Florida SB 4-D Explained: What Condo Boards Need to Know About Milestone Inspections and SIRS

Much of Florida's current condominium structural-compliance landscape traces back to one law: SB 4-D. Passed in 2022 in direct response to the Champlain Towers South collapse in Surfside, it created the state's Milestone Inspection and Structural Integrity Reserve Study (SIRS) requirements — and it has been amended twice since. A board that learned the rules once, in 2022, and hasn't revisited them since is very likely working from an outdated picture: one deadline has already moved, and it has now passed.

This post is the foundation piece: what SB 4-D actually did, how it has changed since, where things stand today, and the misconceptions that come up most often in board meetings. If you're looking for the specific difference between a Milestone Inspection and a SIRS, or the full detail on what HB 913 changed, those are covered in the companion posts linked below — this one is where to start.

This post reflects Florida law current as of August 2026, including SB 154 (2023) and HB 913 (2025). The 2026 legislative session did not add further changes to these specific requirements.

Many Florida boards are still working from a 2022 understanding of SB 4-D. Since then, two amendments — SB 154 (Chapter 2023-203) in 2023 and, more substantially, HB 913 (Chapter 2025-175) in 2025 — have changed deadlines, funding rules, and reporting requirements. The most consequential change: HB 913 moved the one-time initial SIRS deadline from December 31, 2024 to December 31, 2025. That deadline has now passed.

SB 4-D itself (Chapter 2022-269, Laws of Florida) created two separate, ongoing obligations for qualifying condominium and cooperative associations three habitable stories or more: mandatory Milestone Inspections, timed to the building's age from its Certificate of Occupancy date, and mandatory SIRS, which require associations to study and reserve for major structural components and bar owners from voting to waive that funding for the components a SIRS covers. Any qualifying association that hasn't completed its initial SIRS is currently out of compliance, not approaching a future deadline — the first thing to confirm is whether that applies to your building.

A Milestone Inspection asks what condition the building is in today. A SIRS asks what the association needs to financially plan for over the coming decades. Neither substitutes for the other, and a building can be current on one while overdue on the other — including, right now, being overdue on the SIRS specifically.

Not every building owes either requirement. Both statutes apply the same size exemption: single-family, two-family, three-family, and four-family dwellings with three or fewer habitable stories above ground are exempt from Milestone Inspection under F.S. §553.899, and are likewise exempt from SIRS under F.S. §718.112(2)(g). Buildings less than three stories in height are also exempt from SIRS. If your association is a smaller property, confirm exemption status with your local enforcement agency before assuming either requirement applies — and before assuming it doesn't.

"We already did our 40-year recertification, so we're covered." In Broward and Miami-Dade, the county recertification program is how the state milestone inspection requirement is administered and satisfied — one inspection process, not two separate obligations. But completing an older recertification cycle does not automatically satisfy the current one. The trigger years have also changed: Broward now uses a 25-year cycle, and Miami-Dade uses 25 or 30 years depending on building type and location (not the legacy 40-year/50-year framing). Confirm your building's current compliance status with your local enforcement agency rather than assume a past recertification covers today's requirement.

"SB 4-D only applies to coastal buildings." The statewide default trigger is building age from the Certificate of Occupancy date — 30 years. Local enforcement agencies may require the first inspection as early as 25 years where local conditions justify it, including proximity to salt water — but this is a local judgment call, not an automatic statewide rule tied to a fixed distance from the coast. The age-based 30-year trigger applies regardless of location; a building doesn't need to be coastal to be covered. Confirm your building's applicable trigger with your local enforcement agency rather than assuming exemption based on distance from the water.

"We can still get to our SIRS whenever works for the board." This was true in the sense that the deadline could feel distant — it no longer is. An association that hasn't completed its initial SIRS isn't facing an upcoming requirement; it's out of compliance with a deadline already behind it, and the obligation doesn't go away by waiting longer. Completing the study is the only way to resolve it, and after that, the same requirement recurs every 10 years.

A Milestone Inspection and a SIRS are compliance instruments, not guarantees. A Milestone Inspection documents a licensed engineer's or architect's observed structural conditions at the time of inspection — it is not a repair plan, and it does not certify that a building will remain in that condition indefinitely. A SIRS establishes a long-term funding plan for specific structural components — it does not repair anything, and completing one satisfies a financial-planning requirement, not a maintenance one.

Both are necessary, and neither substitutes for ongoing maintenance, for acting on a Phase 2 report's findings, or for an engineer's evaluation when conditions change between inspections. A board that treats a completed Milestone Inspection or SIRS as the finish line — rather than as one input into how it maintains and funds the building — is missing what these requirements are actually for. Compliance documents describe what's required; an engineering evaluation describes the physical condition of the building. Both matter, but they answer different questions.

SB 4-D as originally passed in 2022 was not the final word. SB 154 in 2023 and HB 913 in 2025 both made real, substantive changes to timing, funding mechanisms, and disclosure rules — not minor cleanup language, and in HB 913's case, a change to a deadline that has now come and gone. Several of those changes directly affect board responsibilities specifically, not just associations: HB 913 now requires an officer or director to personally sign an affidavit acknowledging receipt of the completed SIRS, added a baseline funding plan requirement to the SIRS report itself (the study must show how reserves stay funded throughout the plan period, not just what components need reserving), and requires engineers and contractors to disclose in writing if they intend to bid on repair work their own inspection or study identifies. A board, property manager, or vendor working from the 2022 text alone is operating on rules that are, in places, no longer accurate. Treat SB 4-D as a framework that continues to change, not a fixed set of dates from when the law first passed — and confirm current requirements with a licensed engineer familiar with your specific building and jurisdiction before assuming your association's status.

Three questions settle most of what a board needs to know: What is your building's Certificate of Occupancy date and your association's Declaration recording date — the two separate clocks that start Milestone Inspection and SIRS, respectively? Does a size exemption apply to your building? And has your initial SIRS actually been completed? If any of those three answers isn't confirmed, that's the starting point — before worrying about anything else in this post.

• For the Milestone Inspection vs. SIRS distinction in detail, see Milestone Inspections vs. SIRS in Florida: What Condo Boards Need to Know.
• For the full detail on HB 913 — including reserve funding flexibility, the board affidavit, and the new conflict-of-interest disclosure rules — see Florida HB 913: The SIRS Deadline Has Passed — What Broward, Miami-Dade, and Palm Beach Boards Must Do Now.
• A qualified engineer familiar with Milestone Inspections and SIRS can help your board understand what applies to your specific building and what to do next.