Here is some info that may be helpful:
NCAA Bylaws: Signing and Counter Limits
NCAA Bylaws sections concerning FBS signing and counter limits are posted below. Although the basic 25/85 (initial/total) scholarship limits are fairly common knowledge, there are common misconceptions about them too. So, here are
seven important things to understand:
1) Transfers (all types) do count toward annual signee and initial counter limits. There's nothing in the Bylaws stating that transfers are exempt.
15.5.1.10.1 states that
prospective student-athletes and
student-athletes (all-inclusive) do count toward the signing limit.
15.02.3 defines
"counter" as
an individual (all-inclusive) who is on a countable scholarship.
15.02.3.1 defines
“initial counter” as a
counter (all-inclusive) who is receiving an initial countable scholarship.
2) Non-qualifiers who signed an NLI still count against their original signee spot and then count against the corresponding initial counter spot at that school if/when they enroll there after JUCO.
3) Grayshirts (15.5.6.3.2) — Deferred enrollees (after fall term) may count toward signing and initial counter limits for the next academic year.
4) Blueshirts (15.5.6.3.4) — The signings limit (effective for the 2018 cycle) ends the ability for non-recruited (no OV, no off-campus meeting, no NLI; 15.02.8) players to receive fall scholarships (within the 85 limit) and count toward the next year's initial counters limit because they'll count toward the current academic year's signing limit
(post explaining potential blueshirting loophole).
5) Early enrollees (15.5.6.3.5) that are midyear replacements for December or prior academic year graduates may be counted against unused prior cycle signee and initial counter spots. FBS schools may only use the midyear replacement option if they had 85 counters in the fall term.
6) Non-athletic aid (15.5.6.3.7) — A recruited player (OV, off-campus meeting or NLI; 15.02.8) on non-athletic scholarship only counts toward initial and total limits if/when he plays in a game. Exception (15.5.1.2.1) — A recruited player on academic scholarship, after one year with a 3.0/4.0 GPA, may then play and remain a non-counter. Apparently, a non-recruited player on non-athletic aid may play as a non-counter.
7. Voluntary Withdrawal (15.5.6.4.1) — This Bylaws section is at the end of the next post, followed by
two posts explaining how voluntary withdrawal replacement scholarships can be given to new recruits to avoid them counting against annual signing and inital counter limits.
5.02.3 Counter. A “counter”
is an individual who is receiving institutional financial aid that is countable against the aid limitations in a sport.
15.02.3.1 Initial Counter. An “initial counter” is a counter who is receiving countable financial aid in a sport for the first time. (See Bylaw 15.5.6.3 in football for instances in which the institution is permitted to defer the counting of such financial aid until the following academic year.)
15.02.8 Recruited Student-Athlete. For purpose of Bylaw 15, a recruited student-athlete is a student-athlete who, as a prospective student-athlete: (Adopted: 1/15/11 effective 8/1/11)
(a) Was provided an official visit to the institution’s campus;
(b) Had an arranged, in-person, off-campus encounter with a member of the institution’s coaching staff (including any such encounter with the prospective student-athlete’s parents, relatives or legal guardians); or
(c) Was issued a National Letter of Intent or a written offer of athletically related financial aid by the institution for a regular academic term.
15.5.1.10.1 Limitation on Number of National Letter of Intent/Offer of Financial Aid Signings. [FBS] For the football bowl subdivision, there shall be an
annual limit of 25 on the number of
prospective student-athletes who may sign a National Letter of Intent or an institutional offer of financial aid
and student-athletes who may sign a financial aid agreement for the first time. (Revised: 4/26/17 effective 8/1/17 for signings that occur on or after 8/1/17)
15.5.1.10.1.1 Application. [FBS] A prospective student-athlete who signs a National Letter of Intent (NLI) or an institutional offer of financial aid or student-athlete who signs a financial aid agreement that specifies financial aid will be initially provided in the fall term of an academic year shall count toward the annual limit on signings for that academic year. A prospective student-athlete who signs a National Letter of Intent (NLI) or an institutional offer of financial aid or student-athlete who signs a financial aid agreement that specifies financial aid will be initially provided during the second or third term of the academic year may count toward the limit for that academic year or the next academic year. (Revised: 4/26/17 effective 8/1/17 for signings that occur on or after 8/1/17)
15.5.1.10.1.2 Exception—Agreement After One Year. [FBS] A student-athlete who has been in residence at the certifying institution for at least one academic year may sign a financial aid agreement for the first time without counting toward the annual limit on signings. (Adopted: 4/26/17 effective 8/1/17 for signings that occur on or after 8/1/17, Revised: 4/25/18 effective 8/1/18)
15.5.1.10.1.3 Exception—Incapacitating Injury or Illness. [FBS] A prospective student-athlete or student-athlete who, prior to participation in athletically related activities, becomes injured or ill to the point that he or she apparently never again will be able to participate in intercollegiate athletics shall not count toward the institution’s annual limit on signings. (Adopted: 4/26/17 effective 8/1/17 for signings that occur on or after 8/1/17)
15.5.6 Football Limitations.
15.5.6.1 Bowl Subdivision Football. [FBS] There shall be an annual limit of 25 on the number of initial counters (per Bylaw 15.02.3.1) and an annual limit of 85 on the total number of counters (including initial counters) in football at each institution. (Revised: 1/10/91 effective 8/1/92, 12/15/06)
15.5.6.3 Initial Counters—Football (Also see Bylaw 15.02.3.1).
15.5.6.3.1 Recruited Student-Athlete Entering in Fall Term, Aided in First Year. [FBS/FCS] A student-athlete recruited (see Bylaw 15.02.8) by the awarding institution who enters in the fall term and receives institutional financial aid (based in any degree on athletics ability) during the first academic year in residence shall be an initial counter for that year in football. Therefore, such aid shall not be awarded if the institution has reached its limit on the number of initial counters prior to the award of institutional financial aid to the student-athlete.(Revised: 1/15/11 effective 8/1/11)
15.5.6.3.2 Recruited Student-Athlete Entering After Fall Term, Aided in First Year. [FBS/FCS] A student-athlete recruited (per Bylaw 15.02.8) by the awarding institution who enters after the first term of the academic year and immediately receives institutional financial aid (based in any degree on athletics ability) shall be an initial counter for either the current academic year (if the institution’s annual limit has not been reached) or the next academic year. The student-athlete shall be included in the institution’s total counter limit during the academic year in which the aid was first received. (Revised: 1/15/11 effective 8/1/11)
15.5.6.3.3 Recruited Student-Athlete, Aid Received After First Year. [FBS/FCS] A recruited student-athlete (per Bylaw 15.02.8) (including a student-athlete who was not a qualifier) who first receives athletically related financial aid after the student-athlete’s first academic year in residence shall be an initial counter for that academic year in which the aid is first received, if such aid is received during the fall term. However, such a student athlete who first receives athletically related financial aid in the second or third term of an academic year may be considered an initial counter during the academic year in which aid was first received or the next academic year. In either case, the student-athlete shall be included in the institution’s total counter limit during the academic year in which the aid was first received. (Revised: 1/3/06, 1/15/11 effective 8/1/11)
15.5.6.3.4 Nonrecruited Student-Athlete Receiving Institutional Financial Aid. [FBS/FCS] A student-athlete not recruited (per Bylaw 15.02.8) by the institution who receives institutional financial aid (based in any degree on athletics ability) after beginning football practice becomes a counter but need not be counted as an initial counter until the next academic year if the institution has reached its initial limit for the year in question. However, the student-athlete shall be considered in the total counter limit for the academic year in which the aid was first received. (Revised: 1/15/11 effective 8/1/11)
15.5.6.3.5 Midyear Replacement. [FBS/FCS] A counter who graduates at midyear or who graduates during the previous academic year (including summer) may be replaced by an initial counter, who shall be counted against the initial limit either for the year in which the aid is awarded (if the institution’s annual limit has not been reached) or for the following academic year, or by a student-athlete who was an initial counter in a previous academic year and is returning to the institution after time spent on active duty in the armed services or on an official religious mission. In bowl subdivision football, an institution may use the midyear replacement exception only if it previously has provided financial aid during that academic year to the maximum number of overall counters (85 total counters). In championship subdivision football, an institution may use the midyear replacement exception only if it previously has provided financial aid during that academic year that equals the maximum number of overall equivalencies or overall counters. (Revised: 4/20/99 effective 8/1/99, 6/8/99, 4/26/01 effective 8/1/01, 8/2/05, 12/15/06, 1/14/08 effective 8/1/08, 4/2/10, 1/15/11)
15.5.6.4 Exceptions.
15.5.6.4.1 Voluntary Withdrawal. [FBS/FCS] An institution may replace a counter who voluntarily withdraws from the football team by providing the financial aid to another student who already has enrolled in the institution and is a member of the football squad. For this replacement to occur, the counter must withdraw prior to the first day of classes or before the first game of the season, whichever is earlier, and provide the institution with a signed statement releasing the institution from its obligation to provide institutional financial aid and verifying the voluntary nature of the withdrawal. The institution may immediately (beginning with the fall term) award the financial aid to a student-athlete who has been a member of the team for at least one academic year and has not previously received athletically related financial aid. A student-athlete who has not been a member of the team for at least one academic year may not receive the financial aid during the fall term, but may receive it in a following term (e.g., spring semester, winter quarter). (Revised: 4/28/05 effective 8/1/05)