Florida CIE Provisional License: 2025–2026 Founder’s Playbook

If you are an investor planning how to open a college or university in Florida, the CIE Provisional License is your first hard gate. This playbook explains the exact sequence, documents, inspections, and hearing preparation steps you will run in 2025–2026. You will also see how accreditation, Title IV, NC‑SARA, and (optionally) SEVP/SEVIS fit into the plan without wasting months. We use plain language, real‑world patterns, and checklists you can use the same day. For founders asking how much does it cost to open a college or university, we present a budgeting framework that highlights Florida’s fee model, facilities decisions, staffing, systems, and risk buffers. Throughout, we keep the investor lens: focus, evidence, and operational 

Introduction & Orientation

Florida’s Commission for Independent Education (CIE) regulates nonpublic postsecondary institutions under Chapter 1005, Florida Statutes, and Rule 6E, Florida Administrative Code (as of August 2025). If you are opening a college or university—degree or non‑degree—your practical path begins with the Provisional License. After you demonstrate sustained compliance and, when appropriate, meet accreditation milestones, you move to an Annual License; accredited institutions may qualify for License by Means of Accreditation (LBMA). The winning investor strategy is parallelization: assemble the CIE application, stand up governance and core policies, and begin accreditation readiness at the same time. EEC’s role as your accreditation consultant and operating partner is to keep those tracks synchronized so that what the state sees, what the accreditor sees, and what your operations actually do are perfectly aligned.

Investor Blueprint: Mission, Model, Moat

Mission clarity anchors regulator confidence and guides every downstream decision. Keep it specific: who you serve, which programs you will offer, and how you will measure learning. Decide delivery model early—on‑ground, hybrid, or online‑first. Online‑first reduces facilities spend but increases scrutiny on student support, data governance, accessibility, and proctored assessment. Hybrid models add teaching locations, which can trigger additional statutory and rule requirements. Finally, define your moat: licensure‑linked pathways, embedded employer projects, or clinical pipelines that translate directly into outcomes.

Scope and sequencing matter. Start with one to four programs so you can demonstrate quality. Sprawl is the enemy of candidacy and site visits. Collect proofs of capacity from day one: curriculum maps, assessment plans, faculty CVs aligned to course level, student‑services SOPs, and conservative financial planning with reserves. Your go‑to‑market thesis should quantify demand, price, yield, and early employer partnerships. That thesis not only informs recruiting but also helps leadership answer predictable Commission questions with evidence rather than aspiration.

Florida CIE Basics (Statute, Rule, License Types)

Governing authorities (as of August 2025): Chapter 1005, Florida Statutes; Florida Administrative Code Rule 6E; and CIE directives (applications, checklists, calendars).

License types: Provisional License (initial authorization for new unaccredited institutions), Annual License (ongoing authorization after conditions are met), License by Means of Accreditation (LBMA) for institutions holding recognized institutional accreditation, and provisions for out‑of‑state institutions and additional locations. Exemptions exist for specific categories (e.g., certain religious institutions), but do not assume an exemption—request a determination from CIE staff before making public claims. Remember: licensure and accreditation are distinct. Florida licensure authorizes operation in Florida; institutional accreditation is a separate quality assurance status required for Title IV.

The Provisional License Application: Documents & Evidence

Florida’s Provisional License filing is document‑dense. A coherent application shortens staff review and improves your Commission presentation. Core components typically include corporate and governance records, leadership and faculty documentation, academic integrity artifacts, student‑facing documents, facilities and safety evidence, financial capacity, marketing samples, agent licensing (if applicable), and site readiness.

• Corporate & governance: articles of incorporation/organization, bylaws/operating agreement, board roster, conflict‑of‑interest policy, org chart.
• Leadership & faculty: CEO/President, Chief Academic Officer (CAO) with real authority over curriculum and assessment, registrar/compliance lead, and faculty CVs that match course level and discipline.
• Academic integrity: program learning outcomes, curriculum maps, syllabi exemplars, credit hour policy, program length and modality, assessment plans.
• Student‑facing: professionally edited catalog (admissions, transfer of credit, grading, attendance, SAP, student conduct, complaint process, refund policy), enrollment agreement, and disclosures.
• Facilities & safety: lease/deed, fire/occupancy inspections, ADA/504 considerations (on‑ground).
• Financial capacity: multi‑year pro formas, cash flow, reserves policy; supporting statements sufficient to protect students.
• Marketing & agents: truthful, non‑deceptive claims; agent licensing in Florida if recruiters operate in the state.
• Site readiness: evidence that the paper institution matches reality; pre‑opening inspection commonly occurs.

Expect written questions during review. Answer promptly with cross‑references to exhibits (for example, “Catalog §4.2; Faculty Exhibit B; Facilities Exhibit C‑3”). Clarity, not volume, moves your file forward.

Florida Catalog + Enrollment Agreement Deep‑Dive (with samples)

Your catalog and enrollment agreement are the centerpiece of Florida’s consumer‑protection review—and the reason many applications stall. Reviewers expect plain‑English promises you can keep, operational feasibility, and precise language around accreditation and Title IV that reflects your current status.

What Florida reviewers expect to see (and why)

• Plain‑English promises you can keep: the catalog reads like a covenant with students; the enrollment agreement mirrors the same terms.
• Operational feasibility: if you promise a library or 24/7 tutoring, show the contract and clear access instructions.
• No aspirational accreditation or Title IV language: use precise statements about current status and timelines.

Catalog section‑by‑section: what to include and how to write it

Admissions and transfer of credit

Publish eligibility criteria and documentation requirements. For transfer credit, specify maximums, recognized sources, evaluation process, and appeals. State clearly that transfer decisions are case‑by‑case and not guaranteed.

Academic engagement and attendance

For on‑ground, define schedules, absences, and make‑up work policy. For online, define academic engagement (graded submissions, instructor‑moderated discussions, attendance in synchronous sessions), and set minimum weekly engagement expectations to maintain active status.

Credit hour & program length

Publish your credit hour policy and show how contact or engagement maps to credits by modality. On each program page, include total credits, expected time to completion, delivery modality, course list, and program learning outcomes.

Grading, Satisfactory Academic Progress (SAP), and course repeats

Define the grading scale and good standing. SAP must include both pace and GPA requirements, review frequency, warning/probation, and appeals. Spell out repeat limits and how repeats affect GPA and pace.

Refund policy (publish tables + examples)

State the calendar basis and show how refunds are calculated for cancellations, withdrawals, and dismissals. Use a table and at least two worked examples with dates and amounts that align with your instructional calendar.

Complaint resolution

Publish internal steps and Commission contact for students who have exhausted institutional remedies. Keep tone neutral and respectful.

Student conduct and academic integrity

Define expectations for academic honesty and conduct. Align sanctions with due process; publish notice, response, and appeal steps.

Accessibility and accommodations (ADA/504)

Provide a straightforward process for requesting accommodations. Affirm that accommodations do not lower academic standards while ensuring equal access.

Career services and disclosures

If publishing placement data, define the method, time window, and denominator. Avoid guarantees; use accurate descriptors of services.

Enrollment agreement: how to mirror the catalog (line‑by‑line)

• Program name and length must match the catalog exactly.
• Itemized costs: tuition rate or term tuition; fees labeled consistently; estimated books and supplies.
• Refund terms: mirror the catalog’s table and narrative; include a plain‑language example.
• Student acknowledgments: receipt of catalog; acceptance of policies; accurate accreditation/Title IV status statements.
• Signature and date lines for both parties; addenda listed by name and date.

Facilities & Inspection: What Reviewers Look For

On‑ground delivery requires fit‑for‑purpose space and safety evidence: executed lease or deed, occupancy and fire inspections, ADA access, and—as applicable—labs staged with equipment lists. Staff will compare the site to the application; promised spaces must exist. Online‑first institutions still need a Florida‑appropriate presence and robust student services, plus data governance aligned to modern safeguards.

Governance, Faculty, and Student Services (Evidence That Lands)

Seat an independent Board with recorded meeting cadence. Your CAO must have real authority over curriculum, faculty qualifications, and assessment. Publish conflict‑of‑interest controls and follow them. Map faculty CVs to course level and content; document tested experience when used. For student services, provide advising, tutoring, library/e‑resources, disability accommodations, and proactive academic success coaching—especially for working‑adult models. Demonstrate institutional effectiveness with an assessment cycle that produces real improvements: outcomes → evidence → actions → follow‑up.

Commission Hearing Prep—Question Bank & Model Answers

Commission meetings move quickly. You will typically have five to ten minutes for staff presentation and Q&A. Your objective is to demonstrate coherence and readiness. Practice concise, factual, non‑defensive answers.

Governance & leadership

• Who has final authority over curriculum and assessment? — The CAO, empowered by Board policy; chairs Academic Council; approves curriculum maps, faculty assignments, and assessment cycles.
• How will the Board avoid conflicts of interest? — Formal policy; annual disclosures; related‑party transactions require prior Board approval, market comparison, and minute documentation.

Catalog, enrollment & refunds

• Catalog and enrollment agreement mismatch? — Reconciled on [date]; both now mirror tuition and refund tables; admissions and finance teams trained on the updated language.
• Walk through refund math for a mid‑term withdrawal. — Use the published example tied to your term calendar; state tuition, refund percentage, fees, and net retained.

Faculty sufficiency & qualifications

Explain your faculty‑to‑course matrix, terminal degree expectations, and how you document tested experience for practice‑heavy courses; show mentoring and syllabus alignment.

Student services & outcomes

Show online support commitments (24/7 tutoring, library databases with remote authentication), early‑alert triggers in the LMS, and advisor outreach timelines; explain your outcomes tracking windows and how you report methodologically sound, non‑misleading data.

Facilities & inspection

Confirm lease execution, safety inspections with dates, ADA access, and staged labs with inventories. Bring photos and a floor plan that match the application.

Accreditation, Title IV & SARA

State your accreditor engagement status and realistic candidacy timeline; explain why you are not pursuing Title IV prematurely; describe your SARA plan and a state‑activity matrix for clinicals/placements.

Accreditation Strategy (Regional/National) & LBMA Positioning

A Florida license authorizes operation; institutional accreditation provides external quality assurance and is required for Title IV. In 2025–2026, most degree‑granting institutions target a regional/institutional accreditor aligned to geography, or a national accreditor aligned to modality/mission. Each path has stages—eligibility, candidacy/pre‑accreditation, initial—and time‑to‑decision depends on readiness. LBMA becomes realistic once you achieve accredited status in good standing and your Florida scope aligns.

Title IV Readiness (When to Plan It and Why)

Title IV is a growth lever that magnifies operational risk if pursued too early. Build accreditation status, financial responsibility, administrative capability, consumer information, and data security before applying. Plan the Title IV project while your Provisional License and candidacy are moving, but avoid premature filings.

Distance Education & NC‑SARA (Online‑First Play)

Online‑first models require lawful multi‑state operations. NC‑SARA provides reciprocity for distance education beyond your home state but does not cover on‑ground activities such as clinicals. Build a matrix of student locations, activities, and required approvals. If Florida is your home base, confirm SARA details as of August 2025 and budget membership and renewal fees.

International Students & SEVP/SEVIS (If Applicable)

If you plan to enroll F‑1 or M‑1 students in the United States, seek SEVP certification (Form I‑17 in SEVIS). Budget petition and site‑review fees and staff a PDSO/DSO team. Keep institutional and accreditation data current in SEVIS and calendar recertification windows. Florida licensure and federal immigration certification are separate but must align with your real operations.

Timelines That Actually Work in 2025–2026

• CIE Provisional License: approximately four to eight months from complete submission to Commission vote, depending on completeness, inspection, calendars, and responsiveness (as of August 2025).
• Accreditation candidacy: approximately twelve to twenty‑four months from initial engagement, varying by accreditor and readiness.
• Initial accreditation: often two to five years total effort from first contact.
• Title IV initial participation: several months post‑accreditation if audits and systems are ready.
• SEVP certification: variable; plan for evidence requests and site scheduling.

Budgeting: How much does it cost to open a college or university in Florida?

There is no single number, but there is a responsible way to budget. Florida’s fee framework in Rule 6E provides hard inputs; facilities, people, systems, accreditation, international overhead, marketing, and contingency round out the plan. 

A. Hard, verifiable fees (as of August 2025)

Florida uses a fee framework that includes Base Fees and Workload Fees for licensing actions. Treat these as hard inputs because they are published and predictable.

B. Facilities & build‑out

Plan for lease or purchase, code compliance, inspections, ADA access, and—if applicable—labs for allied health or STEM programs. Stage build‑out to match enrollment.

C. People

Staff leadership roles (CEO/President, CAO, Registrar/Compliance), a qualified faculty pool, and student services (advising, tutoring, library, disability accommodations). For online‑first models, budget more for IT and data governance.

D. Systems

Select an LMS and SIS, integrate CRM and financial systems, and provide accessibility tools and proctoring as needed. Ensure reporting can support accreditation and Title IV later.

E. Accreditation march

Budget for accreditor workshops, candidacy/initial fees, evaluator visits, and internal gap‑closing projects aligned to standards.

F. International (optional)

If enrolling international students, budget certification fees and compliance overhead for PDSO/DSO staffing and reporting.

G. Go‑to‑market

Fund compliant advertising, website content aligned to the catalog, community outreach, and employer partnerships.

H. Contingency

Maintain at least a 10–20% reserve to handle unknowns without compromising student services or compliance.

Case‑Style Scenarios: Why They Worked

Scenario 1 — Online‑First Business & Tech (Florida‑based, national reach)

Secure the Provisional License; align catalog and enrollment agreement; prepare for regional accreditor eligibility; plan SARA membership for distance‑education expansion. Evidence that moved the needle: student‑support readiness (library and tutoring), a single flagship master’s program at launch, and a clean faculty‑course alignment.

Scenario 2 — Allied Health Institute (On‑ground with staged labs)

Secure clinical MOUs early; stage lab investment; demonstrate safety, compliance, and faculty sufficiency; pursue programmatic accreditors after institutional systems stabilize. Commission confidence rose when facilities and clinical capacity were real, not aspirational.

Scenario 3 — Hybrid Urban University (Micro‑campuses + online core)

Use small teaching locations for hands‑on learning and online delivery for lecture/core. Plan substantive‑change approvals in advance. Student outcomes and a robust advising model for working adults supported approval and enrollment quality.

‍Risk Map & De‑Risking Tactics

‍Florida Founder’s Toolkits (Templates You Can Reuse)

1) Single‑Page Program Blueprint (fill once per program)

• Program name and CIP code
• Credential and credits
• Delivery (on‑ground/online/hybrid)
• Program learning outcomes (4–6)
• Course list with credit hour mapping
• Assessment plan (key assignments and rubrics)
• Faculty pool (terminal degree, industry expertise, tested experience evidence)
• Student support (advising, tutoring, library, accessibility)
• Licensure alignment if applicable
• Risks and mitigations

2) Faculty‑to‑Course Matrix (snapshot)

3) Refund Calculator Worksheet (structure)

• Inputs: term length, withdrawal week/day, tuition per credit, credits attempted, refundable vs. non‑refundable fees.
• Outputs: refund amount and tuition retained.
• Include two or more pre‑built examples to validate logic.

4) Early Alert SOP (for online‑first retention)

• Trigger: no academic engagement for 7 days or missing two graded submissions.
• Workflow: advisor outreach within 48 hours → faculty notification → intervention plan recorded in SIS.
• Escalation: if no response in 5 days, second outreach and text; connect to tutoring for academic issues or student services for life circumstances.

FAQs 

What is a Florida CIE Provisional License?

It is the initial authorization to operate a nonpublic postsecondary institution in Florida. You must satisfy Chapter 1005 and Rule 6E requirements, pass staff review and inspection, and secure a Commission vote (as of August 2025). This is the first legal step in how to open a college or university in Florida.

How long does a Provisional License last?

It is time‑limited and conditional. After demonstrating sustained compliance, institutions transition to an Annual License or, if accredited, License by Means of Accreditation (LBMA). Timelines are set by the Commission under Rule 6E (as of August 2025).

Do I need accreditation before I apply?

No. Licensure and accreditation are separate. Many founders apply for a Provisional License while preparing for accreditor eligibility or candidacy. An accreditation consultant helps sequence this without over‑promising.

When should I pursue Title IV?

After sufficient accreditation status and administrative capability are in place. Premature pursuit can slow approvals and increase risk. Build audits, consumer information, and security first.

What goes wrong most often in Florida applications?

Mismatched catalog and enrollment agreement; weak faculty‑course alignment; refund math errors; facilities not inspection‑ready; and over‑promising on accreditation or Title IV.

How much does it cost to open a college or university in Florida?

Budget for Rule 6E fees, facilities, people, systems, accreditation activities, go‑to‑market, and contingency. Allied health labs and clinicals elevate costs; online‑first shifts spend to IT and student support.

Are religious institutions exempt?

Some may qualify under Chapter 1005, but exemption tests are specific. Do not assume—request guidance from CIE staff before making public claims.

Can I advertise before I’m licensed?

You may build brand awareness, but avoid claims that imply authorization, accreditation, or Title IV participation that you do not yet have.

What if I’m already accredited in another state?

You still need Florida authorization to operate in Florida. LBMA may be available if your accreditation meets Florida criteria (as of August 2025).

How does NC‑SARA affect Florida licensure?

SARA covers distance‑education reciprocity, not on‑ground operations. You still need Florida authorization to operate here.

Do I need agent licenses for recruiters?

If you use agents operating in Florida, plan for agent licensing under Rule 6E (as of August 2025). Confirm specifics before launch.

I’m opening a K12 school too—does CIE apply?

No. CIE regulates nonpublic postsecondary institutions. Opening a K12 school follows separate state and local processes.

Can I launch with many programs at once?

You can propose multiple programs, but more programs increase risk. Most successful founders launch with a focused slate to build evidence and quality.

What’s asked at the Commission meeting?

Expect questions about governance, faculty credentials, catalog integrity, refund policy, student services, outcomes, facilities readiness, and marketing claims. Bring data, not aspirations.

What happens if my catalog and enrollment agreement change after approval?

Publish a new version with a clear effective date and update the enrollment agreement simultaneously. Notify current students if changes affect them and train staff before the effective date.

Can I start recruiting while my application is pending?

You may develop brand awareness, but avoid claims implying licensure, accreditation, or Title IV that you do not yet have. Use neutral, informational language.

How should I prepare for site inspection logistics?

Create a room‑by‑room checklist: signage, ADA access, equipment lists, visible emergency procedures, and an evidence binder with facility documents and photos matching your application.

Do online programs require proctored exams?

Not universally. Define your approach. If you use proctoring, disclose technology and privacy considerations; if you use alternative assessments, show how you ensure academic integrity.

How do I avoid refund‑policy disputes?

Train staff with worked examples; generate a pre‑withdrawal estimate for students; document every step; confirm in writing. Consistency prevents complaints.

What if first‑year enrollment is lower than forecast?

Protect academics and student services. Adjust adjunct scheduling, defer non‑essential capex, and re‑phase program launches. Communicate transparently with students and maintain compliance.

Is there a fast track if I’m already accredited elsewhere?

Florida recognizes LBMA for qualified, accredited institutions. You must still demonstrate compliance with Florida law and provide Florida‑specific disclosures.

How does opening a K12 school fit with this plan?

K‑12 is regulated separately. The disciplines are similar—governance, safety, consumer info—but the licensing body and content standards differ. Run K‑12 as a parallel workstream with dedicated compliance leads.

Can we add programs after Provisional License approval?

Yes, but changes may require Commission notification or approval and, later, substantive change with your accreditor. Plan additions in quarterly cycles.

What’s the biggest founder mistake you see?

Launching with too many programs and publishing paper policies that don’t match operations. Florida reviewers and accreditors reward focus and follow‑through.

Will Florida accept electronic catalogs and enrollment agreements?

Yes, but ensure version control and that the student’s executed agreement is retrievable and tamper‑evident. Keep a signed copy with the exact catalog version referenced by date or version number.

What staffing mix is realistic for launch?

A lean core works: CEO/President, CAO, Registrar/Compliance, Finance, IT support, and a right‑sized faculty pool. For online‑first, shift budget from facilities to advising, tutoring, and information security.

How detailed should program outcomes be?

Clear and measurable. Each outcome should support assessment design and map to courses. Avoid vague verbs; prefer analyze, design, evaluate, and synthesize with specific contexts.

Can I outsource library services?

Yes, but document contracts, access methods, orientation for students, and how faculty embed research expectations in course design.

What belongs in the student conduct policy?

Academic honesty definitions, classroom and online behavior expectations, sanctions scaled to severity, and a due‑process pathway with notice and appeal.

Do short certificates need the same rigor?

Yes—proportionate to scope. Even short programs require outcomes, assessment, qualified instructors, and accurate disclosures to protect students.

How do I present clinical capacity credibly?

List signed MOUs, number of slots by term, supervision ratios, and contingency partners. Align lab schedules with placement windows so students do not bottleneck.

What is the best way to show continuous improvement pre‑launch?

Pilot modules or short courses, collect early student feedback, and document changes made. Use faculty peer reviews to refine rubrics before the first full term.

Should I publish tuition guarantees?

Only if you can honor them across the expected term length. If you offer a guarantee, define scope, exclusions, and the process for catalog changes that do not affect the guarantee.

How do I avoid scope creep before the hearing?

Freeze the initial program list and locations once the application is filed. Any change triggers internal governance review and may require Commission notification or approval.

Risk Scenarios and Response Plans

Refund dispute escalates to a formal complaint

Immediately generate a written calculation using the published example format; meet with the student to explain line by line; document the meeting; and, if an error is found, correct it promptly and apologize in writing. Use the case in staff training to prevent recurrence.

Adjunct resigns mid‑term in a high‑enrollment course

Activate a pre‑vetted reserve instructor from your adjunct pool. Notify students within 24 hours, publish continuity steps (office hours, grading cadence), and have the CAO review syllabi alignment. Capture the event in your risk log and adjust hiring buffers.

Clinical partner reduces placement slots

Engage contingency partners identified in your clinical capacity plan; redistribute cohorts; and inform students of changes with revised schedules. Use the incident to validate your contingency ratio and update the MOUs list.

Unexpected inspection observation

Acknowledge the observation respectfully, provide context, and commit to remediation with a timeline. Complete the fix within that timeline and file an internal corrective‑action report with evidence before your next Commission interaction.

Data‑privacy incident involving a third‑party vendor

Invoke the incident‑response plan: contain, assess, notify leadership, and document. Coordinate with the vendor to identify root cause and remediation. Review contracts for indemnification and update vendor‑due‑diligence procedures.

Enrollment shortfall relative to forecast

Freeze non‑essential hiring, protect student services, intensify advisor outreach to improve persistence, and revise the next intake’s program mix. Update investors with a factual variance analysis and a corrective plan.

Conclusion & Next Steps

Florida rewards founders who submit coherent documents, build real student support, and keep promises precise. Your fastest and safest route to a CIE Provisional License is a clean catalog and enrollment agreement, inspection‑ready facilities—or a robust online‑first support model—and a governance and assessment spine that accreditors will recognize. From there, you can progress to Annual License or LBMA, pursue accreditation milestones, and, when ready, add Title IV. If you are serious about opening a college or university in Florida in 2025–2026—or pairing it with opening a K12 school—bring EEC in as your accreditation consultant and operator‑minded partner.

For personalized guidance contact Expert Education Consultants (EEC) at +19252089037 or email sndra@experteduconsult.com.