Here’s a breakdown of how the changes affect small associations’ reserve study requirements:
1. Exemption Thresholds for Small Communities Have Changed
A small plat or miscellaneous community that meets these new, expanded thresholds is exempt from the full WUCIOA, which includes the reserve study requirement (RCW 64.90.545).
Impact: This change actually increases the number of small associations that can qualify for the exemption from a full WUCIOA compliance, including the reserve study requirement.
2. Reserve Study Requirement
WUCIOA Reserve Study Requirement: WUCIOA generally requires associations to conduct a reserve study and update it annually (with a visual site inspection update every three years). This requirement was already retroactively applicable to all communities to some degree, or was part of the older HOA Act.
The 2026 “Phase-in” (SB 5129): The core WUCIOA provisions that become mandatory for all common interest communities on January 1, 2026, primarily relate to:
Meetings (open meetings, 15-minute owner comment period).
Accepting payment of assessments.
Electric vehicle charging stations and heat pumps.
Board powers during an emergency.
The reserve study requirement itself (RCW 64.90.545) is not one of the provisions accelerated to January 1, 2026, for all communities. The full adoption of WUCIOA for all older communities, which would eliminate all other old-law exemptions, is scheduled for January 1, 2028 (via SB 5796).
Summary of Impact for Small Associations
The primary impact of the 2026 changes (SB 5129) on a small association’s reserve study is the expanded exemption criteria.
If your small association (specifically a plat or miscellaneous community) now falls within the 50 units / and less than $1,000 annual assessment threshold, you are likely exempt from the full WUCIOA and its reserve study requirements. If you exceed either one then your association is not exempt
If you do not meet this new, expanded exemption threshold, the WUCIOA reserve study requirements would still apply based on previous WUCIOA retroactivity provisions and the community’s governing law (Old Act, Condo Act, or HOA Act).
Pacific Crest Reserves is a not a legal firm. Community association law can be complex. You should consult with an attorney specializing in Washington Common Interest Community law to determine the exact compliance requirements for your specific association.
