Florida Law · Records Transparency · HB 1021 / HB 1203

Florida’s Online Records Portal Rules — What HB 1021 and HB 1203 Mean for Your Board

For Florida condominium associations and Florida homeowners’ associations, the records-transparency framework changed materially in 2024 and is now fully or substantially in effect. The 2026 question for most boards is what the lower thresholds in HB 1021 and HB 1203 pull into the online-records regime — and what the 90-day director-education window requires.

By the CIC-SC Editorial Team Updated May 23, 2026 Reading time: ~11 minutes Audience: Florida Boards, Officers, Managers, Counsel

Educational notice. This information is educational in nature and should not be construed as legal advice. Consult qualified association counsel regarding legal interpretation specific to your jurisdiction.

For Florida condominium associations and Florida homeowners’ associations, the records-transparency framework changed materially in 2024 and is now fully or substantially in effect. Two 2024 statutes — HB 1021 for condominium associations and HB 1203 for HOAs — restructured the way Florida associations are expected to make official records available to members, and the way newly seated directors are expected to complete education on the role.

The two pieces most likely to land on a board’s desk in 2026 are the online records portal requirement and the 90-day director-education requirement. This explainer is a plain-language walk-through of both, with a particular focus on the lower threshold that pulls many more associations into the portal regime than the prior framework did.

This is an educational explainer. It is not legal advice, it is not a compliance determination for any particular association, and the operative statutory text is the controlling document. For application to a specific association, Florida boards consult association counsel.

The Two Statutes in Brief

HB 1021 (2024) — Florida Condominium Associations

The online-records provision of HB 1021 became fully effective for Florida condominium associations on January 1, 2026. As of that effective date, Florida statute generally requires condominium associations meeting the applicable threshold to provide password-protected digital access to specified official records.

The threshold that matters. Under the HB 1021 framework, Florida condominium associations with 25 or more units are within the scope of the online-records provision. That threshold is materially lower than the previous statutory threshold for the equivalent online-records requirement, and it is the headline change in this piece of legislation. A condominium association that previously had no online-records obligation because it sat below the older threshold may now be inside the framework — and many associations in that range have not yet recalibrated their procedures.

HB 1203 (2024) — Florida HOAs

The online-records provision of HB 1203 became effective for Florida homeowners’ associations on January 1, 2025. Under HB 1203, Florida statute generally requires HOAs with 100 or more parcels to post specified official records to a website or mobile application.

HB 1203 also brought a parallel director-education framework into Chapter 720, mirroring the framework already in place for condominium directors under Chapter 718.

The HB 1203 HOA portal requirement has now been operative for more than a calendar year. The HB 1021 condominium portal requirement is the fresher of the two, and it is the one most likely to land on a board’s planning agenda in 2026.

What “Specified Documents” Generally Means

Both frameworks identify categories of official records an association within scope is generally expected to make available. The exact list is statutory and operative across Chapter 718 and Chapter 720, and boards typically confirm the controlling list with association counsel. Categories generally covered include:

Governing documents — declaration, bylaws, rules and regulations as currently in effect;
Meeting notices for board and member meetings;
Board meeting minutes for the period required by statute;
Annual budget and annual financial report;
Contracts and bids for material association expenditures, and contracts in effect with vendors and management;
Insurance information required to be made available;
The Structural Integrity Reserve Study (SIRS) and related reserve documentation, for condominium associations where applicable;
Other categories the applicable statute identifies as official records subject to inspection or posting.

Certain records remain excluded from member inspection regardless of portal status — attorney-client privileged communications, personnel records, certain medical records, statutorily-excluded personal identifiers, and third-party privacy items. The CICSC governance standard GOV-010 lays out the records-request response procedure; the portal framework here sits alongside that procedure rather than replacing it.

The 25-Unit Condominium Threshold — Why This Is the News

The HB 1021 condominium portal provision is the highest-impact piece of the 2026 records-transparency landscape because of how much lower the threshold sits than the previous statutory framework. Florida statute now generally pulls condominium associations of 25 or more units into the portal regime — substantially more associations than were covered under the prior threshold.

In practical terms, that means a meaningful population of mid-size condominium associations across Florida — buildings and condominium communities that previously operated outside the online-records framework — are now within it. Boards in that population are typically working through the same procedural set: confirming with counsel that the association is within scope as a factual matter; identifying the portal solution that will host the required records; migrating the required record categories; validating that access is appropriately limited; and building the operational procedure that keeps the portal current.

The procedural details are statutory determinations. Boards typically confirm with association counsel that any particular portal configuration is consistent with the controlling statute for the association.

The 100-Parcel HOA Threshold — One Year In

For Florida HOAs, the parallel 100-parcel posting framework under HB 1203 has been operative since January 1, 2025. HOA boards within scope have generally already worked through portal selection and migration; the 2026 question for most HOA boards in scope is ongoing currency — keeping the posted records current as the association takes new action. Currency is a different operational discipline than migration, and Florida HOAs at the one-year mark of the HB 1203 framework are typically the ones being tested on it now.

The 90-Day Director-Education Window

HB 1021 and HB 1203 both reinforced and extended the director-education framework already operative under Chapters 718 and 720. Florida statute generally requires that each director, within 90 days of election or appointment, either (a) submit a written certification that the director has read the association’s governing documents and will work to uphold them and faithfully discharge fiduciary duties, or (b) complete an educational curriculum covering the curriculum content the statute generally contemplates.

The framework is operationally simple to track but easy to overlook. Boards typically address it through a board-level tracker — one row per director, with the seating date, the 90-day deadline calculated forward, the education path selected, the program or acknowledgment form on file, and the file location for the certificate. The CICSC governance template fl-director-education-compliance-checklist.md is the board-level tracker pattern; the explainer here is the educational walk-through that goes with it.

The documentation matters because the statute generally treats the certificate of completion or executed acknowledgment as part of the association’s official records. Boards that route every new director through a defined sequence — written notice of the 90-day window at seating, mid-window check-in by the Secretary at day 45, certificate or acknowledgment on file before the deadline closes — generally find that the requirement is easier to satisfy than it appears.

What “Specified Documents” Looks Like in Practice

For boards working through the portal requirement for the first time, the practical operational sequence generally looks like this:

Inventory. Identify every category of record the applicable statute generally requires the association to make available, confirming with counsel which categories apply at the association’s threshold.
Custodian. Designate a single records custodian — typically the Secretary, the manager, or a board officer with a defined role.
Access. Confirm the portal is password-protected and limited to eligible members or unit owners.
Posting cadence. Keep the portal current — meeting notices on issuance, minutes after next-meeting approval, annual budget on adoption, annual financial report when issued.
Audit. Self-verify the portal on a quarterly cadence at minimum.

These are general patterns. The application turns on the controlling statute, the association’s governing documents, and counsel’s review of the specific facts.

What the Portal Is Not

The portal generally satisfies certain inspection obligations for associations within scope, but a written records request still triggers the response framework under Fla. Stat. § 720.303(5) (HOA) or § 718.111(12) (condominium). The two operate in parallel; the portal does not eliminate the records-request response window. CICSC governance standard GOV-010 covers the response procedure in detail.

CICSC is not a Florida state agency, does not issue state-conferred designations, and does not certify any particular educational program as satisfying any particular statutory requirement for any particular association. That determination is made by each association in consultation with its counsel.

When to Consult Counsel

Florida boards typically bring the following questions to association counsel:

Whether the association is within scope of the HB 1021 condominium portal provision or the HB 1203 HOA portal provision as a factual matter at the association’s threshold;
Whether a particular portal configuration is consistent with the controlling statute for the association;
Which records categories the statute generally requires the association to make available, applied to the association’s specific facts;
Whether a particular director-education path (written acknowledgment under the applicable statute, or completion of a specific educational program) is sufficient under the operative text for the association’s directors;
Whether the association’s current records-retention and records-request procedure aligns with the framework around the portal.

The line between general framework and association-specific application is the line where counsel becomes operative. CICSC content is the framework; counsel is the application.

The Credentialing Connection

The CICSC CIC-BOS Foundations credential is structured around the curriculum content typically associated with Florida director-education expectations — board authority, fiduciary duty, meeting procedure, records access, election procedure, enforcement, and financial oversight. Each association determines, in consultation with its counsel, whether any particular educational program is appropriate for its directors under the applicable Florida statute. CICSC issues the CIC-BOS credential as a governance credential; it is not a state-conferred designation, and CICSC does not represent that any particular educational program satisfies any statutory requirement for any particular association or director.

CIC-BOS Foundations is free during the Founders’ Cohort, which closes July 31, 2026. Board members and managers serving Florida associations within scope of the 2024 reform package may wish to enroll inside the window. Enrollment information and the credential framework are available at cic-sc.org.

Companion Resources

Standard: GOV-006 — Florida HOA Governance
Standard: GOV-007 — Florida Condominium Governance
Standard: GOV-010 — Florida Records Request Response Standard
Template: Florida Annual Director-Education Compliance Checklist — fl-director-education-compliance-checklist.md
Template: Records Request Response Template
Article: Florida Records Request Compliance Through the Pecchia Lens — fl-records-request-pecchia-explainer.md
FAQ: Florida HOA Board Member FAQ Library
FAQ: Florida Condominium Board Member FAQ Library
Credential: CIC-BOS Foundations (Founders’ Cohort — free through July 31, 2026)

Tags: HB 1021 · HB 1203 · Florida online records portal · 25-unit condominium threshold · 100-parcel HOA threshold · 90-day director education · § 718.111(12) · § 720.303(5) · SIRS · records transparency

Disclaimer. This article is published by the Common Interest Community Standards Council for educational and informational purposes only. It is not legal advice and does not establish an attorney-client relationship. Statutory references are intended to support informed governance, not to substitute for advice from qualified Florida legal counsel. The application of HB 1021, HB 1203, and the underlying Chapter 718 and Chapter 720 frameworks to a particular association depends on the specific facts and the current state of Florida law. Boards should consult their association’s attorney about scope determinations, portal configuration, records categories, and director-education compliance. CIC-SC, its authors, and its members assume no liability for actions taken in reliance on this content.