Florida HOA Debit Card Ban: The Card Policy Treasurers Need

Florida law bans the HOA debit card and the condo association debit card. No association, officer, director, employee or agent may use one to pay any association expense.

Credit cards are a different story. The statutes do not mention them, so a board that uses one should have its own written rules for who holds it and what it pays for.

The rule is not new. It has applied to condominiums since July 1, 2017, and to homeowners associations since July 1, 2024. It came back into the news on October 4, 2026. That day, attorney Joseph E. Adams of Becker answered a reader's question about association cards in his News-Press column.

This article reports what the two statutes say and who they apply to. It then lays out a card policy a treasurer can bring to the next board meeting. The policy steps are good practice, not legal requirements, except where we quote a statute. Confirm with association counsel before your board adopts one.

What the HOA debit card and condo debit card rules say

The condominium rule is section 718.111(15), Florida Statutes. The homeowners association rule is section 720.303(13). Both are titled "Debit cards," and their first paragraphs match almost word for word.

Paragraph (a) of the condominium version covers "an association and its officers, directors, employees, and agents." They "may not use a debit card issued in the name of the association, or billed directly to the association, for the payment of any association expense."

The HOA version says the same thing, ending with "association expenses" in the plural.

Three parts of that text decide who and what it covers:

Who. The association itself, plus its officers, directors, employees and agents. If a management company pays bills for you, ask counsel how this reaches it.
Which cards. A debit card "issued in the name of the association, or billed directly to the association." Paying association bills from a director's personal card raises its own problems, covered below.
Which payments. "Any association expense." The text sets no dollar floor and no exception for small purchases.

Both statutes then define a phrase that matters for the penalty: "lawful obligation of the association." It "means an obligation that has been properly preapproved by the board and is reflected in the meeting minutes or the written budget."

The penalty: theft, and removal from the condo board

Paragraph (b) of each statute covers a person who uses an association debit card "for any expense that is not a lawful obligation of the association."

For condominiums, section 718.111(15)(b) says that person "commits theft under s. 812.014 and must be removed from office and a vacancy declared."

For homeowners associations, section 720.303(13)(b) says that person "commits theft as provided under s. 812.014." The HOA text does not include the removal language.

Section 812.014 is Florida's theft statute. How serious a charge would be depends on that statute and the facts, which is a question for a lawyer, not a board.

The condominium penalty wording changed in 2024. The 2017 text said misuse "may be prosecuted as credit card fraud pursuant to s. 817.61." The theft and removal wording replaced it through Chapter 2024-244, Laws of Florida, effective July 1, 2024.

Condominium owners also have a state office to call. Section 718.501(1)(a)1. lets the Division of Florida Condominiums, Timeshares, and Mobile Homes investigate complaints after turnover. The list includes "use of debit cards for unintended purposes under s. 718.111(15)."

When the association debit card ban took effect

The dates come from the session laws that added each piece, as published in the Laws of Florida.

Condominiums, the ban itself: July 1, 2017. Chapter 2017-188 (CS/CS/HB 1237) created section 718.111(15), approved by the Governor June 26, 2017.
Condominiums, theft and removal: July 1, 2024. Chapter 2024-244 (CS/CS/CS/HB 1021) rewrote paragraph (b) and added the "lawful obligation" definition.
Homeowners associations: July 1, 2024. Chapter 2024-221 (CS/CS/HB 1203) created section 720.303(13), approved by the Governor May 31, 2024.

So an HOA board that opened its accounts before mid-2024 may still have a debit card it never thought about. That card has been off limits for association expenses for more than two years.

What about a condo association credit card?

Neither statute mentions credit cards. In his October 4 column, Adams of Becker wrote that "there is no prohibition on the use of credit cards by the association." The board, he added, "should have appropriate controls in place regarding who may use any credit card issued to the association and how it may be used."

That is the gap a written policy fills. A credit card in the association's name is legal to hold, but the law sets no limit, no receipt rule and no review step for it. The board has to write those itself.

The statutes do offer a useful test to borrow. Their definition of a "lawful obligation" is an expense "properly preapproved by the board" and "reflected in the meeting minutes or the written budget." That definition applies to the debit card rule, not to credit cards. Still, it is a clean standard for any card charge: if the budget or the minutes do not cover it, the card should not pay for it.

The fiduciary duty applies either way. Condominium officers and directors "have a fiduciary relationship to the unit owners," under section 718.111(1)(a). HOA officers and directors "have a fiduciary relationship to the members," under section 720.303(1).

A written HOA credit card policy a treasurer can adopt this month

What follows is a model outline, not statutory language. Each item is a common internal control for association money. Adjust it to your governing documents and size, and have counsel review the final text.

Retire every association debit card. Ask the bank to list every card tied to the operating and reserve accounts. Cancel any debit card in the association's name or billed to it. Keep the bank's written confirmation.
Name the cardholders by board vote. Decide who may hold a credit card, by title and by name, and record the vote in the minutes. Fewer cards are easier to watch.
Set the limits. Ask the bank for a low credit limit on the account. Set a limit per purchase and per month in the policy. Anything above the limit needs a board vote or the treasurer's written approval first.
Say what the card can pay for. Budgeted items and expenses the board has already approved in the minutes. Borrow the statute's "lawful obligation" test and write it into the policy.
Say what the card never pays for. Personal purchases, cash advances, gift cards, and splitting one purchase into several to stay under a limit.
Require a receipt for every charge. The cardholder turns in an itemized receipt within a set number of days. It notes the budget line, the vendor and the purpose. No receipt means the cardholder explains it in writing.
Reconcile every month. Someone other than the cardholder matches the statement to the receipts and the budget. Unmatched charges go on a short exception list.
Use two people for every review. The cardholder never approves their own statement. The treasurer and a second director, or the treasurer and the manager, sign off each month.
Report to the board. The monthly financial report shows card spending by budget line, plus the exception list.
Close cards when people leave. Cancel or reissue a card the day a cardholder leaves the board or the job. Report lost cards at once.
Review the policy every year. Revisit the limits and cardholders when the board sets the new budget.

One more point belongs in the policy: reimbursements. When a director pays an association bill from a personal card, the association repays them. Require the same receipt and approval steps before any reimbursement goes out. Personal cards should be the exception, not the routine.

The receipts Florida law already requires

Most of these steps are good practice. The receipts are also a records issue, because both statutes make financial records part of the official records.

For condominiums, section 718.111(12)(a)11. requires "accurate, itemized, and detailed records of all receipts and expenditures, including all bank statements and ledgers." It also requires "all invoices, transaction receipts, or deposit slips that substantiate any receipt or expenditure of funds by the association." These records must be kept for at least 7 years under section 718.111(12)(b).

For homeowners associations, section 720.303(4)(a)10. requires financial and accounting records "kept according to good accounting practices." They must include "accurate, itemized, and detailed records of all receipts and expenditures." The records list in section 720.303(4)(a) must be kept for at least 7 years.

Both statutes also let owners inspect the official records. A card charge with no receipt is hard to explain to an owner who asks. Monthly reconciliation finds those gaps while they are still easy to fix.

A checklist for your next board meeting

Ask the bank for a list of every card on every association account, and the type of each.
Cancel any association debit card, and file the bank's confirmation.
Put the card policy on the agenda of a properly noticed board meeting.
Vote on the policy and the named cardholders, and record both in the minutes.
Set the bank's credit limit to match the policy.
Pick the second reviewer for the monthly statement.
Schedule the first monthly reconciliation and the first report to the board.

When to confirm with association counsel

Call counsel before acting when:

Your governing documents say anything about cards, check signers or spending authority.
A management company or employee pays association bills on a card.
You find a past debit card charge that was not approved in the budget or the minutes.
An owner or director raises a concern about card spending.
You are a cooperative. We did not find a matching debit card subsection in section 719.104, the co-op counterpart, in the 2026 text.

How Royale helps treasurers with card controls

Royale's in-house association accounting team prepares monthly financial statements and bank reconciliations and handles invoice processing for the condominiums and homeowners associations we manage. Self-managed boards can keep running their community and hand us the books through our accounting-only service. For more on controls, see our article on theft, fraud and embezzlement. Our free guide, "How to Read Your HOA's Monthly Financial Report," is in the Board Library. If you want a second look at your card policy or your monthly reports, ask us.

Frequently asked questions

Can a Florida HOA use a debit card?

No, not for association expenses. Section 720.303(13)(a) bars an HOA and its officers, directors, employees and agents from using one for association expenses. That covers any debit card issued in the association's name or billed to it. The rule took effect July 1, 2024.

Can a condo association have a credit card?

The statutes do not prohibit one. Section 718.111(15) names only debit cards. Becker attorney Joseph E. Adams wrote on October 4, 2026 that boards should have controls on who may use an association credit card and how.

What happens if a board member misuses an association debit card?

Using one for an expense that is not a lawful obligation of the association is theft under section 812.014, under both statutes. For condominiums, section 718.111(15)(b) adds that the person "must be removed from office and a vacancy declared."

What is a "lawful obligation of the association"?

Both statutes define it as "an obligation that has been properly preapproved by the board and is reflected in the meeting minutes or the written budget." The definition applies to the debit card rule.

Does the debit card ban apply to our management company?

The ban covers the association's "officers, directors, employees, and agents." Whether a particular management company acts as the association's agent for a payment depends on its contract. Ask association counsel.

Sources

Florida Statutes, Section 718.111 (2026), including (1)(a), (12)(a)11., (12)(b) and (15), flsenate.gov.
Florida Statutes, Section 720.303 (2026), including (1), (4)(a), (5)(a) and (13), flsenate.gov.
Florida Statutes, Section 718.501 (2026), Division jurisdiction after turnover in (1)(a)1., flsenate.gov.
Florida Statutes, Section 719.104 (2026), cooperatives, flsenate.gov.
Florida Statutes, Section 718.111 (2017), the original debit card subsection, flsenate.gov.
Laws of Florida, Chapter 2017-188 (CS/CS/HB 1237), effective July 1, 2017, laws.flrules.org.
Laws of Florida, Chapter 2024-221 (CS/CS/HB 1203), effective July 1, 2024, laws.flrules.org.
Laws of Florida, Chapter 2024-244 (CS/CS/CS/HB 1021), effective July 1, 2024, laws.flrules.org.
Joseph E. Adams, "Understanding Electronic Voting and Association Credit Card Rules," News-Press column, October 4, 2026, Becker.