Transfers (all types) do count toward annual signee and initial counter limits. There's nothing in the Bylaws stating that transfers are exempt. Per section
13.9.2.3, both
prospective student-athletes and
student-athletes (all-inclusive) do count toward the signee limits.
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.
NCAA Bylaws: (PDF - free download)
13.9.2.3 Limitation on the 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)
13.9.2.3.1 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)
15.02.3 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.)