Is Your Building's Reserve Study Compliant? A DMV Comparison
Ask a condo board in DC, a condo board in Bethesda, and a condo board in Arlington whether their reserve study is "legally required," and you'll get three different answers — and all three could be right. The DMV isn't one regulatory region when it comes to reserves. It's three, and the gap between them has been widening.
If your association manages buildings across more than one jurisdiction — or you're a board member who assumes "the law" is the same on either side of the district line — this is worth five minutes.
This article is for general information only and isn't legal advice. Reserve funding decisions have real financial consequences; confirm your association's specific obligations with its attorney or a qualified reserve study professional.
The Short Version
Washington, DCMarylandVirginiaReserve study required?No statutory mandateYes, mandatoryYes, mandatoryUpdate frequencyNot specifiedEvery 5 yearsEvery 5 years, reviewed annuallyMinimum funding level required?NoYes — must reach study's recommended level within 5 fiscal yearsNo fixed target, but funding status must be disclosedGoverning lawDC Code §§ 42-1903.08, 42-1904.04Real Property §§ 11-109.4, 11B-112.3Va. Code §§ 55.1-1965, 55.1-1826
Now the detail behind each column.
Washington, DC: The Lightest Touch in the Region
DC's Condominium Act gives associations the power to budget for reserves and collect assessments to fund them, but it stops there. There's no statutory requirement to conduct a reserve study at all, and no mandated funding formula — reserve planning in DC is a best practice, not a legal obligation.
The one place the law does step in is at the point of sale: a declarant's public offering statement must disclose the amount reserved for repairs and replacement, or state plainly that no amount is reserved. Beyond that initial disclosure, DC boards are largely on their own to decide how seriously to take reserve planning — which means the standard is set entirely by the board, the governing documents, and, in practice, by what a lender expects to see during a resale.
What this means for DC boards: just because the law doesn't require a reserve study doesn't mean skipping one is a good idea. Lenders increasingly ask pointed questions about structural soundness and reserve adequacy before approving financing on a unit, and a building without a current study can find that absence working against residents trying to sell.
Maryland: The Strictest Rules in the Region, and Getting Stricter
Maryland has moved decisively in the opposite direction. Since 2022, condominium and homeowners associations responsible for common-area components with an initial cost of $10,000 or more have been required to complete a professional reserve study at least every five years.
What changed more recently is the bigger deal: 2025 legislation went further than simply requiring a study — it now requires associations to act on it. Boards must adopt a formal reserve funding plan, make actual annual deposits toward it, and reach the study's recommended funding level within five fiscal years of the study. A board can only deviate from that funding requirement with a two-thirds vote documenting genuine financial hardship — a high bar, not a routine opt-out. Boards are also required to give owners a summary of the most recent reserve study alongside the annual proposed budget, so this isn't a document that can sit in a filing cabinet.
What this means for Maryland boards: a study alone no longer satisfies the law. If your last reserve study showed you underfunded, Maryland now expects a documented plan to close that gap on a five-year clock — not an indefinite "we'll get to it."
Virginia: Required Study, Disclosed Funding, No Fixed Target
Virginia sits in the middle. The Virginia Condominium Act requires a reserve study at least every five years, with an annual board review of that study to determine whether adjustments are needed. Unlike Maryland, Virginia doesn't set a mandatory funding percentage or require the association to hit a specific number — but it does require real transparency: the annual budget must disclose the current reserve balance, the planned contribution for the coming year, and how that funding compares to what the study recommends.
Worth noting: Virginia's reserve study requirement applies specifically to condominiums under the Condominium Act. HOAs governed by the separate Property Owners' Association Act are not required to commission a reserve study at all, which creates a meaningful gap depending on how your community is structured.
What this means for Virginia boards: the law gives more room for board discretion than Maryland's does, but that discretion comes with a disclosure obligation — a board that underfunds reserves has to say so, in writing, in the budget every owner receives. That's a much more public conversation than simply falling behind quietly.
Why the Comparison Matters Right Now
Reserve requirements across the country have been tightening since the 2021 Surfside condominium collapse in Florida made underfunded reserves and deferred structural maintenance a national conversation. Maryland's 2025 changes are part of that broader trend, and it would be reasonable to expect DC and Virginia to face similar pressure over time, even without a specific bill currently pending in either jurisdiction.
For a board managing a single building, this might be background noise. For a portfolio manager or a board that's part of a larger association network spanning the DMV, it's an active compliance risk — the same reserve policy that satisfies Virginia's disclosure requirement may not come close to satisfying Maryland's mandated funding plan.
What a Board Should Do Regardless of Jurisdiction
A few steps apply no matter which side of the line your building sits on:
Know which law actually governs your building. Confirm whether you fall under a condominium act or a separate HOA/POA act — as Virginia shows, that distinction can change your obligations entirely.
Don't let a study go stale. Even in DC, where it's not required, a current reserve study protects resale values and gives the board a credible answer when residents ask hard questions about future assessments.
Treat the study as a planning tool, not paperwork. Maryland has made this a legal requirement; Virginia requires disclosure of the gap either way. A study that isn't driving the actual budget isn't doing its job.
Revisit this at least annually. These laws are moving. What was compliant in 2023 may not be compliant now, particularly for Maryland associations still catching up to the 2025 funding plan requirement.
Where Urbaniqa Fits In
Because we serve buildings across DC, Maryland, and Northern Virginia, our on-site teams and management partners are already working inside three different regulatory environments — which means we're paying attention to exactly this kind of shift as it happens, not discovering it at renewal time. If your board isn't sure which reserve rules actually apply to your building, or you manage a portfolio spanning more than one jurisdiction, that's a conversation worth having before your next budget cycle, not after.
Urbaniqa Property Solutions 1250 Connecticut Avenue NW, Suite 700, Washington, DC 20036 contact@urbaniqasolutions.com · www.urbaniqasolutions.com
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