestone inspections: what the statute requires now
Which buildings. Buildings three habitable stories or more in height that are subject, in whole or in part, to condominium or cooperative ownership [1].
When. By December 31 of the year the building reaches 30 years of age, based on the certificate of occupancy, and every 10 years after that [1]. The local enforcement agency may require the first inspection at 25 years based on environmental conditions such as proximity to salt water [1].
Early deadlines. Buildings that reached 30 years before July 1, 2022, were due by December 31, 2024. Buildings that reached 30 years between July 1, 2022, and December 31, 2024, were due by December 31, 2025. The local enforcement agency may extend the date for good cause when the owners have contracted with a professional but cannot finish in time [1].
Phase one. A visual examination by a Florida-licensed architect or engineer of the building’s structural condition [1]. If no signs of substantial structural deterioration are found, phase two is not required [1].
Phase two. Required when phase one finds substantial structural deterioration. It may include destructive or nondestructive testing [1]. The inspector submits a phase two progress report within 180 days after the phase one report, and the owners must commence required repairs within 365 days after receiving the phase two report [1].
Where the roof fits. A milestone inspection is a structural inspection, not a roof survey. The roof matters to it because long-term water entry is a common driver of concrete and steel deterioration. Leaks at parapets, drains, equipment curbs and roof-to-wall joints often show up in phase one observations. Expect the engineer to note them; expect the roof’s service life to be addressed in the SIRS.
The SIRS: where the roof lives
Which buildings and how often. A residential condominium association must complete a SIRS at least every 10 years for each building three habitable stories or higher [2].
Deadline. Unit-owner-controlled associations existing on or before July 1, 2022, must have had a SIRS completed by December 31, 2025 [2]; that deadline has passed. An association that must complete a milestone inspection on or before December 31, 2026, may complete the SIRS at the same time, but “in no event may the structural integrity reserve study be completed after December 31, 2026” [2].
Who performs it. A SIRS is based on a visual inspection of the condominium property and must be performed or verified by a Florida-licensed engineer, a licensed architect, or a certified reserve specialist [2].
What it covers. The statute lists, in order: roof; structure, including load-bearing walls and primary structural systems; fireproofing and fire protection systems; plumbing; electrical systems; waterproofing and exterior painting; windows and exterior doors; and any other item with a deferred maintenance or replacement cost over $25,000 (inflation-adjusted) whose failure would negatively affect the items above [2].
What it must say about each item. At a minimum, the estimated remaining useful life and the estimated replacement cost or deferred maintenance expense, plus a recommended annual reserve amount [2]. Reserves for replacement need not be maintained for an item with more than 25 years of remaining useful life, though deferred maintenance reserves may still be recommended [2]. Because roof coverings usually have shorter service lives than that, a roof replacement reserve will normally apply.
No waiving the roof reserve. For budgets adopted on or after December 31, 2024, members of a unit-owner-controlled association that must obtain a SIRS may not vote to provide no reserves, or less than the required reserves, for SIRS items [2]. The roof is a SIRS item. Exceptions are narrow, such as the limited post-milestone pause described above [2][5].
What boards should do about the roof
A SIRS is only as good as its inputs. The roof line is often one of the largest near-term numbers in the study, so the assumptions behind it deserve attention before the study is finalized.
1. Get a documented roof condition assessment
The reserve professional performs a visual inspection. A roofing contractor or roof consultant can add detail the study can use:
- Roof system type, age and permit history for each roof area, including penthouse roofs, A/C tower enclosures, and pool or amenity decks that act as roofs.
- Core cuts or moisture survey results where wet insulation is suspected.
- Condition of drains, scuppers, parapet caps, counterflashing, equipment curbs, pitch pans and roof hatches.
- Photographs keyed to a roof plan.
Share it with the reserve professional. They decide what the SIRS says.
2. Pin down remaining useful life honestly
Remaining useful life should reflect the observed condition, not only the age printed on a warranty certificate. A roof with saturated insulation may have far less life than its age suggests. A well-maintained roof that qualifies for restoration may have more. Ask the professional to state the basis for the estimate.
3. Ask for a replacement cost that matches the building
A realistic replacement cost for a mid-rise or high-rise condo roof includes more than material per square foot:
- Tear-off and disposal, including multiple layers.
- Tapered insulation and drainage corrections.
- Equipment lifts or curbs raised to meet current code heights.
- Crane or hoist mobilization, street or sidewalk permits, and staging.
- Temporary protection, overhead protection for residents, and any required engineering.
- HVHZ product approvals in Miami-Dade and Broward.
- Permit and inspection costs.
For residential single-family planning numbers, see our South Florida roof replacement cost guide; commercial and condo roofs are measured and priced on site.
4. Consider restoration where the substrate allows it
Not every low-slope roof needs a full tear-off. Fluid-applied or silicone restoration systems can extend service life when the membrane, insulation and details are sound enough. Perkins’ Miami Beach condo silicone roof coating project is one published example. Whether restoration is appropriate is a condition question, and the SIRS should reflect the chosen strategy and its expected life.
5. Plan the re-roof around an occupied building
Condo re-roofs happen over people’s homes. A workable plan addresses:
- Phasing by roof area so the building is never fully exposed, with daily dry-in.
- Material hoisting, crane days and resident notices.
- Protection of balconies, pool decks, entrances and parked cars.
- Rooftop mechanical shutdowns coordinated with building management.
- Weather hold points and how exposed work is secured before storms.
Perkins’ published condo records include a re-roof of an occupied five-story waterfront condominium in Coconut Grove on Biscayne Bay, a roof restoration on the 22-story Majestic Towers in Bal Harbour, a re-roof of rooftop A/C tower enclosures at Pinnacle Condominium in Sunny Isles Beach, and a clay barrel tile re-roof on Fisher Island, a private ferry-access condominium and villa community where deliveries and staging require coordination. Each shows how access and residents shaped the roofing scope.
6. Specify HVHZ-approved systems where required
In Miami-Dade and Broward, roofing products must carry the appropriate Miami-Dade Notice of Acceptance (NOA) [8]. Miami-Dade has noted that HVHZ code and test-protocol changes affect some existing underlayment NOAs [8]. Make sure the specification lists current approvals for the exact system proposed. With the 9th Edition of the Florida Building Code listed to take effect December 31, 2026, also confirm which code edition your permit will fall under.
7. Read the warranty terms before comparing prices
Ask for the manufacturer’s system warranty (term, whether it covers materials only or labor too, and inspection or registration requirements) and the contractor’s workmanship warranty. A manufacturer system warranty on a low-slope roof may carry a separate per-building fee and a minimum slope requirement. Record the expected warranty term in the building’s maintenance file so the next SIRS has it.
8. Watch the conflict-of-interest rules
If a firm bids on your milestone inspection or SIRS and also intends to bid the resulting repair work, it must disclose that in writing [5]. Keep the roles clear. The reserve professional sets the SIRS figures; contractors provide condition information and pricing.
Miami-Dade 40-year recertification: the 90-day report window
Miami-Dade County has required building recertification since 1975 [6]. For decades the first one came when a building turned 40, which is why owners still call it “40-year recertification.” Ordinance 22-57, adopted June 1, 2022, rewrote the program in Section 8-11(f) of the Code of Miami-Dade County [9].
Which schedule applies. Buildings built on or before 1982 keep the 40-year start and recertify every 10 years after that [9]. Buildings built from 1983 to 1992 had to complete an initial recertification by December 31, 2024 [6][9]. Buildings built in 1993 or later recertify at 30 years, and condominium and cooperative buildings three stories or taller within three miles of the coastline built in 1998 or later at 25 years, then every 10 years [6]. Single-family homes, duplexes, and buildings with an occupant load of 10 or fewer and 2,000 square feet or less are exempt [6].
The clock starts with the county’s notice. The Building Official sends the owner a Notice of Required Inspection, plus courtesy notices two years and one year before the recertification year. A missed courtesy notice does not excuse the owner [9]. Within 90 days of the Notice of Required Inspection, the owner must furnish a written report certifying that the building is structurally and electrically safe, or has been made safe, for continued occupancy [9]. The report is prepared by a professional engineer or architect registered in Florida. For a threshold building, a structural engineer prepares the structural portion and an electrical engineer the electrical portion [9]. A report counts as timely anywhere from two years before the recertification anniversary to 90 days after the notice, including any extension [9]. The county charges a late fee for reports filed after 90 days [6].
The extension is short and conditional. The Building Official may grant an extension of not more than 60 days to submit the report or to obtain necessary permits. The engineer or architect must request it in writing, with a signed and sealed statement that the building may continue to be occupied while it goes through recertification [9][6]. If the owner neither files the report nor asks for an extension, the Building Official may, after notice, order the electrical utilities disconnected when that inaction leaves it uncertain whether the building can safely stay occupied [9].
When the report calls for repairs. The owner has a total of 150 days from the Notice of Required Inspection to complete repairs that do not need a permit and to obtain the permits for those that do. Permitted work then follows the permit’s own timeline [9]. While repairs are under way, the engineer or architect gives the Building Official a letter on whether the building can stay occupied; each letter is valid for no more than 180 days [9]. When the repairs are done, the same professional files an amended report recertifying the building [9].
| Miami-Dade recertification (County Code §8-11(f)) | State milestone inspection (§553.899, F.S.) | |
|---|---|---|
| Buildings covered | All buildings except single-family homes, duplexes and minor structures [6][9] | Condominium and cooperative buildings three habitable stories or more [1] |
| First inspection | 40 years if built on or before 1982; 30 years for newer buildings; 25 years for certain coastal condos and co-ops [6][9] | By December 31 of the year the building turns 30, or 25 where the local enforcement agency requires it [1] |
| After the notice | Report within 90 days; extension of up to 60 days [9] | Phase one report within 180 days [1] |
| Who inspects | Florida-registered engineer or architect; structural and electrical engineers for threshold buildings [9] | Florida-licensed architect or engineer [1] |
| Scope | Structural and electrical condition [9] | Structural; phase two only if phase one finds substantial structural deterioration [1] |
One inspection in Miami-Dade. The amended ordinance says that for a building that needs a milestone inspection, the county recertification “shall serve as compliance” with the milestone requirements of section 553.899 [9]. The county’s 2025 guidelines describe its program as synonymous with the state milestone program, combining phase one and phase two into a single inspection [10].
Where the roof comes in. Recertification is an engineer’s inspection, not a roof survey, but the county’s guidelines tell the inspector what to look for on roofs [10]:
- On sloped tile roofs, deflection from deteriorated rafters or joists, and valley and base flashing at roof penetrations.
- On flat built-up roofs, deflection too. The guidelines note these roofs “will generally be approaching expected life limits at the age when building recertification is required,” and list blisters, wrinkling, alligatoring, loss of gravel, punctured or loose base flashings and loose counterflashing as signs of trouble.
- Gypsum roof decks damaged by sustained leakage, corroded reinforcing in concrete roof systems, and loss of uplift anchorage on roof decks.
Ninety days is not long enough to design, permit and install a new roof. If you know the roof leaks, have it inspected, repaired and documented before the engineer arrives, and keep the paperwork for the report. If the report calls for roof work that needs a permit, the 150-day window is the time to get that permit. Perkins does not prepare recertification reports; they must come from a registered engineer or architect. We can inspect the roof, document its condition and do the repairs or re-roof the engineer calls for.
Broward and how the programs relate
Broward. Broward County’s Board of Rules and Appeals administers a Building Safety Inspection Program that began as a 40-year program in 2006 [7]. It has since been revised, and the timing that applies to your building depends on the current program rules and your municipality.
How they relate. In Miami-Dade, the county recertification is the milestone inspection for buildings that need one [9][10]. Elsewhere, the local enforcement agency may accept an earlier structural inspection report if it substantially complies with the state requirements [1]. Confirm with your building department which inspection satisfies which requirement for your building.
Turn the roof findings into a construction brief
Keep the professional report with its stated limitations, then list the roof areas, observed defects, access restrictions and decisions the board needs to make. The condo replacement guide explains the project-planning conversation. For condo and high-rise construction, ask the proposal to identify the roof scope and responsible professionals separately from the association’s inspection and reserve-study obligations.
Frequently asked questions
Does the milestone inspection include the roof? It is a structural inspection by a licensed architect or engineer [1]. The inspector may note roof leaks or conditions that affect structure, but roof service life and replacement cost belong in the SIRS [2].
Is the roof required in our SIRS? Yes. The roof is the first item listed in section 718.112(2)(g) [2]. The study must state its estimated remaining useful life and replacement cost or deferred maintenance expense [2].
Can owners vote to skip or reduce roof reserves? Not for budgets adopted on or after December 31, 2024, in a unit-owner-controlled association that must obtain a SIRS [2]. A temporary pause or reduction for up to two consecutive annual budgets after a milestone inspection is allowed through December 31, 2028 [5].
When is our SIRS due? For unit-owner-controlled associations existing on or before July 1, 2022, the deadline was December 31, 2025, so an association without a completed SIRS is already past it. If a milestone inspection is due on or before December 31, 2026, the SIRS may be done alongside it, but no later than December 31, 2026 [2]. Your association attorney should confirm your specific deadline.
Our building is on the coast. Is the first inspection at 25 years? Only if your local enforcement agency requires it. The fixed 3-mile coastal rule was replaced in 2023 with local discretion based on environmental conditions [1][4]. Miami-Dade applies 25 years to certain coastal condominiums [6].
How long do we have to file a Miami-Dade recertification report? Ninety days from the county’s Notice of Required Inspection. The Building Official may extend that by no more than 60 days, on a written request from the engineer or architect with a signed and sealed statement that the building can stay occupied [9].
Can a roofing contractor prepare our SIRS? The SIRS must be performed or verified by a licensed engineer, a licensed architect or a certified reserve specialist [2]. A roofing contractor can provide condition findings and replacement pricing for the professional to consider, but construction pricing does not replace the study or the professional’s judgment.
Can residents stay in the building during a re-roof? Often, with phasing and protection. It depends on the scope, access and building condition. The occupancy plan should be agreed with the project team and, where required, the building department.
How far ahead should we plan a condo re-roof? Allow time for design or specification, bidding, board approval, funding, permitting and material lead times. Starting when the SIRS shows fewer than five years of remaining life gives the board room to phase the work and the funding.
Your next step
When the study points to a re-roof, our condo roof replacement guide for boards covers approvals, the competitive-bid rule, special-assessment notices and comparing bids.
If your board is preparing a SIRS or acting on one, bring the roof sections of the study, any milestone inspection findings, roof drawings and leak history. Perkins can inspect the roof, document its condition and provide a written re-roof or restoration scope. Request a board consultation or read more about our condo and high-rise services.
This guide is general information, not legal, engineering or financial advice. Statutes change; the citations below were checked in September 2026 (the Miami-Dade ordinance, guidelines and county page on September 29, 2026). Confirm your association’s obligations with its attorney, its licensed professionals and the local enforcement agency.
Information sources
- Section 553.899, Florida Statutes (2026) — Mandatory structural inspections for condominium and cooperative buildings. https://www.flsenate.gov/Laws/Statutes/2026/553.899
- Section 718.112, Florida Statutes (2026) — Bylaws; reserves (2)(f) and structural integrity reserve study (2)(g). https://www.flsenate.gov/Laws/Statutes/2026/718.112
- Chapter 2022-269, Laws of Florida (SB 4-D, 2022 Special Session D). https://laws.flrules.org/2022/269
- Florida Senate, SB 154 (2023) bill summary. https://www.flsenate.gov/Committees/BillSummaries/2023/html/154
- Florida Senate, CS/CS/HB 913 (2025) bill summary. https://flsenate.gov/Committees/BillSummaries/2025/html/913
- Miami-Dade County, Building Recertification. https://www.miamidade.gov/global/economy/building/recertification.page
- Broward County Board of Rules and Appeals, Building Safety Inspection Program. https://www.broward.org/CodeAppeals
- Miami-Dade County, Product Approval Notices. https://www.miamidade.gov/global/economy/board-and-code/product-approval-notices.page
- Miami-Dade County Ordinance No. 22-57 (Amended Agenda Item 7(D), second reading June 1, 2022), amending Section 8-11(f), Code of Miami-Dade County. https://www.miamidade.gov/resources/economy/building/documents/amended-miami-dade-ordinance.pdf
- Miami-Dade County Building Recertification, General Considerations & Guidelines (2025). https://www.miamidade.gov/resources/economy/building/documents/general-consideration-guidelines-2025.pdf