Florida DBPR Amends Condominium Reserve and SIRS Rules: What Boards Need to Know Before Budget Adoption
By Laura Murray, CEO and Co-Founder, Domexa Labs
It's budget season, and the reserve rules just changed. Effective October 4, 2026, the Florida Department of Business and Professional Regulation (DBPR) amended Florida Administrative Code Rule 61B-22.005, the rule that governs condominium reserves. The amended rule expands guidance on reserve funding, changes between pooled and straight-line accounting, structural integrity reserve study (SIRS) updates, and reporting. If your board is finalizing next year's budget, here is what you need to know.
Reserve funding now follows your SIRS
For condominiums required to complete a SIRS, the reserve funding amount for each item or group of items must align with the funding amount in the association's most recently completed SIRS. The rule also states plainly that an association may not alter or manipulate the findings of the SIRS, including remaining useful life and repair or replacement cost estimates.
In practical terms, your SIRS is no longer a report on the shelf. It is the blueprint for your reserve budget.
For condominiums not subject to SIRS requirements, the association must evaluate each line-item asset separately against the minimum reserve threshold the Division publishes on its website each year. The Division adjusts that threshold annually for inflation, so last year's analysis may not hold.
Only a Full SIRS satisfies the ten-year requirement
The rule recognizes three types of SIRS: a Full Structural Integrity Reserve Study, an Update with Site Visit, and a Financial Update Without Site Visit. Every SIRS, including updates and amendments, must be completed on the current DBPR Form CO 6000-10.
The statutory ten-year requirement can only be satisfied by a Full SIRS covering all statutory items. Updates do not reset the ten-year clock.
An association may update the reserve schedule without a new visual inspection only in limited circumstances:
The SIRS with the most recent visual inspection was completed within the preceding 36 months, and the update is limited to changes in reserve funding amounts or estimated replacement costs.
The update relates solely to a change in the funding method, such as a special assessment, line of credit, or loan.
A new visual inspection is required if, since the last inspection, an incident or disaster has occurred that may reasonably be expected to affect the building's structural integrity or life-safety systems. If a repair or replacement changes an item's remaining useful life, the next SIRS must include a visual inspection of that item.
Two new triggers for an updated SIRS
The amended rule tells associations when an existing SIRS is no longer good enough. An updated SIRS is required if either of the following occurs:
The projected year-end reserve balance for any fiscal year differs from the projection in the most recent SIRS by 50 percent or more of the association's most recent annual cash inflows to reserves.
A repair, replacement, or maintenance project on a SIRS item is completed more than two years earlier or later than the schedule in the most recent SIRS.
Both triggers are worth checking now. A delayed project or an underfunded year can quietly put a building out of compliance.
When a SIRS is "completed"
The rule now defines a completed SIRS as the version that has been signed, dated, and delivered to the association by the licensed professional or qualified company that performed it. Preliminary drafts or revisions prepared for internal board review are not completed studies.
That definition matters because it starts the clock on several obligations. Once a completed SIRS is received, the association must:
Distribute or otherwise make the completed SIRS available to unit owners.
File notice of completion with the Division, along with the Affidavit of Acknowledgement on DBPR Form 6000-11, through the association's online account.
Complete and submit the SIRS Reporting form in that same online account for each study, initial or amended.
If a completed SIRS is later amended, replaced, or its reserve schedule is modified in a way that materially affects useful life, cost, funding requirements, or the items included, the distribution and filing requirements apply again.
Pooled vs. straight-line accounting
An association may now change between pooled and straight-line reserve accounting without a unit-owner vote, as long as the change does not alter the authorized purpose, the required funding level, or the restricted use of reserve funds. If balances need to be reclassified between components, all of the following must be true:
All transferred funds remain restricted to statutory reserve purposes.
The total reserve balance is not reduced, and the resulting balances are clearly disclosed in the financial reports and adopted budget.
No reserve funds are used for anything other than repair or replacement of reserve components.
When converting from pooled to straight-line, interest earned in the pooled account is allocated among components in proportion to each component's share of the pooled principal.
An owner vote is still required if the change reduces or eliminates funding for any component, uses reserves for a purpose owners did not approve, or amounts to a waiver, reduction, or repurposing of reserves.
For pooled reserves, the rule also tightens the funding schedule. Annual rates of change may account for inflation or deflation, but may not exceed the annual change in the Consumer Price Index for Urban Consumers (or the Producer Price Index for final demand). Pooled schedules may not include balloon payments, defer contributions to lower current assessments, or front-load contributions to lower future ones.
Other reminders in the rule
Combined payments: If owners pay operating and reserve assessments in one payment, the reserve portion must move to a separate reserve account within 30 calendar days to avoid commingling.
Waivers: For buildings not subject to SIRS, a vote to waive or reduce reserves is effective for one annual budget only. SIRS reserves cannot be waived or reduced.
No adopted budget: Assessments for any period without an adopted budget must include full statutory reserve funding, even if reserves were previously waived or reduced.
Timing: Reserves must be funded at least as often as assessments are due.
What to do before you adopt your budget
Match every reserve line item in the proposed budget to the funding amounts in your most recently completed SIRS.
If your building is not subject to SIRS, test each asset against this year's published threshold.
Check both update triggers: the 50 percent reserve balance variance and the two-year schedule deviation.
Confirm your SIRS is on the current Form CO 6000-10 and that the owner distribution, Affidavit of Acknowledgement, and SIRS Reporting form are complete.
If you use pooled reserves, confirm the inflation assumptions do not exceed CPI and the schedule has no balloon or deferred payments.
If you are considering a switch between pooled and straight-line accounting, document how each condition is met and review it with association counsel.
The bottom line
These amendments reward associations that keep their records current and their deadlines visible. The boards that will struggle are the ones that treat the SIRS as a one-time report rather than the foundation of the budget. At Domexa Labs, we built My Condo Compliance so boards and managers can track SIRS dates, filings, and reserve requirements in one place, before a deadline becomes a problem.
Read the full text of Rule 61B-22.005. Managers and boards should review these changes before finalizing their association's annual budget.
This article is for general information only and is not legal advice. Associations should consult their own counsel and reserve professionals about their specific circumstances.
