[IMAGE PLACEHOLDER] Hero background — Florida condo building exterior, coastal or stucco
Guide · Florida Condo Compliance
Florida SIRS and Your Painting Reserves: What Condo Boards Need to Know
Exterior painting is one of the eight components Florida’s structural integrity reserve study must cover — and since January 2026, funding it is mandatory. What that means for scoping, budgeting and timing a repaint.
General information for Florida condo boards, current as of August 2026 — not legal or engineering advice.
The answer
Does Florida’s SIRS cover exterior painting?
Yes. Florida Statute § 718.112(2)(g) requires a structural integrity reserve study to cover eight components, and “waterproofing and exterior painting” is one of them. Condominium and cooperative associations with buildings of three or more habitable stories must complete a SIRS every ten years, and since 1 January 2026 reserve funding for those components is mandatory — it can no longer be waived or reduced by owner vote.
For most boards this is a shift in how the conversation goes. Exterior painting used to be the line item that got deferred when the budget was tight. It’s now a component with a statutory funding obligation and an assessed useful life behind it.
The eight components
What a SIRS has to cover
A SIRS must assess eight categories, assign each a remaining useful life and replacement cost, and produce a funding plan.
| # | Component |
|---|---|
| 1 | Roof |
| 2 | Load-bearing structure |
| 3 | Fireproofing and fire protection systems |
| 4 | Plumbing |
| 5 | Electrical systems |
| 6 | Waterproofing and exterior painting |
| 7 | Windows and exterior doors |
| 8 | Any other item above the annual threshold affecting those systems |
On the eighth: the catch-all threshold was raised from $10,000 to $25,000 by HB 913, with annual inflation adjustment. DBPR set the 2026 figure at $25,675. It applies only where the item’s failure would affect one of the seven named categories — it doesn’t remove or modify those seven.
Why it’s included
Why exterior painting sits alongside the roof and the structure
Because on a Florida building, the coating system is part of the waterproofing envelope — not decoration. Paint and sealant are what keep water out of the wall assembly, and water in the assembly is what damages the structure the rest of the statute is concerned with.
[IMAGE PLACEHOLDER] Photo — failed exterior coating and sealant at a stucco control joint
The statute pairs them deliberately: waterproofing and exterior painting. On a stucco or masonry building in this climate, the exterior coating is a functional layer. When it fails — chalking, cracking, loss of adhesion — the wall stops shedding water. Combined with failed sealant at joints and penetrations, moisture reaches the substrate.
From there it’s a structural conversation rather than a cosmetic one: corroding embedded steel, spalling concrete, damaged sheathing.
That’s the logic behind including it. The Surfside collapse exposed how long deferred envelope maintenance can run before it becomes visible, and the reforms treat the envelope as structural because functionally it is.
Repainting over failed sealant doesn’t protect the building. It traps water inside the assembly and hides the evidence.
What’s already assumed
Your reserve study contains a painting assumption you should know about
Your SIRS assigns your exterior coating system a remaining useful life and a replacement cost. Both numbers rest on assumptions about scope, surface preparation and product quality — and painting to a lower specification than the study assumed quietly shortens the cycle and underfunds the next one.
When a reserve professional assessed your coating system, they estimated how long it should last and what replacing it should cost. That estimate assumes a certain standard of work — appropriate prep, appropriate product, sealant addressed as part of the job.
If the association then accepts a bid that skips pressure washing, coats over failed sealant, or uses a lower-grade product to hit a number, the actual service life comes in shorter than the reserve model. The funding plan is now wrong, and nobody finds out for several years.
Three questions worth asking your reserve professional:
- What service life did you assign the coating system, and what does that assume about product and prep?
- Does the replacement cost include sealant and substrate repair, or coating only?
- Were different elevations assessed separately? South and west elevations weather faster than north and east — a single blended figure can be optimistic.
And one worth asking any bidding contractor:
“What service life do you expect from this specification, and what does it assume about prep and sealant?”
If a contractor can’t answer that, they’re bidding a price rather than a system.
SIRS vs. milestone
How the two requirements differ
A SIRS is a financial document — what components you have, how long they’ll last, and what you must fund. A milestone inspection is a structural assessment — whether the building is sound today and what physical work it needs. They’re separate obligations on separate schedules.
| SIRS | Milestone inspection | |
|---|---|---|
| Statute | § 718.112(2)(g) | § 553.899 |
| Question it answers | What must we fund? | Is the building sound? |
| Applies to | Condo/co-op, 3+ habitable stories | Condo/co-op, 3+ habitable stories |
| Trigger | Regardless of building age | 30 years after CO — 25 within 3 miles of coast |
| Frequency | Every 10 years | Every 10 years after the first |
| Performed by | Architect, engineer, RS or PRA | Licensed architect or engineer |
| Output | Funding plan | Condition assessment and repair scope |
How they interact: a milestone inspection frequently identifies coating failure, sealant deterioration and water intrusion at the envelope. Those findings become scoped repair work — and painting and waterproofing are usually part of the remedy. HB 913 also permits a board that has completed a milestone inspection identifying necessary repairs to pause reserve contributions for up to two consecutive budget years to redirect funds toward those repairs, subject to an owner vote.
The coastal rule
Buildings within three miles of the coast hit milestone five years earlier
The milestone inspection trigger is 30 years after certificate of occupancy — but 25 years for buildings within three miles of the coastline. In Northeast Florida that captures Jacksonville Beach, Neptune Beach, Atlantic Beach, Ponte Vedra and the Amelia Island buildings.
Why the distinction exists: salt-laden air accelerates corrosion of embedded steel and coating breakdown. A coastal building of the same age is functionally older in envelope terms than an inland one.
What it means practically for coating budgets: a coastal building’s coating system doesn’t just need earlier inspection — it genuinely runs a shorter cycle. Failure starts at metal and joints: window frames, railings, fasteners, door hardware. Corrosion begins there and works outward beneath the coating, which is why a coastal building can look sound from the parking lot and be failing at every window return.
If your reserve study applied a generic service life to a coastal building, that’s worth a conversation.
Common mistakes
Five things that cost associations money
Treating painting as cosmetic
It’s the most common framing error and it drives everything else — deferral, low-bid selection, coating-only scope. On a Florida building the envelope coating is functional.
Accepting a bid that excludes sealant
Sealant and coating fail on different schedules but they protect together. A repaint that leaves failed sealant in place traps water rather than excluding it — and hides it for several years.
Comparing bids on price without comparing specification
Two bids for “exterior repaint” can describe genuinely different work: different prep, different product, different service life. Comparing the numbers without comparing the scope is comparing nothing.
Assuming one study covers every building
The statute requires a SIRS for each qualifying building. Multi-building associations can’t rely on a single study where buildings differ in age, structure or condition.
Deferring past the funding requirement
Since 1 January 2026, reserve funding for SIRS components can’t be waived or reduced by owner vote. Deferral is no longer a budget lever in the way it was.
Scoping the work
How to scope a repaint that matches what you’re funding
Ask bidders to specify surface preparation method, product and system, sealant scope, substrate repair allowance, and expected service life. Then compare those against what your reserve study assumed. A bid that can’t be compared to your funding model isn’t usable, whatever the number says.
What a comparable proposal should state:
| Element | Why it matters |
|---|---|
| Surface prep method | Pressure washing, sanding, chalk removal. The biggest single driver of service life. |
| Primer and coating system | Product line and number of coats, not “premium paint.” |
| Sealant scope | Which joints, full replacement or spot, what product. |
| Substrate repair allowance | Stucco cracks, spalling, wood rot — and what happens if more is found. |
| Elevation treatment | Whether south and west get the same system as north and east. |
| Expected service life | The number that should be compared against your reserve model. |
| Warranty | Term, and what it actually covers. |
| Phasing | If funding is staged, how the work splits across budget years. |
The lowest bid and the longest service life are rarely the same proposal. Your reserve study is funding a service life — not a paint job.
Important
A note on legal and engineering advice
This guide is general information, not legal or engineering advice. Florida Statutes § 718.112(2)(g) and § 553.899 have been amended several times since 2022, and requirements vary by building, age, height and location. Confirm your association’s specific obligations with your association attorney, licensed community association manager, and reserve professional.
Paintcoats does not perform structural integrity reserve studies or milestone inspections. Those must be carried out by a licensed architect, licensed engineer, or credentialed reserve specialist. We perform the painting, coating and waterproofing work a reserve study budgets for.
Last reviewed: August 2026. We review this page as Florida condominium law changes.
Questions
Common questions
Does a SIRS cover exterior painting?
Yes. “Waterproofing and exterior painting” is one of the eight components Fla. Stat. § 718.112(2)(g) requires a SIRS to cover.
Which buildings need a SIRS?
Condominium and cooperative buildings of three or more habitable stories, regardless of age. Buildings under three habitable stories are generally exempt, as are most single-family HOAs and townhome communities.
How often is a SIRS required?
Every ten years, for each qualifying building.
Can we still waive reserves?
Not for SIRS components. Since 1 January 2026, funding for those components can’t be waived or reduced by owner vote. HB 913 does permit loans, lines of credit and special assessments as funding sources.
Who can perform a SIRS?
A licensed architect, a licensed engineer, a CAI-credentialed reserve specialist (RS), or an APRA professional reserve analyst (PRA).
When is our milestone inspection due?
Thirty years after certificate of occupancy, or twenty-five if the building is within three miles of the coastline, then every ten years.
What’s the difference between a SIRS and a milestone inspection?
A SIRS is a funding document — what you have, how long it lasts, what you must reserve. A milestone inspection is a structural assessment of current condition. Separate obligations, separate schedules.
We have several buildings. Does one study cover all of them?
Not if they differ in age, structure or condition. The requirement applies per building.
Our reserves are underfunded. What are the options?
That’s a conversation for your attorney and reserve professional. HB 913 permits loans, lines of credit and special assessments, and a limited pause on reserve contributions following a milestone inspection that identifies repairs. Phasing painting work to match available funding is usually possible.
Does painting to a higher specification actually extend the cycle?
Prep and product both materially affect service life, and that service life is what your reserve model funds. Ask any bidder what service life their specification assumes — a proposal that can’t answer is a price rather than a system.
Scoping a repaint against your reserve study?
We paint condominium and HOA communities across Northeast Florida, and we write proposals boards can compare — prep method, coating system, sealant scope, substrate allowance and expected service life, itemized. We also handle common-area and portfolio painting beyond a single repaint (see Multifamily Painting), and if your buildings need a verified color standard across phased work, our Paint Matching & Color Standardization guide covers that.
Serving Duval, Clay, St. Johns and Nassau counties.