Florida Resort Developers, Managers, Owners, and HOAs: Confused About HB 913?

[EDITOR’S NOTE: For decades, Withum has worked alongside resort developers, management companies, homeowners associations, and hospitality organizations throughout Florida and across the United States. The firm’s Hospitality Services team helps boards and managers navigate complex financial reporting, reserve planning, compliance requirements, audits, operational challenges, and emerging regulatory changes. As Florida associations continue adapting to the state’s Structural Integrity Reserve Study (SIRS) requirements, Withum professionals are helping communities understand both the financial implications and practical realities of compliance.]

The State of Florida updated the laws governing Structural Integrity Reserve Studies (SIRS) through House Bill 913, effective July 1, 2025. These changes aim to alleviate some financial pressure on associations while maintaining the state’s long-term building-safety goals. Here’s what you need to know, explained simply, without legal jargon.

What the Update Did Do

1. Gave Associations More Time

The deadline to complete the first SIRS was pushed back from December 31, 2024, to December 31, 2025. This gave communities an extra year to schedule inspections and hire qualified engineers or architects. 

2. Expanded Ways to Fund Required Reserves

The law now authorizes several funding methods beyond regular annual assessments, providing associations with greater financial flexibility.  These options require an affirmative vote of a majority of the entire voting interests. 

• Special assessments: The board may propose a special assessment to fund all or part of the required SIRS obligations. 
• Loans: The association may obtain a loan. The loan proceeds can be incorporated directly into the SIRS funding plan, helping reduce the amount needed through reserve contributions.
• Lines of credit: The association may secure a line of credit. Funds can then be drawn as needed for structural repairs, and the availability of this credit can reduce the required reserve contribution with certain limitations.

3. Allowed Temporary Pauses in Studies and Reserve Payments (Only in Limited Circumstances)

Under certain circumstances, associations have two related options: they may delay conducting the SIRS study, or they may pause or reduce reserve contributions, for no more than two consecutive annual budgets.

An association that has completed the required Milestone Inspection can now delay conducting its SIRS for up to two consecutive budget years following that inspection, allowing time to address any repairs identified by that inspection.

For budgets adopted on or before December 31, 2028, if a Milestone Inspection reveals necessary repairs, an association can, with an affirmative vote of a majority of the entire voting interests, temporarily pause or reduce reserve contributions for SIRS components for no more than two consecutive annual budgets to free up funds for those Milestone-related repairs.

The Milestone Inspection must have been received within the two years preceding the pause, and a SIRS must be obtained within two years after the pause before reserve funding resumes.

4. Clarified Which Buildings Are Covered

The law now makes it clear that SIRS applies only to buildings with three or more “habitable” stories. Garage levels or other non-living spaces do not count as habitable floors. 

5. Raised the Cost Threshold for Required Components

Components now must be included in a SIRS only if they cost $25,000 or more, up from the previous $10,000 threshold. This could reduce the number of items that must be evaluated.   The threshold will also be adjusted annually for inflation.

6. Required New Conflict-of-Interest Disclosures

Professionals bidding to perform the SIRS must disclose if they also plan to bid on repair work associated with their findings, promoting transparency. 

What the Update Didn’t Do

1. It Did Not Remove the Obligation to Complete a SIRS

Associations that meet the criteria (three or more habitable stories) still must complete a SIRS. The requirement itself did not change. 

2. It Did Not Allow Owners to Waive SIRS Reserve Funding

Even though there is more flexibility in how reserves can be funded, owners cannot waive or redirect required SIRS reserves for any other purpose. These reserves remain mandatory. 

3. It Did Not Change the 10-Year Update Cycle

A new SIRS must still be completed at least every 10 years, even if recent repairs were made. 

4. It Did Not Reduce the Safety Components That Must Be Reviewed

The SIRS still must assess major structural elements, including:

• Roof
• Structure (including load bearing walls)
• Electrical systems
• Plumbing
• Fireproofing and fire protection systems
• Waterproofing and exterior painting
• Windows and exterior doors
• Any other item with a replacement cost exceeding $25,000 (threshold changed with this update). 

5. It Did Not Expand Exemptions…mostly

Buildings under three habitable stories remain exempt, as before. The only exemption added is that four-family dwellings (four-family residential buildings) with three or fewer habitable stories above ground are now exempt from the SIRS requirement.

Bottom Line for Owners and Boards

The SIRS update gives communities more time, clarity, and financial tools, but it does not reduce the state’s expectations around long-term building safety. Boards should continue to plan ahead, communicate clearly with owners, and budget responsibly to ensure the association remains compliant and financially stable.

ABOUT THE AUTHORS

Lena Combs, CPA, CGMA, is a Partner and leader of Withum’s Hospitality Services Team. She has spent much of her career advising resort, hospitality, vacation ownership, and community association clients on accounting, auditing, reserve planning, governance, and financial management issues.

Maida Calvert, CPA, CITP, is a Manager within Withum’s Hospitality Services practice. She works closely with hospitality and association clients, helping boards and management teams interpret regulatory requirements, strengthen financial processes, and make informed operational decisions.

ABOUT WITHUM

Withum is a forward-thinking, technology-driven advisory and accounting firm, committed to helping clients in the hospitality industry be more profitable, efficient, and productive in the modern business landscape. For further information about Withum and their cybersecurity, digital advisory and hospitality services teams, contact Lena Combs (LCombs@Withum.com) at (407) 849-1569, or visit www.withum.com/hospitality.