SIRS, Milestone Inspections, and Your Roof

Since the Champlain Towers South collapse in Surfside in 2021, Florida has rebuilt the rules for how condominium associations inspect their buildings and fund their reserves. For a board, two of those rules matter most, and both touch the roof directly: the milestone inspection and the Structural Integrity Reserve Study (SIRS). This article explains what each one is, how they intersect with the roof, and what a board should ask its roofer to provide so that meeting these obligations is cheaper and less stressful. The statutory details here are current as of the 2025 legislative changes; specific deadlines and thresholds should always be confirmed with the association's attorney for your particular building.

What is a SIRS, and does it cover the roof?

A Structural Integrity Reserve Study, or SIRS, is a required study that determines how much money a condominium association must set aside in reserves to maintain and replace its major structural components — and yes, the roof is one of the components a SIRS must cover. The SIRS requirement lives in Florida Statute 718.112 and applies to condominium and cooperative buildings that are three or more habitable stories tall.

A SIRS must, at a minimum, study these components and set a reserve funding schedule for each:

• Roof (the membrane, coatings, drainage, and flashing)
• Load-bearing walls and the primary structural system
• Fire protection systems
• Plumbing
• Electrical systems
• Waterproofing and exterior painting
• Windows and exterior doors (where the association maintains them)
• Any other item with a deferred maintenance or replacement cost that exceeds $25,000 and affects one of the above

For each component, the study estimates its remaining useful life and its future replacement cost, then calculates how much the association needs to contribute to reserves each year to have the money ready when the work comes due. The roof is usually one of the largest single line items in the study, which is exactly why its condition and remaining life deserve careful attention.

A critical point that changed recently: under the 2025 law (HB 913), owners can no longer vote to waive or reduce the reserve funding for these listed structural components the way associations often did in the past. Reserves for the roof and the other SIRS components must now be funded on the schedule the study calls for. Boards that were used to waiving reserves each year to hold down dues no longer have that option for these items.

What is a milestone inspection, and when is it required?

A milestone inspection is a structural safety inspection, performed by a licensed engineer or architect, that Florida requires for condominium and cooperative buildings of three or more habitable stories once they reach a certain age. It is defined in Florida Statute 553.899 and was created by the post-Surfside legislation in 2022.

The timing works like this:

• The first milestone inspection is generally required when the building reaches 30 years of age, measured from the date its certificate of occupancy was issued.
• After the first inspection, milestone inspections recur every 10 years.
• For buildings near the coast, the trigger can come earlier. The original 2022 law set 25 years for buildings within three miles of the coastline. A 2024 amendment (HB 1021) changed this so that 25 years is no longer an automatic statewide rule; instead, the local enforcement agency has the authority to require the first inspection earlier — as early as 25 years — based on coastal proximity and local conditions. Because this now varies by locality, a coastal board should confirm its specific deadline with the local building department rather than assume a single number.

A milestone inspection has two possible phases. Phase 1 is a visual inspection; if the engineer finds signs of substantial structural deterioration, a more detailed Phase 2 inspection follows. The roof interacts with this because roof leaks are a leading cause of the concealed water intrusion and structural deterioration that a milestone inspection is designed to catch. A roof that has been allowed to leak into the structure below can turn a routine Phase 1 into a costly Phase 2 and a repair order — one more reason twice-yearly inspections pay off before an engineer ever arrives.

One more 2025 clarification worth knowing: the "three habitable stories" threshold now explicitly excludes floors used only for parking, storage, or mechanical equipment, so a building's story count for these purposes is based on its habitable floors.

How does the roof's remaining life feed the reserve schedule?

The roof's remaining useful life feeds the reserve schedule by setting the clock the SIRS funds against — the shorter the remaining life and the higher the replacement cost, the more the association must set aside each year. This is the mechanical heart of why roof documentation matters for reserves.

Consider two identical buildings. Both have a roof that a reserve analyst, absent better information, might assume has a typical remaining life. In the first building, the board has years of dated inspection reports and a maintenance record showing the roof is in good condition and tracking toward the top of its expected service life. In the second, there are no records, so the analyst has to make a conservative assumption. The first building can often justify a longer remaining-life estimate, which spreads the replacement cost over more years and lowers the required annual contribution. The second building gets the conservative number, and its owners pay more into reserves sooner.

The remaining-life estimate is not a fixed fact; it is a professional judgment, and professional judgment is only as good as the evidence behind it. A well-documented roof gives the reserve analyst evidence to work from — the same roof file that shapes how an insurer sees the building. An undocumented roof forces guesswork, and guesswork in a reserve study almost always rounds against the association.

Why does documented maintenance make SIRS updates cheaper and easier?

Documented maintenance makes SIRS updates cheaper and easier because it lets the professional preparing the study rely on records instead of rebuilding the roof's history from scratch — and because it supports a realistic, often longer, remaining-life estimate. A SIRS has to be updated periodically, and every update is faster when the roof's condition, repairs, and remaining life are already on the record.

The benefits compound:

• Faster, less expensive studies. The professional spends less time investigating a roof whose history is already documented.
• More favorable and defensible remaining-life estimates. Evidence of good maintenance supports keeping the roof in service to the end of its real life rather than budgeting to replace it early.
• Fewer surprises. A board that has watched its roof age through annual reports is rarely blindsided by a reserve number, because it has seen the trend coming.
• Cleaner milestone inspections. A roof that has not been allowed to leak into the structure gives the milestone inspector less to flag.

In short, the documentation that good maintenance produces is the same documentation the SIRS and milestone processes consume. Keeping it is not extra work for compliance; it is the same work, filed.

What should a board ask its roofer for?

A board should ask its roofer for the documentation that a SIRS professional and a milestone inspector will need — and should ask for it in a form that feeds those processes directly. Specifically, ask for:

• A written roof condition report, with dated photos, issued on a regular schedule rather than only when something breaks.
• A remaining-useful-life estimate for each roof, stated plainly, so it can be handed to the reserve analyst.
• A repair and maintenance log showing what was done and when, which supports both the warranty and the reserve study.
• A capital-planning outlook — a rough forecast of major roof expenses over the next several years — so the roof line in the reserve budget is grounded in reality.
• Manufacturer warranty status, since a valid, documented warranty affects both risk and reserve assumptions.

A roofer who understands the SIRS and milestone framework will produce reports that a reserve analyst and an engineer can use without translation. A roofer who does not may hand the board a repair invoice and nothing more, leaving the association to reconstruct the roof's story every time a study or inspection comes due. If your community is also approaching a flat-roof replacement decision, the same condition report tells you how much life the current roof really has before the reserve line has to fund a new one.