The statute is a two part test
A trust accounting must be a reasonably understandable report from the date of the last accounting or, if none, from the date on which the trustee became accountable, that adequately discloses the information required in subsection (2).
Section 736.08135(1), Florida Statutes.
Both halves have to be satisfied. A document can contain every number the statute asks for and still fail the first half if no ordinary person could follow it. The Fourth District put the point in a single sentence in November 2025.
Chapter 736 does not permit a trust accounting to be an instrument of obfuscation. ‘A trust accounting must be a reasonably understandable report from the date of the last accounting or, if none, from the date on which the trustee became accountable, that adequately discloses the information required in subsection (2).’ § 736.08135(1), Fla. Stat. (2022).
Revah v. Revah, No. 4D2024-1992 (Fla. 4th DCA Nov. 12, 2025) (slip op. at 8).
The checklist
Subsection (2) is the part worth reading with your own accounting in front of you.
The accounting must show all cash and property transactions and all significant transactions affecting administration during the accounting period, including compensation paid to the trustee and the trustee’s agents. Gains and losses realized during the accounting period and all receipts and disbursements must be shown.
Section 736.08135(2)(b), Florida Statutes.
Read that clause about compensation again. What the trustee paid themselves, and what they paid their agents, has to appear. It is not an optional line item and it is not something a beneficiary has to go looking for.
To the extent feasible, the accounting must identify and value trust assets on hand at the close of the accounting period. For each asset or class of assets reasonably capable of valuation, the accounting shall contain two values, the asset acquisition value or carrying value and the estimated current value. The accounting must identify each known noncontingent liability with an estimated current amount of the liability if known.
Section 736.08135(2)(c), Florida Statutes.
Two values per asset, not one. An accounting listing only current values does not comply, because the pair is what shows whether the asset gained or lost under this trustee’s management.
The remaining paragraphs are quieter and still useful. Paragraph (d) requires significant transactions that do not change the amount the trustee is accountable for, such as name changes in holdings, adjustments to carrying value, a change of custodial institution, and stock splits. Paragraph (e) requires the allocation between income and principal to be shown wherever it affects a beneficiary’s interest, which is the provision that matters most in a second marriage trust. And paragraph (f) requires a final accounting to include a plan of distribution for anything still undistributed.
What is not an accounting
This is where the statute earns its keep, because the common complaint is not that no paper arrived. It is that a great deal of paper arrived and none of it answered anything.
Viewed in the light most favorable to Suzanne, the record shows that Cecile failed to serve any statutorily compliant accountings as required by Chapter 736. The only documents Cecile produced were (1) a 2022 ‘document dump’ of third-party financial records and (2) unsworn ledgers filed on October 5, 2023, which was over a year after litigation commenced. These documents lack the essential elements of a statutory accounting under section 736.08135, as they are not ‘reasonably understandable’ reports and do not include the information required by section 736.08135(2). In addition to not being organized in a report format, the documents were not provided annually as required.
Revah v. Revah, No. 4D2024-1992 (Fla. 4th DCA Nov. 12, 2025) (slip op. at 9 to 10).
Four separate failures sit in one paragraph, namely not a report, missing the subsection (2) elements, not organized as a report, and not annual. Any one of them is enough.
The trial court improperly relied on the unsworn, post-litigation ledgers as satisfying Cecile’s statutory duty. Mere bank statements or transaction logs do not constitute a statutory accounting. The absence of sufficient annual accountings for over a decade establishes a per se breach of trust under section 736.1001(1), Florida Statutes.
Revah v. Revah, No. 4D2024-1992 (Fla. 4th DCA Nov. 12, 2025) (slip op. at 10).
Who has to prove what
Beneficiaries routinely assume they must demonstrate that the accounting they received was deficient. That is backwards.
The trial court erred in granting summary judgment on Suzanne’s accounting claim because Cecile failed to meet her burden of establishing that she had served statutorily compliant accountings. Suzanne made a prima facie case that Cecile was a trustee, and that Suzanne did not receive accountings. At that point, the ultimate burden of proof rested with Cecile to account for the property held by her in trust consistent with Chapter 736.
Under Florida law, the burden is on fiduciaries to adequately account for their use of a beneficiary’s funds.
Revah v. Revah, No. 4D2024-1992 (Fla. 4th DCA Nov. 12, 2025) (slip op. at 9).
Two facts make the prima facie case. This person is the trustee, and I did not get accountings. Everything after that is the trustee’s problem.
How far back, and the amendment nobody has applied
Subsection (4) sets the reach of the form and content rules, and it now has two triggers rather than one. They govern accountings for periods beginning on or after January 1, 2003, and, following a 2018 amendment, all trust accountings rendered on or after July 1, 2018. The second trigger does not depend on what period the accounting covers, only on when it was produced. No reported Florida decision has yet applied it.
A caution for anyone checking our citation against an older case. In Corya v. Sanders the Fourth District cited this effective date rule as subsection (3), which is where it lived in 2015. Chapter 2018-35 inserted a new subsection (3), the family trust company election, and pushed the effective date provision down to (4). The court was right when it wrote it. If you follow that citation into today’s statute you will land on the family trust company rule and conclude somebody made a mistake.
How far back a trustee must actually reach is a live question rather than a settled one, and it is genuinely unresolved. Corya held that statutory laches capped a look back accounting at four years. The Legislature then amended section 736.1008 in 2018 and provided, in section 8 of the same act, that the change was remedial and applied retroactively. In Revah the Fourth District did not decide the point but directed that on remand the beneficiary be given leave to argue whether the Legislature abrogated Corya by that amendment. No appellate court has yet answered it. Our page on section 736.1008 covers the limitations machinery in detail.