For about thirty years, the way a lot of Florida condominium associations handled the roof was simple: put a reserve line in the budget, then vote every year to fund it at zero. Keep the maintenance fee flat. Let the next board deal with it. When the roof finally failed, pass a special assessment and hope the owners could absorb it.
That playbook is now closed — at least for the roof, and at least for most condominium buildings.
The rewrite of Florida’s condo safety and reserve laws that started after Surfside has settled into its current form, and the practical result for a board is this: the roof is a named, mandatory reserve item, and for most condominium buildings the membership no longer has the power to vote it down.
We work with association boards and property managers across Volusia County, and the same questions keep coming up in the parking lot after the budget meeting. Here are the answers, with the statute cites so you can hand this to your manager or your attorney and have a real conversation.
One caveat up front: this is general information from a roofing contractor, not legal advice. Your declaration and your association counsel control. Where this article gives you a deadline, verify it against your own building’s certificate of occupancy date and your own city’s building department.
First: Are You Actually a Condominium? Because HOAs Are Not Covered
This is the single most confused point in Florida community association law, and getting it wrong in either direction costs money.
“Condominium” is a form of ownership, not a building type. You cannot tell by looking at the property. A three-story building of stacked flats might be an HOA. A row of two-story townhomes might be a condominium. The recorded declaration decides it, not the architecture.
Why it matters:
| Requirement | Condominium (Ch. 718) | Cooperative (Ch. 719) | HOA (Ch. 720) |
|---|---|---|---|
| Milestone inspection (§553.899) | Yes — 3+ habitable stories | Yes | No |
| Structural integrity reserve study (SIRS) | Yes — 3+ habitable stories | Yes | No — no Chapter 720 equivalent exists |
| Roof reserve mandatory? | Yes, regardless of cost | Yes | Only if the members voted to establish reserves |
| Can members waive or underfund it? | No, for SIRS items | No | Yes — still allowed, one budget year at a time |
Section 553.899 applies only to a building “subject, in whole or in part, to the condominium or cooperative form of ownership.” Chapter 720 appears nowhere in it. And §718.112(2)(g) expressly excludes any portion of a building that has not been submitted to the condominium form of ownership.
If you serve on an HOA board and someone has told you that you owe a reserve study every three years, or that your multi-story buildings need a SIRS: that is not in the statute. It circulates widely online and it is wrong. HOA reserves are governed by §720.303(6), they exist only if the membership voted to create them or the governing documents require them, and the membership can still vote to waive or reduce them — for one budget year at a time.
None of which means an HOA board should ignore the roof. It means the discipline has to come from the board rather than from Tallahassee.
What the Structural Integrity Reserve Study Actually Requires
A structural integrity reserve study (everyone says “SIRS”) is required under §718.112(2)(g) for a residential condominium association, at least every 10 years, for each building on the property that is three habitable stories or higher as determined by the Florida Building Code.
The word habitable is doing real work there. It was added in 2025. A three-story building whose ground floor is non-habitable parking with two living floors above it is now outside the requirement — a meaningful change for a lot of beachside buildings in Volusia County.
The statute lists exactly eight components the study must cover. Here it is, in order:
- Roof
- Structure, including load-bearing walls and other primary structural members
- Fireproofing and fire protection systems
- Plumbing
- Electrical systems
- Waterproofing and exterior painting
- Windows and exterior doors
- Any other item with a deferred maintenance or replacement cost above the statutory threshold, where failing to maintain it would negatively affect items 1 through 7
The roof is item (a). First on the list.
Two details boards get wrong here. First, that dollar threshold — $25,675 for 2026, inflation-adjusted annually by the Division and posted each February — applies only to the catch-all item 8. It does not gate the roof. The roof goes in the study no matter what it costs. Second, the general reserve requirement in §718.112(2)(f) separately names roof replacement as a mandatory reserve line for every condominium association “regardless of the amount” — including the two-story buildings that never trigger a SIRS at all.
So the roof is locked in twice, by two different subsections, on two different tracks.
The Study Has to Put a Number on Your Roof
At minimum, the SIRS must identify each inspected component and state its estimated remaining useful life and its estimated replacement cost, then produce a funding schedule that gets you to that replacement cost by the end of that useful life.
That is where a roofing contractor becomes genuinely useful to a board rather than just a vendor. The engineer, architect or credentialed reserve specialist performing the study needs two numbers for the roof: how many years are left, and what replacement will actually cost. The first is a professional judgment call about your specific roof. The second is a construction number — and a study built on a stale square-foot figure from three years ago will underfund the reserve by a wide margin.
There is one carve-out worth knowing. For components with an estimated remaining useful life greater than 25 years, or where useful life is not readily ascertainable, the association is not required to reserve the replacement cost — only any recommended deferred maintenance expense. In practice an asphalt shingle roof essentially never clears that bar. A newer tile roof sometimes will. Which puts a lot of weight on one professional’s estimate of remaining useful life, and is a good reason for a board to make sure that estimate is grounded in an actual look at the roof.
Where the SIRS Falls Short on Roofs — and What Boards Should Do About It
The statute says the SIRS is based on a visual inspection of the condominium property. That is the standard. It does not require destructive testing, core cuts, infrared moisture surveys, or lifting tile.
For a shingle roof that is usually adequate. Granule loss, cupping, seal failure, soft decking underfoot, rusted or undersized flashing — a competent visual inspection catches all of it.
For a tile roof, it can be badly misleading, and Volusia County has plenty of tile. The tile itself may outlast the building. The component that actually determines when the roof gets replaced is the underlayment beneath it — the layer doing the waterproofing. It is not visible without lifting tile. A reserve study that looks at a tile roof and sees intact tile can put a long remaining useful life on a roof that is, in practical terms, a season or two from leaking into units.
Nothing in the statute stops a board from commissioning a more thorough roof condition assessment to inform the study. We would argue that for any tile roof past about fifteen years, a board should. The cost of pulling and resetting some tile in a few representative areas is trivial against the cost of getting the reserve number wrong by a decade.
A Milestone Inspection Is Not a Roof Inspection
Boards conflate these constantly. They are separate requirements with separate triggers.
Under §553.899, a building three habitable stories or more that is under condominium or cooperative ownership must have a milestone inspection by December 31 of the year it turns 30 years old, based on the certificate of occupancy date, and every 10 years after that. Phase 1 is a visual examination by a licensed architect or engineer. If no substantial structural deterioration is found, that is the end of it. Phase 2 is required only if Phase 1 finds substantial structural deterioration, and it may involve destructive or nondestructive testing.
Two things a board needs to hear clearly:
1. The 30-year trigger is the statewide default, but your city can require 25. The old automatic rule for buildings within three miles of the coastline was repealed in 2023 — you will still find it recited on websites and even on some government fee schedules, and it is out of date. What replaced it is narrower: the local enforcement agency (your city or county building department) may determine that local circumstances, including proximity to salt water, require inspection at 25 years instead.
In Volusia County that is not academic. Ormond Beach adopted a 25-year trigger by ordinance in 2024, with civil penalties that accrue daily for non-compliance. Other Volusia municipalities we checked have no published 25-year determination — but a determination does not require an ordinance, and there is no statewide list. Call your building department and confirm your building’s trigger age in writing. That is the only answer that cannot be wrong.
2. The milestone inspection largely does not cover your roof covering. Its scope is load-bearing elements and primary structural members. Roof framing, trusses and deck are structural. Shingles, tile and membrane generally are not. A clean Phase 1 report tells you the building is standing. It does not tell you the roof is watertight, and a board that treats it as a roof clearance is going to be surprised.
The roof lives in the SIRS. The structure lives in the milestone inspection.
The Waiver Is Gone — and the “Special Assess Later” Plan Got Much Harder
Here is the core change. A unit-owner-controlled association can still vote by majority to provide no reserves or reduced reserves generally. But for a budget adopted on or after December 31, 2024, an association that must obtain a SIRS may not vote to provide no reserves or less reserves for the items in paragraph (g).
The roof is paragraph (g), item (a). So for a three-habitable-story condominium building, the annual vote to zero out the roof reserve is no longer available.
A few related mechanics that matter at budget time:
- “Fully funded” is the wrong standard. The statutory floor is a baseline funding plan — funding sufficient to keep the reserve cash balance above zero each budget year. The study may recommend other schedules. But you are not obligated to hit 100% of the theoretical accrued balance, and any consultant telling a board otherwise is overselling.
- The roof reserve cannot be diluted. Reserve funding for paragraph (g) components may only be pooled with other paragraph (g) components. And using reserve funds for anything other than their authorized purpose requires approval by a majority of all voting interests, not just those at the meeting.
- You have more funding tools than assessments. Reserves for these items may be funded by regular assessments, special assessments, lines of credit, or loans — each of the latter three requiring a majority vote of the total voting interests. For a board staring at a five-year runway and a twenty-year-old roof, a reserve loan is now an express statutory option.
- The 2025 pause is a narrow bridge, not an exit. For budgets adopted on or before December 31, 2028, an association that completed a milestone inspection within the previous two calendar years may, with approval of a majority of total voting interests, temporarily pause or reduce reserve contributions for no more than two consecutive annual budgets, and only to fund repairs the milestone inspection recommended. An association that uses it must have a SIRS performed before contributions resume. It is real relief for a building facing an unexpected structural repair bill. It is not a way to defer the roof.
Why Deferring Is More Expensive Than It Used to Be
Even setting the statute aside, the economics moved:
- Buyers find out now. For contracts entered after December 31, 2024, a condominium resale contract must include the buyer’s acknowledgment of receipt of the milestone inspection summary and the association’s most recent structural integrity reserve study — or the buyer gets a cancellation window. A deferred roof and a thin reserve are now disclosed at the closing table, to every buyer, in writing.
- Lenders find out too. Significant deferred maintenance or missing reserves can push a condominium project out of conventional financing eligibility, which shrinks the buyer pool for every owner in the building.
- Directors have personal exposure on the study itself. Under §718.112(2)(g), if officers or directors willfully and knowingly fail to complete a SIRS, that failure is a breach of their fiduciary duty to the unit owners. Note the precise scope: the statute attaches that to failing to complete the study.
- Building officials have teeth. A local enforcement agency may prescribe timelines and penalties, and where an owner fails to show that Phase 2 repairs are scheduled or commenced, the agency must determine whether the building is unsafe for human occupancy. Statewide in 2024 and 2025, 54 buildings were determined unsafe or uninhabitable.
What a Volusia County Board Should Do This Quarter
Concretely, in order:
- Confirm your form of ownership. Pull the recorded declaration. Condominium, cooperative or HOA. Everything downstream depends on it.
- Count habitable stories per building. Not stories — habitable stories, per the Florida Building Code. Do it building by building; a multi-building property can have some in scope and some out.
- Find your certificate of occupancy date and calculate your milestone year. Then call your city or county building department and confirm in writing whether they apply the 25-year trigger. In Volusia County, Ormond Beach does.
- Check whether your SIRS is done. For unit-owner-controlled associations that existed on or before July 1, 2022, the deadline was December 31, 2025. If yours has not been completed, you are behind — talk to counsel about how to catch up rather than about whether you have to.
- Read the roof line in your SIRS critically. What remaining useful life did it assign? What replacement cost? When was that cost figure priced? If it says your tile roof has 30 years left based on a look from the ground, get a second opinion before you build a decade of budgets on it.
- Get a current, line-item replacement cost. Reserve studies are only as good as their construction numbers, and material and labor pricing has not been stable.
- Bid it properly when the time comes. Contracts above 5% of your total annual budget including reserves are subject to competitive bidding under §718.3026. Architects and engineers are exempt from that requirement. Contractors are not.
Where a Roofing Contractor Fits Into This
Not as the person who performs your SIRS — that has to be done or verified by an engineer licensed under Chapter 471, an architect licensed under Chapter 481, or someone credentialed as a reserve specialist or professional reserve analyst by CAI or APRA.
What a contractor should give a board is the ground truth the study depends on:
- An honest condition assessment of the actual roof, including what is under tile
- A defensible remaining-useful-life opinion the reserve professional can work from
- A current, line-item replacement cost — broken out by building, so the reserve schedule can be too
- Phasing options, because a five-building property rarely needs all five roofs in the same budget year
- A bid package a board can put side by side with two others and actually compare
One more thing worth knowing: Florida added a conflict-of-interest disclosure requirement in 2025. An architect or engineer who bids to perform a milestone inspection must disclose in writing an intent to bid on the repair work that inspection may recommend. If the firm telling you what you need is also the firm that wants to sell it to you, that has to be on the table.
Frequently Asked Questions
Does our HOA need a structural integrity reserve study?
No. The SIRS requirement in §718.112(2)(g) applies to residential condominium associations, and §719.106 applies the equivalent to cooperatives. There is no Chapter 720 equivalent for homeowners’ associations, regardless of how many stories the buildings have. HOA reserves are governed by §720.303(6) and remain waivable by member vote, one budget year at a time.
Can our owners still vote to skip funding the roof reserve?
If your association is required to obtain a SIRS, no. For budgets adopted on or after December 31, 2024, members may not vote to provide no reserves or less reserves for the components listed in paragraph (g), and the roof is the first item on that list. A condominium association whose buildings are all under three habitable stories is not subject to the SIRS requirement — but roof replacement is still a mandatory reserve line under §718.112(2)(f), and waiving it is a decision the board should make with eyes open.
Is our building on a 25-year or a 30-year milestone inspection clock?
Thirty years from the certificate of occupancy date is the statewide default. The old automatic 25-year rule for buildings within three miles of the coastline was repealed in 2023. Your local building department may still determine that local conditions, including proximity to salt water, require 25 years — Ormond Beach adopted that by ordinance in 2024. There is no statewide list of which jurisdictions have done so, so confirm directly with the building department that issues your permits.
Will the milestone inspection tell us whether we need a new roof?
Not reliably. Its scope is load-bearing elements and primary structural members. Roof framing and decking fall inside that; the roof covering generally does not. A clean Phase 1 report is not a statement that your shingles, tile or membrane have life left. That determination belongs in the reserve study and in a roof-specific inspection.
Our tile roof looks fine from the ground. Why would we reserve for it?
Because on a tile roof, the tile is not the part that fails first. The underlayment beneath it does the waterproofing, and it is not visible without lifting tile. It is entirely normal in Florida to have sound-looking tile over underlayment at the end of its service life. If your reserve study assigned a long remaining useful life to a tile roof on the strength of a visual inspection alone, that is worth a second look.
How much of a roof replacement do we have to reserve if the roof has 30 years of life left?
For components with an estimated remaining useful life greater than 25 years, or where useful life is not readily ascertainable, the association is not required to reserve replacement costs — but it must reserve any deferred maintenance expense the study recommends. In practice this rarely applies to asphalt shingles and sometimes applies to newer tile. It turns entirely on the remaining-useful-life figure in the study, which is exactly why that figure deserves scrutiny.
Can we take out a loan instead of a special assessment?
Yes. Reserves for paragraph (g) items may be funded by regular assessments, special assessments, lines of credit, or loans. A special assessment, line of credit, or loan requires approval by a majority of the total voting interests. Talk to your association counsel and your lender about structure before you take it to the membership.
Talk to a Roofing Contractor Who Works With Boards
Affordable Roofing & Construction has served Volusia County for more than 20 years. We work with condominium associations, HOAs, property managers and commercial building owners as well as single-family homeowners. We hold both a roofing license and a general contractor license (CCC 1327602 and CGC 1509441), we are CertainTeed ShingleMaster credentialed with dual Master Craftsman certifications, and every roof we install includes a wind mitigation inspection and a 5-year labor warranty.
We serve Daytona Beach, Port Orange, New Smyrna Beach, Ormond Beach, DeLand, Deltona, Edgewater, South Daytona, Holly Hill, Orange City and the surrounding Central Florida area.
Board members and property managers: if you need a roof condition assessment, a remaining-useful-life opinion for your reserve study, or a line-item replacement cost you can budget against, we provide all three at no charge. Call 386-392-8952 or request a free estimate online.
Related reading: who pays for the roof on a Florida condo or townhome, how to compare roofing estimates line by line, and TPO vs. EPDM flat roofing for commercial and low-slope buildings.
This article is general information from a licensed roofing contractor, not legal or accounting advice. Florida’s condominium statutes have been amended repeatedly since 2022 and continue to change. Your declaration, your building’s certificate of occupancy date and your local building department’s determinations control. Consult your association attorney and your reserve professional before making budget decisions.
Affordable Roofing & Construction — Licensed & Insured | CCC 1327602 | CGC 1509441 | Serving Volusia County for over 20 years