Washington's Reserve Study Law Changed in 2026: What Every Board Must Do Before 2028

Short version: Since January 1, 2026, the reserve study section of the Washington Uniform Common Interest Ownership Act — RCW 64.90.545 — applies to every common interest community in Washington, including condominiums and HOAs formed before July 1, 2018 that used to follow the older Condominium Act (RCW 64.34) or Homeowners' Associations Act (RCW 64.38). On January 1, 2028, those older acts are repealed and WUCIOA (RCW 64.90) becomes the single statute for all associations. If your community's last full reserve study is more than three years old, you are already behind.
What changed, and when
Washington has been moving all community associations onto one statute for several years. Two bills finished the job:
- ESSB 5796 (2024) — often called "WUCIOA for All" — set January 1, 2028 as the date the Condominium Act (RCW 64.34), the Homeowners' Associations Act (RCW 64.38) and the older Horizontal Property Regimes Act (RCW 64.32) are repealed and every association is governed by WUCIOA.
- ESSB 5129 (2025) pulled a group of WUCIOA provisions forward to January 1, 2026 for communities formed before July 1, 2018. The reserve study requirement, RCW 64.90.545, is on that list, alongside rules on meetings, budgets, records and financial disclosures.
Before 2026, an older community only followed WUCIOA's reserve provisions if it opted in. That is no longer the case.
What RCW 64.90.545 requires
- A reserve study prepared by a reserve study professional, based on a visual site inspection.
- An update every year, and a full study with a new visual site inspection at least every three years. Under the old acts, three years was the recommended cadence; under WUCIOA it is the floor.
- A component inventory of the major common elements with a predictable useful life — roofing, siding and building envelope, decks and walkways, paving, elevators, mechanical and plumbing systems — with an estimated remaining life and replacement cost for each.
- A recommended annual funding plan, including the contribution needed to keep the reserve account on track and the current percent funded.
- Disclosure: the study's key figures flow into the annual budget summary owners receive before the budget meeting, and reserve information appears in resale certificates. WUCIOA also requires reserve funds to be kept separate from operating funds and limits how reserve funds may be invested.
Exemptions are narrow — essentially nonresidential communities, communities with nominal reserve costs, and cases where the study itself would cost more than a set share of the annual budget. The small-association exemptions many boards relied on under RCW 64.38 disappear with that act on January 1, 2028. Before relying on an exemption, confirm it with association counsel.
Why this matters more than the penalty
The statutory penalty for ignoring the requirement is modest. The real exposure is elsewhere:
- Lending. Fannie Mae and Freddie Mac project reviews, and most lenders' condo questionnaires, ask for a current reserve study and percent-funded figure. A missing or stale study can make units hard to finance and hard to sell.
- Resale disclosure. Buyers and their attorneys read the resale certificate. An association that cannot produce a compliant study is a red flag.
- Special assessments. Communities without a funding plan are the ones that end up levying five- and six-figure assessments when a roof or siding fails.
- Board liability. A current, professional reserve study is the clearest evidence that directors are meeting their fiduciary duty on capital planning.
What your board should do now
- Find the date of your last full study with a site inspection. If it is more than three years old, or you have never had one, order a full (Level I) study now.
- If your full study is current, get the annual update done before the 2027 budget is drafted, so the contribution rate in the budget matches the study.
- Put the cadence on the calendar: annual updates, full study with inspection every third year.
- Use the 2027 budget cycle to close the gap. If the study shows you are underfunded, phase contribution increases in now rather than facing a special assessment after the 2028 transition.
- Confirm the reserve account is segregated from operating funds and that any investment of reserve funds follows the statute.
Plan your next reserve study
Bach Associates has prepared reserve studies for Washington associations since 1999, with Reserve Specialist (RS) credentials on staff. If your community needs a compliant study or an annual update, request a proposal — we respond within 24 hours.
This article summarizes Washington statutes for general information and is not legal advice. Consult your association's attorney about how the law applies to your community.