Here are the NCAA Bylaws sections petaining to FBS signee and counter limits. This is worth bookmarking or copying and saving somewhere for future reference.
Bylaw 13.9.2.3 states that both prospective student-athletes and student-athletes (e.g., transfers) count against the 25 signees limit. Bylaw 15.02.3 defines the term "counter" as an individual on scholarship.
There is nothing in the Bylaws stating that transfers don't count toward the annual 25 signees and 25 initial counters limits.
NCAA Bylaws
13.9.2.3 Limitation on Number of National Letter of Intent/Offer of Financial Aid Signings Bowl Subdivision Football. [FBS] In bowl subdivision football, 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. [D] (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 or an institutional offer of financial aid or a 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 or an institutional offer of financial aid or a 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 limit for 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.)
15.02.8 Recruited Student-Athlete. For purposes 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 institutions campus;
(b) Had an arranged, in-person, off-campus encounter with a member of the institutions coaching staff (including a coachs arranged, in-person, off-campus encounter with the prospective student-athlete or the prospective student-athletes 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.
15.5.6 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 CountersFootball (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 institutions annual limit has not been reached) or the next academic year. The student-athlete shall be included in the institutions 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-athletes 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 institutions 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 institutions 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)
15.5.6.3.6 Aid First Awarded After Second Year. [FBS/FCS] A student-athlete who has been in residence at the certifying institution for at least two academic years may receive athletically related financial aid for the first time without such aid counting as an initial award, provided the aid falls within the overall grant limitation. (Adopted: 1/11/89, Revised: 1/10/90 effective 8/1/90)
15.5.6.3.7 Recruited Student-Athlete, Varsity Competition. [FBS/FCS] In accordance with Bylaw 15.5.1.2, a recruited student-athlete (per Bylaw 15.02.8) receiving institutional financial aid certified as having been granted without regard in any degree to athletics ability becomes an initial counter in the first academic year in which the student-athlete competes on the varsity level. (See Bylaw 15.5.1.2.1.) (Revised: 10/27/05 effective 8/1/06, 1/15/11 effective 8/1/11)
15.5.6.3.8 Returning Two-Year Transfer. [FBS/FCS] A student-athlete who previously was an initial counter and who transferred to a two-year college shall not be an initial counter upon return to the original institution.
15.5.6.3.9 Delayed Initial Counter Who Does Not Return to School. [FBS/FCS] A student-athlete who receives countable financial aid but whose status as an initial counter under this bylaw is delayed until the following academic year shall be counted against the initial limit the following academic year, regardless of whether the student-athlete reports for participation or attends the institution in that academic year.
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)