Rule 61B-19.004: A New Framework for HOA Board Education

Effective September 7, 2026, Rule 61B-19.004, Florida Administrative Code, establishes the procedures used to administer Florida’s education requirements for homeowners’ association directors.

Section 720.3033, Florida Statutes, created the underlying certification and continuing education obligations; the new rule defines important terms, establishes a uniform education year, regulates course and provider approval, identifies how directors document compliance, and assigns specific compliance responsibilities to the association.

The following discussion focuses on the actions and procedures established by the new rule rather than repeating the broader statutory requirements.

Defines the Types of Education

The rule defines two distinct forms of HOA director education:

• Board Member Certification, or BMC: A Division-approved course satisfying the initial education requirement. The course includes financial literacy and transparency, recordkeeping, levying fines, and notice and meeting requirements.

• Continuing Education, or CE: Ongoing Division-approved education used to satisfy the annual education requirements under section 720.3033.

A course must be approved for the specific purpose for which the director intends to use it. An informative association seminar does not automatically qualify as either BMC or CE.

Establishes a Uniform “Education Year”

The rule defines an education year as the period beginning July 1 and ending June 30 of the following calendar year.

This definition gives all HOA directors a common period for measuring annual continuing education. CE must be completed and the certificate submitted on or before June 30, the end of the applicable education year.

The education year does not replace the initialelected or appointed director must still complete and submit the BMC certificate within 90 days after election or appointment.

Measures BMC Validity by Education Years

A BMC certificate is valid for four education years, provided the director serves without interruption. The director must submit the new certificate within 90 days after the beginning of the applicable education year.

This is an important clarification. The rule measures validity by education years rather than simply counting four years from the certificate’s calendar completion date. Because a partial education year may be involved, directors and associations should not assume that every certificate expires exactly 48 months after completion.

The association should record:

• The certificate-completion date;
• The education year in which it was completed;
• The director’s continuity of service; and
• The education year in which renewal will be required.

The Division has not published an official example explaining whether every possible completion date receives the same amount of usable time. Therefore, associations should avoid extending a certificate beyond the four education years permitted by the rule.

Allows Multiple Courses to Satisfy Annual CE

The rule permits a director to combine multiple approved courses to reach the required annual CE total. A director is not required to obtain all required hours through one program.

For example, a director requiring four annual hours could potentially satisfy the requirement through four approved one-hour courses or another combination totaling at least four approved hours.

Prohibits Repeating the Same Course for Additional Credit

A director may not take the same course more than once during the same education year and count it repeatedly toward the minimum CE requirement.

The restriction applies within the education year. Replaying or retaking the same program does not generate additional qualifying hours for that July 1–June 30 period.

Defines How a Director Demonstrates Complianc

A director satisfies the applicable BMC or CE requirement by submitting a valid certificate of completion to the association secretary or equivalent officer within the required timeframe.

The operative document is the certificate of completion. Registration confirmations, payment receipts, attendance emails, course materials, or a director’s verbal statement do not replace it.

Assigns Responsibility to the Association Secretary

The rule expressly makes the association secretary, or equivalent officer, responsible for:

• Ensuring board-member compliance with the education requirements; and
• Maintaining the association’s education records.

This is more than a passive filing responsibility. The association should maintain a tracking system showing each director’s election or appointment date, initial BMC deadline, certificate-validity period, annual CE hours, and applicable June 30 deadline.

Although management may assist with tracking and recordkeeping, the rule assigns the formal responsibility to the secretary or equivalent officer.

Directs the Board to Suspend a Noncompliant Director

If a director fails to meet an education requirement by the applicable deadline, the rule directs the board to suspend that director until the director becomes compliant.

During the suspension:

• The director should not participate as a serving board member;
• The board may temporarily fill the vacancy; and
• The suspension continues until the applicable educational requirement is satisfied.

The rule therefore turns education tracking into an active governance obligation. The board must respond to an expired compliance deadline; it should not simply note the deficiency and allow the director to continue serving.

Authorizes Multiple Delivery Methods

Division-created or Division-approved BMC and CE courses may be offered 

through:

• Asynchronous instruction: Self-paced modules, prerecorded presentations, written materials, or electronic media;
• Synchronous instruction: Live instruction delivered by or in the presence of an instructor; or
• Hybrid instruction: A combination of live and self-paced education.

The method of delivery may vary, but the instructor must still take reasonable steps to confirm that the director satisfactorily completed the entire course.

Requires Verification of Complete Participation

An instructor must verify that a participant satisfactorily completed the approved course in its entirety before issuing a certificate.

This means merely registering, signing in, or attending only part of a program is insufficient. Providers must have a procedure for verifying completion, particularly for virtual and self-paced programs.

Creates a Path for CAM Courses to Qualify as HOA CE

A course already approved as Community Association Manager continuing education does not automatically qualfy as HOA board-member CE. However, the rule creates a separate application process through which a provider may seek approval of an existing CAM CE course for HOA directors.

The provider must identify the CAM course and explain how it relates to homeowners’ association governance. This creates the possibility that on program may qualify for both audiences, but separate HOA approval is still required.

Board members should therefore confirm that a CAM course has also received approval as HOA director continuing education before relying on it.

For Education Providers:

1. Establishes Approval Standards for Providers and Instructors
2. Requires Provider Recordkeeping
3. Allows DBPR to Withdraw Course Approval
   

Conclusion

Rule 61B-19.004 converts the HOA director-education requirements into a more structured compliance system. It establishes a uniform July 1–June 30 education  year, measures BMC validity by four education years and uninterrupted service, permits directors to combine approved CE courses, prevents duplicate credit for repeating the same course, and places responsibility on the association secretary to track compliance and maintain the records.

The practical lesson for every HOA board is clear: verify the course approval, obtain and submit the certificate, track deadlines by education year, and act promptly .when a director becomes noncompliant.