Milestone Inspection, Recertification, or SIRS — Which Does Your Building Owe?

A milestone inspection is a structural inspection required by Florida Statute 553.899 for any building three habitable stories or more in height, as determined by the Florida Building Code, that is subject in whole or in part to condominium ownership under Chapter 718 or cooperative ownership under Chapter 719. It must be performed by December 31 of the year the building reaches 30 years of age, measured from the date its certificate of occupancy was issued, and every 10 years after that. The inspection is performed by an engineer licensed under Chapter 471 or an architect licensed under Chapter 481, and the resulting report is filed with the local building department. It exists to answer one question: is this building structurally sound right now.

The inspection runs in two phases. Phase One is a visual, qualitative examination of the building, and it must be completed within 180 days of the date the owner receives written notice from the local enforcement agency. If the engineer finds no substantial structural deterioration, Phase One is the entire inspection and nothing further is required. Phase Two applies only where Phase One identifies substantial structural deterioration, and it uses destructive or nondestructive testing on the distressed areas to establish how far that deterioration extends. Statewide reporting for 2024 and 2025 records 8,736 Phase One inspections against 1,575 Phase Two inspections — roughly 18 percent escalating, though those figures are self-reported and incomplete.

A structural integrity reserve study, usually called a SIRS, is a reserve study mandated by Florida Statute 718.112(2)(g) for residential condominium associations, covering each building on the property that is three habitable stories or higher. It must be completed at least every 10 years. Associations existing on or before July 1, 2022 were required to complete their first study by December 31, 2025 — a deadline extended from December 31, 2024 by HB 913. Where a milestone inspection is required by December 31, 2026, the study may be performed at the same time, but no later than that date. It answers a different question from the milestone inspection: not whether the building is sound today, but what its major components will cost to replace and when.

The statute sets the minimum scope. The study must cover the roof; the structure, including load-bearing walls and other primary structural members and systems; fireproofing and fire protection systems; plumbing; electrical systems; waterproofing and exterior painting; and windows and exterior doors. It must also cover any other item with a deferred maintenance expense or replacement cost exceeding $25,000, or the inflation-adjusted amount published annually by the division, whichever is greater. HB 913 added two requirements that change how the study is used: it must include a baseline funding plan keeping the reserve balance above zero, and it must distinguish the mandatory components from other items the study merely recommends.

Building recertification is a county-level requirement, entirely separate from the state milestone inspection, that an aging building be certified as structurally and electrically safe by a licensed engineer or architect on a recurring schedule. The term "40-year recertification" persists because that was the interval for decades, but the schedules have changed. Miami-Dade restructured its program in June 2022: coastal condominium and cooperative buildings within three miles of the coast that are three storeys or taller now recertify at 25 years if built in 1998 or later, and buildings generally outside that coastal band recertify at 30 years if built in 1993 or later, every 10 years thereafter. Buildings built on or before 1982 that already went through the 40-year programme continue on their existing schedule.

Broward County operates something different again. Its Building Safety Inspection Program is governed by Board of Rules and Appeals Policy 05-05 and administered by each individual municipality, so the operative trigger age and process vary by city — confirm yours with your local building department rather than assuming a county-wide rule. Two features distinguish it sharply from the state requirement: it reaches commercial buildings as well as residential, and it is not limited to condominium or cooperative ownership or to buildings of three or more storeys. Palm Beach County has no unified county programme at all; municipalities adopted their own ordinances, and Boca Raton's sets recertification at 30 years, or 25 for condominiums and cooperatives within three miles of the coastline.

Not automatically, and this is the most common misunderstanding in the market. Statute 553.899 sets the milestone inspection requirement at 30 years for every covered building. It then permits a local enforcement agency to determine that local circumstances — including environmental conditions such as proximity to salt water — require inspection at 25 years instead. That is a discretionary determination made by your local building department, not a statewide coastal rule, and it has been discretionary since SB 154 in 2023. Any source telling you your coastal condominium must be inspected at 25 years under state law is describing a rule that does not exist in that form. Confirm what your jurisdiction has actually adopted before commissioning anything.

The confusion has a specific source. Miami-Dade County's recertification programme does use a three-mile coastal test, and it does set 25 years for coastal condominium and cooperative buildings built in 1998 or later. Boca Raton's ordinance uses a similar three-mile test. Those are county and municipal programmes operating under separate authority, and their triggers have been widely repeated as though they were the state rule. A building in Miami-Dade may well owe a recertification at 25 years and a state milestone inspection at 30 — two obligations, two clocks, arriving five years apart, and satisfying neither one satisfies the other.

Both the milestone inspection statute and the SIRS statute set their threshold at three habitable stories, and both defer to the Florida Building Code for how storeys are counted. Neither statute defines the term itself. This matters more than it sounds: a building with ground-floor parking and two residential levels above may not reach three habitable storeys, which would place it outside both requirements entirely. Associations get this wrong in both directions — commissioning inspections they do not owe, or skipping ones they do. If your building sits near the threshold, have an engineer or your building department make the determination in writing before you either commission or skip an inspection.

Yes, and in most cases they should be. The two requirements overlap substantially in field work — both examine the roof, the structure, and the building envelope — so performing them under one engagement avoids paying twice to mobilise, gain access, and inspect the same components. The statute contemplates this directly: where a milestone inspection is required by December 31, 2026, the structural integrity reserve study may be performed simultaneously, though no later than that date. The two deliverables remain separate reports serving separate statutory purposes. A milestone inspection does not satisfy the SIRS requirement, and a SIRS does not satisfy the milestone inspection requirement, however much of the fieldwork they share.

Where a county recertification is also due in the same window, the same logic applies with one important caveat. Recertification requires an electrical certification as well as a structural one, and in Miami-Dade the electrical scope includes infrared thermography on systems operating at 400 amperes or greater, performed by a certified technician with the system energised and under load. That is a different discipline from the structural work and needs to be scheduled around building operations. Firms that hold both structural and electrical capability can combine the visits; firms that hold only one will subcontract the other, which is worth establishing before you sign anything.

That is your board's decision, but Florida now regulates the disclosure. Under HB 913, effective July 1, 2025, a design professional performing a milestone inspection must disclose in writing any intent to bid on the repair work they recommend, along with any financial or familial relationship bearing on the engagement. If that disclosure is not made, the contract is voidable. The underlying concern is straightforward: an inspector who stands to win the repair contract has a financial incentive to find more work than the building needs. Ask for the disclosure in writing before you sign, whoever you hire, and treat reluctance to provide it as informative.

Contact your building department and retain a professional rather than letting the date pass quietly. Statute 553.899 does not itself set a monetary penalty; it requires local enforcement agencies to prescribe timelines and penalties, so consequences depend on your jurisdiction and can range from fines to an unsafe structure determination. There is a formal path for associations running late: a local enforcement agency may grant an extension for good cause where an inspection contract has been executed but the work cannot be completed in time. Statewide, 1,587 extensions were granted across 2024 and 2025, the overwhelming majority in coastal counties. Being late with work under contract is a materially better position than being late with nothing.

The SIRS deadline of December 31, 2025 has now passed, so an association without a completed study is out of compliance today. The practical consequences arrive from several directions at once rather than as a single penalty. Boards face fiduciary duty exposure. Lenders and secondary-market purchasers increasingly request evidence of milestone inspection and reserve study status, and gaps can affect unit financing for every owner in the building. Buyers and their attorneys ask for these documents during due diligence. The remedy is the same either way — commission the study — and the cost of doing it late is considerably lower than the cost of the alternative.