HOA & Compliance10 min readApril 10, 2025

    HOA Elevator Requirements Under Florida's SIRS Law (SB 4-D)

    Florida's Surfside-era legislation fundamentally changed how condo associations must handle elevator capital planning. HOA boards that haven't acted yet may be running out of time — and personal liability is now on the table.

    By Jonathan Colpani — Certified General Contractor CGC1540788 + Elevator Certificate of Competency CC6467Certified General Contractor CGC1540788 · Registered Elevator Co. #1106 · Elevator Certificate of Competency CC6467

    The 2021 Champlain Towers South collapse in Surfside, Florida triggered one of the most significant changes to Florida condominium law in the state's history. Senate Bill 4-D, signed into law in May 2022, established mandatory Structural Integrity Reserve Studies (SIRS) and fully funded reserve requirements for qualifying condo buildings. For the thousands of South Florida condo associations operating aging elevator systems, this law has direct and immediate implications.

    What Is a Structural Integrity Reserve Study (SIRS)?

    A SIRS is a comprehensive engineering assessment of a condominium building's structural and life-safety systems, including an analysis of repair/replacement costs and a recommended reserve funding schedule. Unlike traditional reserve studies, which were advisory, a SIRS must be performed by a licensed engineer or architect and must address specific components mandated by Florida Statute 718.112(2)(g).

    Are Elevators Covered Under SIRS?

    Yes — with an important distinction. Florida Statute 718.112(2)(g) specifically lists the following as required SIRS components:

    • Roof
    • Load-bearing walls or other primary structural members
    • Floor
    • Foundation
    • Fireproofing and fire protection systems
    • Plumbing
    • Electrical systems
    • Waterproofing and exterior painting
    • Windows
    • Any other item that has a deferred maintenance expense or replacement cost that exceeds $10,000 and the failure to replace or maintain such item negatively affects one or more items listed above

    Elevators typically fall under two categories: (1) they may be included as an electrical system component, and (2) they virtually always qualify under the "any other item" provision, as elevator replacement costs routinely exceed $10,000 and failed elevators directly affect the building's life-safety systems.

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    If your building's SIRS does not address the elevator system, your study may be incomplete. Work with your engineer and licensed elevator contractor to ensure elevator capital needs are properly scoped and costed.

    Key Compliance Deadlines

    Florida law established rolling deadlines for SIRS compliance:

    Building AgeSIRS Required ByReserve Waiver Prohibition
    30+ years, 3+ stories, within 3 miles of coastDecember 31, 2024January 1, 2025
    30+ years, 3+ stories, inlandDecember 31, 2025January 1, 2026
    25–29 years, 3+ storiesAt next reserve study cycleUpon SIRS completion
    Under 25 yearsNot yet requiredN/A

    Confirm the current reserve-funding requirements for your association with a qualified professional.

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    As of January 1, 2025, associations subject to SIRS requirements can no longer waive fully funded reserves. This is a fundamental change — previously, unit owners could vote to waive or reduce reserve funding. That option no longer exists for covered buildings.

    What This Means for Elevator Capital Planning

    For the hundreds of South Florida condo buildings with aging elevator systems, SIRS compliance has several practical implications:

    • Reserve line items: Elevator modernization or replacement must appear as a funded line item in the reserve study, with an accurate current cost estimate and remaining useful life assessment.
    • Licensed contractor input: Engineers preparing SIRS typically request a written cost estimate from a licensed elevator contractor for each elevator system in the building. This estimate forms the basis of the reserve funding calculation.
    • Deferred maintenance risk: Buildings that have deferred elevator maintenance may face higher reserve funding requirements because the estimated remaining useful life is shorter than a well-maintained system.
    • Board liability: Under SB 4-D, HOA board members can face personal liability for failing to maintain required reserves. This is a significant shift from prior law.

    How to Get Your Elevator SIRS Documentation

    If your building is conducting a SIRS and needs elevator system documentation, a licensed elevator contractor can provide:

    • Current condition assessment of the elevator system(s)
    • Estimated remaining useful life
    • Modernization cost estimate (partial and full)
    • Replacement cost estimate
    • Recommended timeline for capital action

    This documentation plugs directly into your engineer's reserve study and ensures your SIRS is accurate and defensible. We provide this documentation to condo associations and their engineers regularly — it's a standard part of our service offering for South Florida's HOA market.

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    Request a written elevator condition assessment before your SIRS is finalized. An inaccurate remaining useful life estimate — even one that's optimistic by 5 years — can significantly underfund your reserve and create compliance problems down the road.

    Frequently Asked Questions

    Need an Elevator Assessment for Your SIRS or Reserve Study?

    We provide written elevator condition assessments and cost documentation for South Florida condo associations and their engineers. Certified General Contractor CGC1540788 + Elevator Certificate of Competency CC6467.