A buyer touring two Old Naples condos last month asked me why one was listed $220,000 below the other when the floor plans, exposures, and finishes were nearly identical. The answer had nothing to do with the units. One building had already completed its Structural Integrity Reserve Study, was fully funding the eight required components, and had a clean insurance renewal in hand. The other had a milestone inspection still open, a reserve line that used to be waived, and a carrier asking questions. That gap is the story of the downtown condo market right now.
The document that sets a downtown condo's ceiling in mid-2026 is no longer the appraisal or the comp sheet. It is the reserve study. Buyers who understand that are the ones getting the sharper deals.
What actually changed on January 1, 2026
Florida's post-Surfside framework rolled out in stages, and 2026 is the year the stages collapsed into a single hard line. As of January 1, 2026, Florida condominium associations are prohibited from waiving or underfunding reserves for the eight SIRS-mandated structural components — the grace period is officially over. For downtown Naples, where most mid-rise buildings sit within three miles of the Gulf and therefore hit the milestone trigger at 25 years rather than 30, the compliance window is not theoretical. Milestone inspections under Section 553.899 are mandatory structural inspections for buildings three or more habitable stories, required at 30 years (or 25 years within three miles of the coast) and every 10 years thereafter.
Two calendars are now running in parallel across Old Naples buildings. The first is the SIRS itself. If your building's milestone inspection is due in 2025 or 2026, you may coordinate the SIRS with that inspection, but no later than December 31, 2026. After the initial SIRS, an updated SIRS is required at least every 10 years. The second is the funding schedule that follows from it. Starting with budgets adopted January 1, 2025 or later, associations cannot waive or reduce reserve funding for SIRS-required components. By 2026, affected associations should be operating on a funding plan consistent with their SIRS.
The eight components a SIRS must cover are not incidental line items. They are the spine of the building:
- Roof
- Load-bearing walls and primary structural systems
- Floor
- Foundation
- Fire protection systems
- Plumbing
- Electrical systems
- Waterproofing and exterior painting, plus windows and exterior doors, plus any other item over $25,000 affecting those systems
That list matters because it is the shape of every future assessment. A building that funds it in full will move dues up slowly and predictably. A building that skipped funding for years will move them up in a single quarter, and it will do so at the moment a buyer is trying to close.
Why the insurance carrier now reads the SIRS before it reads the appraisal
The friction most Old Naples buyers hit in a July closing is not the mortgage, because most of these transactions are cash. It is the binder. Under HB 913, Citizens Property Insurance Corporation is explicitly prohibited from issuing or renewing policies for condominium unit owners or associations unless the association complies with both milestone inspection requirements under Florida Statute 553.899 and SIRS requirements under Florida Statute 718.112(2)(g). If your building has not completed its SIRS or is not funding reserves in accordance with the study, Citizens will not cover you. Private carriers are working from the same playbook. Most now require the SIRS summary page or a DBPR Compliance Affidavit before they will even generate a quote. Underwriters are cross-referencing the DBPR's digital database — where your SIRS data is now publicly accessible — to verify that what your association reports matches what the state has on file.
The database itself is the piece most buyers do not know exists. As of January 1, 2025, the DBPR maintains a searchable public database of associations that have completed their SIRS. Associations not on this list may be flagged for non-compliance. Before writing an offer on a downtown condo, that database is worth a look. It is a five-minute step that can rewrite a negotiating position.
The premium consequences follow. Buildings that come to the underwriter with a completed SIRS, a clean milestone report, and a funded reserve line are often quoted materially less than buildings that arrive with open items, with quoted savings frequently cited in the 10 to 15 percent range for compliant properties. In a downtown building where a unit owner's share of master policy premium already runs into the thousands, that spread compounds into the assessment budget every year.
A Bright Spot for Newer Communities
While Florida's new reserve funding requirements have created significant challenges for many older condominium communities, the outlook is much brighter for newer developments. At Naples Square—including Naples Square I, II, III, and Quattro—all buildings have successfully completed their required Structural Integrity Reserve Studies (SIRS). Because these communities are relatively new, they are also not yet subject to Florida's Milestone Inspection requirements, which generally apply only once buildings reach 25 years of age in coastal areas. For buyers, this provides added peace of mind: the buildings have already met the state's reserve study requirements without the costly deferred maintenance issues that many older communities are now facing. It's one of the many reasons newer luxury communities like Naples Square remain especially attractive in today's market.
What a buyer should actually ask for
Before offer, a serious downtown buyer should ask the listing side for three documents in the same conversation. First, the completed SIRS report, or written evidence that a qualified provider has been engaged and where the association sits in the queue. Wait times for qualified SIRS providers in Florida have been reported at three to six months in some markets. Second, the milestone inspection status and, if a Phase 2 has been triggered, the scope. Required repairs must begin within 365 days after the local enforcement agency receives the Phase 2 report. Third, the 2026 budget with the reserve schedule broken out by SIRS component, plus the meeting minutes for the last two annual meetings.
None of that is unusual to request. All of it is normal association recordkeeping. What is new is that a buyer who asks for it in July is likely to get an answer before season, when the seller still has leverage, rather than in January when three other offers are competing.
Sellers face the mirror-image question. A downtown owner listing a unit this summer benefits materially from getting the building's compliance file assembled before showings begin. Buyers are reading the DBPR database now. The unit that presents a completed SIRS, a filed compliance affidavit, and a funded reserve line is the unit that holds its ask through a longer marketing period.
A short FAQ for downtown Naples owners and buyers
Does this apply to my two-story townhouse or courtyard residence? The milestone and SIRS regime applies to buildings three or more habitable stories. Lower-rise product and single-family homes sit outside it, which is one reason the Old Naples courtyard-and-cottage inventory is behaving differently from the mid-rise condo inventory this year.
My building already voted years ago to waive reserves. What happens now? That waiver has expired as a matter of law. Starting with budgets adopted January 1, 2025 or later, associations cannot waive or reduce reserve funding for SIRS-required components. Boards that still carry underfunded lines are exposed on two fronts, insurance renewal and director fiduciary duty. Florida law provides that officers or directors who willfully and knowingly fail to complete a required SIRS may be deemed to have breached their fiduciary duty.
Can the milestone inspection and the SIRS be done together? Yes, and for many Old Naples buildings that is the sensible path. If both are due by December 31, 2026, Florida law allows them to be completed simultaneously. A milestone inspection within the past 5 years can also replace the visual inspection portion of the SIRS.
Is a special assessment automatic if my building is behind? Not automatic, but common. When a reserve line has been underfunded for years and the SIRS finally quantifies the backlog, the funding gap gets resolved through some combination of higher regular dues, a special assessment, and in some cases a bank loan taken by the association. Reading the SIRS funding plan tells you which lever the board has chosen.
Is this a temporary problem or the new normal? The framework is not going away. Cycles of milestone inspection, SIRS update, and reserve recalibration are now a permanent 10-year rhythm for every three-story-plus condo in the state. The buildings that internalize that rhythm early will be the ones that trade cleanly through the rest of the decade.
If you are weighing a purchase or a sale in Naples Square, Quattro, Eleven Eleven Central, or any of the walkable downtown buildings this summer, the reserve file is worth pulling before the offer, not after. Eileen Komanecky works through these documents building by building. Let's Connect.
