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Multiple Deadlines Already Passed

SB4-D Compliance Deadlines: Where Does Your Building Stand?

By Florida Construction Specialists|

Florida's condominium structural safety legislation has established a series of mandatory deadlines for milestone inspections, Structural Integrity Reserve Studies, and reserve funding. As of February 2026, several of these deadlines have already passed, and buildings that have not complied face escalating consequences.

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As of February 2026, Multiple SB4-D Deadlines Have Already Passed

The December 31, 2024 milestone inspection deadline for buildings with certificates of occupancy before July 1992 has passed. The December 31, 2025 SIRS completion deadline and the milestone inspection deadline for 1992-1994 buildings have also passed. If your building has not completed these requirements, your association may already be facing compliance exposure including insurance non-renewal, mortgage restrictions, and potential board liability.

Complete SB4-D Deadline Calendar

The following table reflects the current state of all SB4-D compliance deadlines as of February 2026. Status indicators show whether each deadline has passed, is currently in effect, or is still ahead.

PAST DUEDecember 31, 2024

Milestone inspection: buildings with CO before July 1, 1992

Buildings that received their certificate of occupancy before July 1, 1992 were required to complete their initial milestone structural inspection by this date.

PAST DUEDecember 31, 2025

Milestone inspection: buildings with CO between July 1992 and December 1994

Buildings with certificates of occupancy issued between July 1, 1992 and December 31, 1994 were required to complete their milestone inspection by this date.

PAST DUEDecember 31, 2025

SIRS completion for all applicable buildings

All condominium and cooperative buildings three stories or higher were required to complete a Structural Integrity Reserve Study by this date.

IN EFFECTJanuary 1, 2025

Reserve waiver prohibition begins

Associations can no longer waive or reduce reserves for structural components identified in the SIRS. Full funding of structural reserves is now mandatory.

APPROACHINGDecember 31, 2026

Coordinated SIRS and milestone inspection deadline

Deadline for buildings to complete both SIRS and milestone inspection requirements if not already done under earlier deadlines.

ONGOINGYear building turns 30 (or 25 near coast)

Buildings reaching 30 years after January 1, 1995

Buildings with certificates of occupancy after January 1, 1995 must complete their milestone inspection in the year they reach 30 years of age, or 25 years if within three miles of the coastline.

ONGOINGEvery 10 years

Subsequent inspections after initial milestone

After completing the initial milestone inspection, buildings must undergo subsequent inspections every 10 years.

Understanding Your Building's Timeline

Determining which SB4-D deadlines apply to your condominium requires knowing three key facts about your building: when it received its certificate of occupancy, how many stories it has, and how close it is to the coastline.

Determine Your CO Date

Your certificate of occupancy date establishes which deadline tier your building falls under. This date is available from your local building department, your original developer documents, or the county property appraiser. In Tampa, contact Construction Services at (813) 274-3100 or search the Accela permitting system.

Three Stories or Higher

SB4-D milestone inspection requirements apply to condominium and cooperative buildings that are three stories or higher. “Stories” is determined by the building code definition, which counts habitable floors above grade. Parking levels that are partially below grade may or may not count depending on the local building official's interpretation. If your building is at the threshold, consult with the local building department for a definitive determination.

25-Year vs 30-Year Trigger

Buildings within three miles of the coastline must complete their first milestone inspection at 25 years of age. Buildings farther from the coast have until 30 years. In the Tampa Bay area, the vast majority of condominium buildings fall within the three-mile zone due to proximity to Tampa Bay, the Gulf of Mexico, and the Intracoastal Waterway. The local building official makes the final determination on coastal proximity.

HB 913 Changes (Effective July 1, 2025)

House Bill 913, signed into law in June 2025, introduced several significant modifications to the original SB4-D framework. These changes affect reserve funding, reporting requirements, and the financial planning obligations of condominium associations.

Baseline Funding Plan Requirement

SIRS must now include a baseline funding plan demonstrating that reserves for structural components will remain above zero throughout the study period. This replaces the previous approach where associations could choose from multiple funding methodologies. The baseline plan ensures minimum structural reserve adequacy.

$25,000 Threshold (Inflation-Indexed)

The threshold for mandatory reserve funding increased from $10,000 to $25,000, and is now indexed to inflation. Structural reserve components exceeding this threshold must be fully funded according to the SIRS baseline plan. The inflation indexing means this threshold will adjust automatically in future years.

Two-Year Reserve Pause Option

Associations may now pause reserve contributions for up to two fiscal years to prioritize funding of immediate structural repairs. This provision recognizes that associations facing large remediation costs may need to redirect funds from long-term reserves to address urgent structural deficiencies identified during milestone inspections.

Enhanced Conflict-of-Interest Disclosures

Engineers and architects performing milestone inspections and SIRS must now provide enhanced conflict-of-interest disclosures. This includes disclosure of any financial interest in remediation work that might be recommended as a result of the inspection. The provision aims to ensure inspection objectivity.

Online DBPR Reporting Requirement

Condominium associations must now report milestone inspection results and SIRS completion to the Florida Department of Business and Professional Regulation through an online portal. This creates a centralized compliance tracking system and makes non-compliance more visible to regulators, insurance carriers, and prospective buyers.

What Happens When You Miss a Deadline

The consequences of missed SB4-D deadlines are not abstract. They affect insurance availability, property financing, property values, and the personal liability exposure of board members. These consequences tend to compound over time.

Insurance Non-Renewal or Premium Increases

Property insurance carriers are increasingly requiring proof of milestone inspection completion and SIRS compliance as a condition of coverage renewal. Buildings that cannot demonstrate compliance face non-renewal, dramatically increased premiums, or coverage restrictions that leave the association effectively underinsured. In Florida's already constrained property insurance market, losing coverage can be catastrophic for property values.

Mortgage and Financing Restrictions

Fannie Mae, Freddie Mac, and FHA have implemented lending restrictions for condominium units in buildings that are not in compliance with structural inspection requirements. Lenders may decline to issue mortgages for units in non-compliant buildings, which directly reduces the pool of eligible buyers and depresses unit sale prices throughout the building.

Code Enforcement and Unsafe Building Proceedings

Local building officials have the authority to issue code violations for non-compliance with SB4-D requirements. In severe cases, this can escalate to unsafe building proceedings that may ultimately require building evacuation. While this is an extreme outcome, the legal framework exists and has been applied in South Florida jurisdictions.

Board Member Personal Liability

Condominium association board members have a fiduciary duty to maintain the building and comply with applicable laws. Boards that fail to initiate milestone inspections or address inspection findings may face personal liability claims from unit owners, particularly if non-compliance results in financial harm such as lost property value, increased assessments, or insurance unavailability.

Florida Statute 553.899

Mandatory Structural Inspections for Condominium and Cooperative Buildings

Establishes milestone inspection requirements for condominium and cooperative buildings three stories or higher. Buildings must complete initial inspections at 25 years (within 3 miles of coast) or 30 years, with subsequent inspections every 10 years. Phase 2 remediation, when required, must commence within 365 days of the inspection report. As amended by HB 913 (2025), includes baseline funding plans for structural reserves and enhanced conflict-of-interest disclosures.

View F.S. 553.899

SB4-D Deadline Questions

Frequently asked questions about SB4-D compliance deadlines, milestone inspection timing, and the consequences of non-compliance.

As of February 2026, the December 31, 2024 milestone inspection deadline for buildings with certificates of occupancy issued before July 1, 1992 has passed. The December 31, 2025 deadline for buildings with certificates of occupancy between July 1992 and December 1994 has also passed. Additionally, the December 31, 2025 SIRS (Structural Integrity Reserve Study) completion deadline has passed for all applicable buildings. Associations that have not met these deadlines face increasing insurance, mortgage, and legal exposure.

The next major deadline is December 31, 2026, which is the coordinated SIRS and milestone inspection deadline for buildings that have not yet completed both requirements. Beyond that, buildings that reach 30 years of age after January 1, 1995 must complete their milestone inspection in the year the building turns 30 (or 25 years if within three miles of the coastline). Subsequent inspections are required every 10 years after the initial milestone inspection.

Your building's certificate of occupancy (CO) date is typically available from your local building department. In Tampa, you can contact Construction Services at (813) 274-3100 or search the Accela permitting system online. In other Tampa Bay jurisdictions, contact the county or city building department. Your condo association's original developer documents or property appraiser records may also contain this information. The CO date determines which milestone inspection deadline applies to your building.

The inspection timeline depends on your building's proximity to the coastline. Buildings located within three miles of the coast must complete their first milestone inspection at 25 years. Buildings farther than three miles from the coast have until 30 years. In the Tampa Bay region, the majority of condominium buildings fall within the three-mile coastal zone due to proximity to Tampa Bay, the Gulf of Mexico, and the Intracoastal Waterway. If there is any ambiguity about your building's classification, the local building official makes the determination.

HB 913, effective July 1, 2025, made several significant changes to the SB4-D framework. It introduced a baseline funding plan requirement for SIRS, meaning reserve studies must now demonstrate that reserves remain above zero. The reserve threshold for mandatory funding increased from $10,000 to $25,000, indexed to inflation. Associations may now pause reserve contributions for up to two fiscal years to prioritize immediate structural repairs. The bill also added enhanced conflict-of-interest disclosure requirements for engineers and architects, and mandated online reporting to the Florida DBPR.

Florida law does not provide a formal extension process for missed SB4-D milestone inspection deadlines. However, associations that are actively engaged in the inspection and remediation process, even if past their original deadline, are in a stronger position than those that have taken no action. The practical consequences of missed deadlines, including insurance non-renewal, mortgage restrictions, and potential code enforcement, tend to escalate over time rather than triggering immediate penalties. The most important step for any past-due association is to begin the inspection process immediately and document the timeline of engagement.

Call to Discuss Your Building's Compliance Timeline

Whether your building has already missed a deadline or you need to understand which requirements apply, Florida Construction Specialists can help you assess your compliance status and develop a remediation plan.

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