The statute told Florida condo boards what a Structural Integrity Reserve Study (SIRS) must cover. On October 4, 2026, the Division’s amended Rule 61B-22.005 told them how: which study types count, when an update is mandatory, what paperwork to file, and that the adopted budget must align with the study’s findings.
That timing matters. Calendar-year associations are building 2027 budgets now. If your last SIRS is unsigned, never filed, or out of sync with the cash on hand, the new rule is the checklist—not a blog roundup.
This is a practical board briefing from Felten Property Assessment Team (Safety Harbor / Tampa Bay), written in RS/PRA voice. It is technical guidance for boards and managers, not legal advice. Have association counsel review owner-vote and notice mechanics before you rely on any vote path described below.
As of October 5, 2026, further rule development on annual funding adjustments and pooled vs. straight-line language is already noticed. Recheck flrules.org before you publish board packets that quote this post.
What changed on Oct. 4, 2026
Amended Rule 61B-22.005 (Reserves) became effective October 4, 2026 (final notice 31410072, rule file date September 14, 2026). In plain board language, the amendment:
- Defines three SIRS products: Full, Update with Site Visit, and Financial Update Without Site Visit
- Requires every SIRS (including updates and amendments) on current DBPR Form CO 6000-10
- Sets two mandatory update triggers (a projected year-end reserve-balance variance equal to or exceeding 50% of the most recent annual cash inflows to reserves; a schedule deviation of more than two years) and requires a visual inspection on any update made after an incident or disaster that may affect structural integrity or life-safety systems
- Defines “completed” as signed, dated, and delivered—drafts do not count
- Requires filing the completion notice, Affidavit of Acknowledgement (Form 6000-11), and the SIRS Reporting form through the association’s DBPR online account
- Bars altering or manipulating SIRS findings when you fund
- Clarifies pooled vs. straight-line switches and when an owner vote is required
- Limits Alternative Funding Method (AFM) to multicondominium associations, with a 60/30/15-day submission-and-cure clock
HB 913 / s. 718.112 still supplies the statutory “what.” Rule 61B-22.005 is the Division’s rule on how to carry it out. For threshold-year scoping of “other” items, see FPAT’s 2026 $25,675 threshold checklist. For how funding sits beside GSE warrantability this season, see Fannie Mae Highest Goal & 15%.
Three kinds of SIRS: Full, Update with Site Visit, Financial Update Without Site Visit
Rule 61B-22.005(9) states that a Structural Integrity Reserve Study includes a Full Structural Integrity Reserve Study, an Update with Site Visit, and a Financial Update Without Site Visit. All of them—including updates or amendments—must be completed on current DBPR Form CO 6000-10 (incorporated by reference, effective August 2026; Ref-19575). The rule names the three types, and Form CO 6000-10 has a checkbox for each, but neither defines them. The table below is FPAT’s reading of how they map to the update rules in (9)(b).
| Study type | What it is for | Visual inspection? | Rule cite |
|---|---|---|---|
| Full SIRS | Satisfies the 10-year statutory SIRS cycle; covers all statutory items in s. 718.112(2)(g) | Yes (full study) | (9)(a) |
| Update with Site Visit | Update when inspection is required (incident/disaster; RUL change after repair/replacement; window closed) | Yes | (9)(b)2–4 |
| Financial Update Without Site Visit | Funding amounts / replacement costs only, when the last visual inspection is inside the 36-month window; or a funding-method-only update (special assessment, LOC, loan) under s. 718.112(2)(g)4.c., which needs no new visual inspection regardless of the 36-month window | No | (9)(b)1 |
The 10-year Full SIRS rule
Under Rule 61B-22.005(9)(a), the ten-year statutory SIRS requirement in s. 718.112(2)(g) is satisfied only by completing a Full SIRS that covers all statutory items and requirements in that subsection. Associations subject to the SIRS duty must complete a Full SIRS at least once every ten years. An update—even a thorough one—does not restart that ten-year Full clock by itself.
The 36-month visual-inspection window
Rule 61B-22.005(9)(b)1 allows an association to update the reserve schedule portion of a SIRS without a new visual inspection when:
- 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 the estimated replacement cost of reserve items.
If the last visual inspection is older than 36 months, plan on a site visit with the update.
Funding-method-only updates (special assessment, LOC, loan)
The same subparagraph says an update required under s. 718.112(2)(g)4.c. that solely relates to changes in the association’s funding method—including special assessments, securing a line of credit, or a loan—does not require a new visual inspection. That is the Financial Update Without Site Visit lane when the only change is how you fund, not what the building needs.
For study-type context beside this rule (traditional vs. SIRS scope), see Traditional vs. SIRS Reserve Studies.
When an update is mandatory
Boards ask: “Is our existing SIRS still good enough for the 2027 budget?” Run these checks against Rule 61B-22.005(9)(b).
Decision checklist
Do you need a SIRS update before adopting the 2027 budget?
Cards 1–2 are the rule’s only two mandatory update triggers. Cards 3–6 tell you whether an update you do make needs a site visit; work down them, and the first card that matches sets the study type.
Projected year-end reserve balance for any fiscal year differs from the most recent SIRS projection by an amount equal to or exceeding 50% of the most recent annual cash inflows to reserves.
→ Updated SIRS required — one of the rule’s two mandatory update triggers. Rule 61B-22.005(9)(b)5
Repair, replacement, or maintenance of a SIRS item finished more than 2 years earlier or later than the SIRS schedule.
→ Updated SIRS required — the rule’s other mandatory update trigger. Rule 61B-22.005(9)(b)6
You are updating the SIRS, and since the last visual inspection an incident or disaster may reasonably be expected to affect structural integrity or life-safety systems.
→ If and when you update, the update must include a visual inspection (Update with Site Visit). The incident by itself does not make an update mandatory. Rule 61B-22.005(9)(b)2
You are updating funding amounts or replacement costs, and the last visual inspection is older than 36 months.
→ Update with Site Visit — the 36-month window has closed. Rule 61B-22.005(9)(b)1
The update solely changes the funding method (special assessment, line of credit, or loan) under s. 718.112(2)(g)4.c.
→ Financial Update Without Site Visit — no new visual inspection is required, and the 36-month window does not apply. Rule 61B-22.005(9)(b)1
No incident since the last visual inspection, the last visual inspection is inside the 36-month window, and you are only changing funding amounts or replacement costs.
→ Financial Update Without Site Visit may be available. Rule 61B-22.005(9)(b)1
■ Site visit required ■ Update mandatory ■ No new site visit needed
≥50% reserve-balance variance trigger (labeled example)
Rule 61B-22.005(9)(b)5: an association must obtain an updated SIRS if the projected year-end reserve balance for any fiscal year differs from the projected year-end reserve balance in the most recent SIRS by an amount equal to or exceeding fifty percent of the association’s most recent annual cash inflows to reserves.
Labeled example (illustrative only — not your association’s numbers):
| Line | Example figure | Notes |
|---|---|---|
| Most recent annual cash inflows to reserves | $120,000 | EXAMPLE |
| 50% of those inflows (variance gate) | $60,000 | EXAMPLE |
| Year-end balance projected in most recent SIRS | $450,000 | EXAMPLE |
| Current projected year-end balance (same fiscal year) | $380,000 | EXAMPLE |
| Absolute difference | $70,000 | EXAMPLE |
| Gate result | Update mandatory | $70,000 ≥ $60,000 |
Swap in your actual inflows and both year-end projections. If the difference clears 50% of inflows, the rule says obtain an updated SIRS—do not “hope the budget absorbs it.”
>2-year schedule deviation
Rule 61B-22.005(9)(b)6: an association must obtain an updated SIRS if completion of a repair, replacement, or maintenance of an item included in the SIRS deviates from the schedule in the SIRS by more than two years, either earlier or later than the anticipated date in the most recent SIRS.
Board translation: the roof that finished three years late (or two-plus years early) is not a silent footnote. It is an update trigger.
After a storm or incident affecting structure or life safety
Rule 61B-22.005(9)(b)2: a visual inspection is required when updating a SIRS if, since the last visual inspection, any incident or disaster at the condominium property that may reasonably be expected to affect the structural integrity or life-safety systems of the building has occurred.
That is the hurricane / major incident hook. Do not run a paper-only financial update after a storm that hit the building systems the SIRS covers.
Related RUL rules in (9)(b)3–4: if remaining useful life changes because an item was repaired or replaced, the next SIRS must visually inspect that item; and you may not ripple RUL changes onto other items unless those items are inspected too.
“Completed” means signed, dated, delivered
Rule 61B-22.005(9)(c)1 is blunt: for purposes of this rule, a completed SIRS is the version that has been signed, dated, and delivered to the association by the licensed professional or qualified company that performed the SIRS.
Preliminary drafts or revisions prepared for internal board review do not constitute a completed SIRS. If your packet still says “draft for discussion,” you do not have a completed study under this rule—full stop.
Under (9)(c)2, the association must distribute or otherwise make the completed SIRS available to unit owners, and must file notice with the Division pursuant to s. 718.112(2)(g)11. and 12. Under (9)(c)3, if a completed SIRS is later amended, replaced, or the reserve schedule is modified in a way that materially affects any item’s remaining useful life, replacement cost, or deferred maintenance expense—or that alters the overall reserve funding schedule or a required item’s funding requirements, brings items to or above the statutory reserve threshold, or adds or removes items, the association must again comply with those distribution and notice duties.
Filing: Form CO 6000-10, SIRS Reporting form, Affidavit Form 6000-11
Three paperwork pieces boards should put on one checklist:
Study itself on Form CO 6000-10. Rule 61B-22.005(9) requires all SIRS—including updates and amendments—on the current DBPR Form CO 6000-10, Structural Integrity Reserve Study (SIRS) Form (Ref-19575; effective August 2026). Plain-text form reference for editors: flrules.org/gateway/reference.asp?No=Ref-19575.
Affidavit of Acknowledgement — Form 6000-11. Under (9)(c)2, the association must file notice of completion of the SIRS and Affidavit of Acknowledgement using DBPR Form 6000-11 (Ref-19576; effective August 2026) to the Division through the association’s online account, as required by s. 718.501(3). Plain-text form reference: flrules.org/gateway/reference.asp?No=Ref-19576.
SIRS Reporting form. Rule 61B-22.005(10) requires each association required to complete a SIRS to complete and submit the Structural Integrity Reserve Study (SIRS) Reporting form available on the association’s online account with the Division for each study completed—initial and amended.
Verified day counts: s. 718.112(2)(g)11. and 12. give the association 45 days after receiving the SIRS to distribute it (or a notice that it is available) to owners and to give the Division a statement that it was completed. DBPR’s SIRS reporting page says the SIRS Reporting Form is due within 45 days of the SIRS being completed. The rule sets no separate day count for Form 6000-11; it ties that filing to (g)11. and 12. Use the online account path the statute and rule name: s. 718.501(3) and Rule 61B-22.005(9)(c)2 / (10). DBPR’s SIRS reporting resource (plain text for editors): www2.myfloridalicense.com/condos-timeshares-mobile-homes/condominiums-and-cooperatives-sirs-reporting/.
For the broader Dec. 31, 2026 milestone + SIRS coordination window, see Florida SIRS December 2026 Deadline.
Funding must match the SIRS — nobody may massage the findings
Two companion rules:
- Rule 61B-22.005(3)(b): for a residential condominium required to complete a SIRS, the reserve funding amount for each item or group of items identified in the SIRS must align with the funding amount listed in the most recently completed SIRS as prescribed in this rule.
- Rule 61B-22.005(9)(d): an association is required to implement and fund reserves in accordance with the most recent SIRS, and shall not alter or otherwise manipulate the findings of the SIRS, including the estimated remaining useful life or cost of repair or replacement of reserve items, or any other determinations contained in the SIRS.
Board translation: you may not “smooth” RUL, shave replacement cost, or rewrite determinations so the assessment looks friendlier. If the building reality changed, commission an update under (9)(b)—do not edit the PDF.
Funding-mandate context (not a rehash of this rule): 2026 SIRS Funding Mandate.
Pooled vs. straight-line: what the rule allows without an owner vote
Rule 61B-22.005(3) still recognizes straight-line and pooled formulas for statutory reserves.
Pooled limits (3)(d): the contribution must keep beginning balance plus projected inflows ≥ projected outflows over remaining useful lives; projected inflows may include estimated earnings; the formula shall not include balloon payments or other financing that creates a one-time payment exceeding the standard payment amounts on the reserve schedule; pooled schedules may not defer contributions to reduce current assessments or increase current contributions to offset or reduce future assessments; rates of change may track inflation/deflation but shall not exceed annual CPI-U (or PPI final demand for individual commodities).
Switching methods without an owner vote (3)(e): an association may change between straight-line and pooled accounting without a unit-owner vote if the change does not alter the original authorized purpose, the required level of funding, or the restricted use of reserve funds. Reclassification / redistribution of balances without a vote is allowed only if:
- All transferred funds remain restricted for reserve purposes under ss. 718.112(2)(f) and (g)
- The total reserve balance is not reduced and resulting balances are clearly disclosed in financial reports and the adopted budget
- No reserve funds are applied to a non-reserve purpose
- On conversion from pooled to straight-line, interest earned on the pooled account is allocated among components in proportion to each component’s share of current pooled principal
Owner vote required (3)(e)2 if the method change results in:
- Reduction or elimination of reserve funding for any reserve component
- Use of reserve funds for a purpose not originally approved by the unit owners
- Transfer or reallocation that constitutes a waiver, reduction, or repurposing of reserves under s. 718.112(2)(f)
Nothing in (3)(e) expands or restricts Chapter 718 authority—(3)(e)3. Have counsel draft the motion language.
Non-SIRS condos and multicondos: line-item threshold, AFM multicondo-only (60/30/15)
Non-SIRS residential condominiums (not required to complete a SIRS under s. 718.112(2)(g)):
- Rule 61B-22.005(1)(a): determine whether deferred maintenance expense or replacement cost of an item exceeds the minimum reserve threshold published by the Division for that calendar year; consider each line-item asset separately. (2026 posted threshold context: FPAT $25,675 board checklist.)
- Rule 61B-22.005(3)(a): use a formula that allocates each line-item asset’s (or group of assets’) total estimated cost evenly over its remaining useful life on an annual basis; evaluate costs annually; keep the reserve balance above zero unless properly waived or reduced.
- Rule 61B-22.005(7)(a): may waive or reduce reserves under s. 718.112(2)(f); any vote to waive or reduce components not listed in s. 718.112(2)(g) is not effective for more than one annual budget; majority of total voting interests at a duly noticed meeting. If there is no adopted budget, assessments must include full statutory reserve funding amounts.
Low-rise / height-exemption questions belong on SIRS-Exempt Low-Rise Condo Reserve Study (2026)—not in this rule explainer.
Multicondominium associations — Alternative Funding Method only:
Rule 61B-22.005(8): an AFM can only be used by a multicondominium association. Clock:
| Step | Deadline in the rule | Cite |
|---|---|---|
| Submit proposed AFM to the Division via online account (s. 718.501(3)) | At least 60 days before the meeting at which the annual budget is to be adopted | (8) |
| Division notifies deficiencies in writing | Within 30 days of a complete submission | (8)(b) |
| Association cures deficiencies | 15 days from Division notification | (8)(b) |
| Owner approval | Majority of total voting interests; reflected in official minutes | (8)(d) |
Submission must identify any accountant, CFP, RS/PRA (CAI or APRA), or other person/entity that prepared/reviewed/certified/approved the AFM, plus supporting documentation; if an attorney reviewed it, identify the attorney and provide documentation ((8)(a)). Failure to cure in 15 days renders the submission incomplete—resubmit.
Rule 61B-22.005(7)(c): nothing in the waiver subsection permits waiver or reduction of reserves required under s. 718.112(2)(g).
HOA boards under Chapter 720 are outside this SIRS rule lane; see FPAT’s HOA reserve study services when the question is Ch. 720, not 718.
What’s still coming (development notice 9/17/2026)
The same rule number already has a Notice of Rule Development (31379517), published September 17, 2026 (FAR Vol. 52/181). The flrules history description: clarify language about adjustments to annual reserve funding amount and language about changes between pooled and straight-line reserve accounting. Plain-text URL for editors: www.flrules.org/gateway/View_notice.asp?id=31379517.
Board takeaway: treat this post as current as of October 5, 2026. Before you lock 2027 budget language that quotes pooled/straight-line switch rules or annual funding adjustments, recheck the Rule 61B-22.005 page on flrules.org (gateway/ruleno.asp?id=61B-22.005) for a newer effective text.
Board checklist before the 2027 budget vote
| Checklist item | Done? | Rule / statute hook |
|---|---|---|
| Study on current Form CO 6000-10 (incl. any update/amendment) | ☐ | (9) |
| Signed, dated, delivered completion date on file (not a board draft) | ☐ | (9)(c)1 |
| Owners received / can access the completed SIRS | ☐ | (9)(c)2; s. 718.112(2)(g)11–12 |
| Form 6000-11 Affidavit of Acknowledgement filed via online account | ☐ | (9)(c)2; s. 718.501(3) |
| SIRS Reporting form submitted for this study (initial or amended) | ☐ | (10) |
| Ran the ≥50% year-end balance vs. annual reserve inflows test | ☐ | (9)(b)5 |
| Checked schedule slip >2 years early or late on any SIRS item | ☐ | (9)(b)6 |
| Any storm/incident since last visual inspection affecting structure or life safety? | ☐ | (9)(b)2 |
| Last visual inspection date inside 36 months if attempting financial-only update | ☐ | (9)(b)1 |
| Adopted funding aligns with most recent completed SIRS; no manipulated findings | ☐ | (3)(b); (9)(d) |
| If switching pooled ↔ straight-line: vote path documented under (3)(e) | ☐ | (3)(e) |
| Multicondo AFM path: 60-day submission clock started if applicable | ☐ | (8) |
| Cross-check Dec. 31, 2026 MI+SIRS window and Jan. 4, 2027 Fannie 15% packet | ☐ | See linked FPAT posts |
Quiet operating note from the same rule: combined operating/reserve payments are not treated as commingled if the reserve portion moves to a separate reserve account within 30 calendar days of deposit ((2)). Reserves must be funded at least as often as assessments are due ((6)).
FAQ
What took effect on October 4, 2026 for Florida condo reserves?
Amended Rule 61B-22.005 (Reserves) became effective October 4, 2026. It adds SIRS study-type definitions, Form CO 6000-10 / Form 6000-11 filing duties, mandatory update triggers, a “completed SIRS” definition, anti-manipulation language, pooled/straight-line switch rules, and multicondo-only AFM procedures.
What are the three kinds of SIRS under Rule 61B-22.005?
A Full Structural Integrity Reserve Study, an Update with Site Visit, and a Financial Update Without Site Visit. All must use current Form CO 6000-10. Only a Full SIRS satisfies the ten-year statutory cycle.
When can we update a SIRS without a new visual inspection?
When the SIRS with the most recent visual inspection was completed within the preceding 36 months and the update is limited to funding amounts or estimated replacement costs—or when the update solely changes funding method (special assessment, line of credit, or loan) under s. 718.112(2)(g)4.c. (Rule 61B-22.005(9)(b)1).
When is a SIRS update mandatory under the new rule?
The rule adds two mandatory triggers: the projected year-end reserve balance differs from the SIRS projection by an amount equal to or exceeding 50% of the most recent annual cash inflows to reserves ((9)(b)5), or a SIRS item’s repair, replacement, or maintenance finishes more than two years earlier or later than scheduled ((9)(b)6). The statute separately requires an updated SIRS before adopting any budget whose reserve funding does not align with the most recent SIRS funding plan (s. 718.112(2)(g)4.c.). And any update made after an incident or disaster that may reasonably affect structural integrity or life-safety systems must include a visual inspection ((9)(b)2).
What does “completed SIRS” mean for filing?
The version signed, dated, and delivered to the association by the licensed professional or qualified company. Board drafts do not count. File notice of completion and Affidavit Form 6000-11 through the online account, and submit the SIRS Reporting form for each study ((9)(c), (10)).
Can the board change from pooled to straight-line reserves without an owner vote?
Yes, under Rule 61B-22.005(3)(e), if the change does not alter authorized purpose, required funding level, or restricted use, and the rule’s reclassification conditions are met (funds stay restricted, total not reduced, disclosed, interest allocated pro rata on pooled-to-straight-line conversion). An owner vote is required if the change reduces/eliminates component funding, uses funds for an unapproved purpose, or constitutes a waiver/reduction/repurposing under s. 718.112(2)(f). Counsel should review the motion.
Who can use an Alternative Funding Method, and what is the timeline?
Only a multicondominium association (Rule 61B-22.005(8)). Submit the AFM via the online account at least 60 days before the budget-adoption meeting; the Division has 30 days to flag deficiencies; the association has 15 days to cure; then a majority of total voting interests must approve, with the vote reflected in the minutes.
Expert note
“The statute told boards they need a SIRS. The new rule tells them when the one they have stops being good enough. If your reserve balance drifts far from the study, if a project slips by more than two years, or if a storm hits the building and you update, plan on a site visit — and get the affidavit filed so the Division sees the study you actually adopted.”
— Eric Dixon, RS / PRA, Felten Property Assessment Team (Safety Harbor / Tampa Bay)
Ready for a 24-hour proposal?
If your Florida condo board needs a Form CO 6000-10 SIRS update review, an update-trigger check (≥50% variance, >2-year schedule slip), a post-incident inspection plan, or a board-ready package before the 2027 budget vote, request a 24-hour proposal from FPAT via Florida Reserve Study services or the SIRS service hub.
This post is technical guidance for boards and managers, not legal advice. Confirm filing and vote steps with association counsel.
