Many Florida institutions operate on the belief that they are exempt from CIE licensure. Some are right. A number are relying on an exemption they no longer hold, or never held, and don’t find out until the question is asked by someone with authority to ask it.

Here is how to check.

“We’re exempt, so we don’t need a license.”

I’ve had versions of this conversation more than once, and it almost always starts the same way. A founder calls about something else entirely. Somewhere in the first ten minutes they mention, in passing, that the institution is exempt.

So I ask the question that decides how the rest of the call goes: exempt under which paragraph?

Usually there’s a pause. Sometimes there’s an answer, and it’s the right one, and we move on to what they actually called about. Often the pause is the answer.

Exemption is a category, not a decision

Section 1005.06(1), Florida Statutes, lists the institutions that fall outside the Commission’s jurisdiction. Every other college or school operating in this state has to be licensed by the Commission. You don’t elect exemption because your model feels like it should qualify. You either fit one of the enumerated paragraphs or you don’t, and the paragraph you fit under determines everything that follows.

Your Florida CIE exemption has an expiration date

This is the part that surprises people. A religious college operates outside the Commission’s purview only if it applies annually on CIE Form 113—including a sworn affidavit executed by an officer or director—and receives a letter of exemption from the Commission. The letter is valid for one year from the date it bears. Miss the filing and you have not quietly kept your exemption; you are holding an expired letter. The grandfathered category is stricter still: an institution relying on it must notify the Commission and apply for licensure the moment it stops meeting the qualifying criteria. Exemption is a status you renew, and renewals get missed.

Exempt does not mean unregulated

An institution exempt under s. 1005.06(1)(c) or (f) that solicits students still owes every prospective student a written statement of its purpose, programs, facilities, licensure status, fee schedule, refund policy, and credit transferability, delivered at least one week before enrollment or before any tuition is collected. Exempt institutions carry disclosure obligations to the students they enroll. Many don’t know it.

The cost of getting this wrong isn’t a letter. It’s discovering, with students already enrolled and tuition already collected, that you have been operating unlicensed. At that point you are not filing an initial license application on your own timeline. You are filing it under pressure, with a history behind you, and answering for the period in between.

Three questions that test your exemption

If you believe your institution is exempt, you should be able to answer all three of these without looking anything up:

1. 1. Which paragraph of s. 1005.06(1) do you rely on?
   2. Do you hold a current letter of exemption, and what is its date?
   3. Who at the institution owns the annual Form 113 filing?

If you can answer one but not three, you don’t have an exemption. You have an assumption. Those are very different things to build a college on.

If you can’t answer all three

That is what an exemption review is for. Clarion Academic Consulting advises private postsecondary institutions in Florida on CIE licensure, exemption status, and accreditation.

In an exemption review I read your programs, governing documents, and enrollment materials against s. 1005.06(1) and give you a written determination covering:

• which paragraph you rely on, and whether you actually meet it
• whether you hold a current letter of exemption and when it lapses
• what the next Form 113 filing requires
• what would have to change if you don’t meet it

Flat fee and a fixed turnaround, both agreed before any work starts.

If the answer turns out to be that you need a license, you will hear it from me, on your timeline, while you still have room to act. That is a considerably better position than hearing it from the Commission on theirs.

Clarion Academic Consulting supports private higher education institutions in Florida with CIE licensure readiness, compliance gap analysis, documentation alignment, governance, and academic recordkeeping. If your institution is working through a licensure, reporting, or documentation question, schedule a consultation.