Florida CIE Religious Exemption: Who Qualifies and How to Apply

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A Florida CIE religious exemption lets a qualifying religious postsecondary institution operate without a state license under Section 1005.06(1)(f) of the Florida Statutes. To qualify, the institution files an annual sworn affidavit (CIE Form 113) affirming its religious name, religious-vocation programs, and clearly religious degree titles. Since July 1, 2025, the Commission for Independent Education must approve each affidavit in a public meeting before issuing a letter of exemption.

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Introduction

If you are launching a Bible college, seminary, or ministry-training institution in Florida, you have probably been told you can operate without a state license. That route is real. It lives in Section 1005.06(1)(f) of the Florida Statutes, and it is called the religious exemption. But the exemption is narrower — and, since 2025, more procedural — than most founders expect.

The exemption removes your institution from the licensing jurisdiction of the Florida Commission for Independent Education (CIE). It does not erase every obligation, and it is not a backdoor around accreditation or federal financial aid. Florida has long been one of the most workable states for faith-based institutions, which is why many founders weigh Florida religious-exempt schools against full CIE licensure before they file anything.

This guide explains who qualifies for the Florida CIE religious exemption, what changed when House Bill 1255 took effect on July 1, 2025, how to apply using CIE Form 113, and how the exemption differs from licensure and accreditation. Expert Education Consultants has guided 115+ institutions through state authorization decisions, and the religious exemption is one of the most misunderstood paths we see. Read this before you assume your institution qualifies — because the Commission now reviews and votes on every affidavit in a public meeting.

What Is the Florida CIE Religious Exemption?

The Florida CIE religious exemption is a provision in state law that lets a qualifying religious postsecondary institution operate without a state license and outside the Commission for Independent Education's oversight. Under Section 1005.06(1)(f) of the Florida Statutes, a nonpublic religious postsecondary educational institution is not under the jurisdiction or purview of the Commission and is not required to obtain licensure when it meets the statutory criteria and files an approved annual affidavit.

In practice, the Commission for Independent Education can issue your institution a letter of exemption — a document stating that you have met the requirements of state law and are not subject to licensure by the Commission. That letter is what you keep on file to show banks, landlords, and partners that you are operating lawfully.

One point trips up nearly every founder: the religious exemption is an exemption from state licensure, not from every rule. It is also not accreditation, and it does not by itself make your students eligible for federal financial aid. We return to that distinction below, because it changes which path is right for your institution.

Who Qualifies for a Religious Exemption in Florida?

You qualify only if your institution is genuinely religious in its name, mission, programs, and credentials — and you can affirm each statutory criterion under oath every year. Section 1005.06(1)(f) of the Florida Statutes sets out the affirmations a nonpublic religious postsecondary educational institution must verify by sworn affidavit:

1. Religious name. The institution's name includes a religious modifier or the name of a religious patriarch, saint, person, or symbol of the church, and the affidavit explains the religious modifier, name, or symbol used.
2. Religious-vocation programs only. The institution offers only educational programs that prepare students for religious vocations as ministers, professionals, or laypersons in ministry, counseling, theology, education, administration, music, fine arts, media communications, or social work.
3. Clearly religious degree titles. Degree titles cannot be confused with secular titles. Each must include a religious modifier immediately preceding or within the degree — the Associate of Arts, Associate of Science, Bachelor of Arts, Bachelor of Science, Master of Arts, Master of Science, Doctor of Philosophy, or Doctor of Education — and the modifier must appear on the title line, on the transcript, and in official school documents and publications.
4. Program duration. The duration of all degree programs is consistent with the Commission's standards.
5. Fair consumer practices. The institution's consumer practices are consistent with those required by Section 1005.04 of the Florida Statutes.

The common thread is that everything about the institution must read as religious. A school that wants to grant a standard Bachelor of Science in Nursing or a secular MBA does not fit this profile — those founders pursue a license instead. If your model is faith-based but you are still choosing a state, it is worth comparing what it takes to open a religious-exempt university across jurisdictions before you commit to Florida.

What Changed in 2025: HB 1255 and the New Approval Process

Since July 1, 2025, the Commission for Independent Education must review and approve each religious-exemption affidavit in a public meeting before an institution is recognized as exempt. That requirement came from House Bill 1255, which the Governor signed on May 30, 2025 as Chapter 2025-110, Laws of Florida.

The 2025 law made three practical changes to Section 1005.06(1)(f):

• It replaced the older term "religious college" with nonpublic religious postsecondary educational institution.
• It expanded the sworn affirmations in the annual affidavit from five to seven, adding, among other things, an explanation of the institution's religious name.
• It moved approval out of the back office and into a public meeting. The Commission must approve an affidavit unless it is facially invalid, is contradicted by the institution's own public advertisements or other evidence, or the institution fails to provide documentation the Commission requests.

The Commission can now ask for documentation demonstrating compliance, and the institution must respond within 30 days. If an institution that already holds a letter of exemption later falls out of compliance, the Commission can revoke its approval — again, in a public meeting.

It is worth knowing that a separate 2025 bill, Senate Bill 46 (with identical House Bill 125), would have removed religious colleges from the exemption list entirely and folded them into a new licensure framework. That bill died in the Senate's Education Postsecondary committee on June 16, 2025. The exemption survived — but the message from Tallahassee is clear: religious-exempt institutions will face more scrutiny, not less.

A sourcing note for the diligent reader: during the 2025–2026 codification cycle, the statute text published by the Florida Senate and the Florida House briefly differed, with some copies still showing the prior five-affirmation language. The Florida House edition and the Commission's own guidance reflect the current Chapter 2025-110 rules, and those are the rules that govern your filing today.

How to Apply: CIE Form 113 and the Annual Affidavit

You apply by filing CIE Form 113 — the sworn Affidavit for Religious Institution Letter of Exemption — with the Commission for Independent Education, and you renew it every year. Under Rule 6E-5.001 of the Florida Administrative Code, the Commission issues a letter of exemption after it receives a properly completed Form 113 and approves it. The form is available at no cost from the Commission.

Here is the process, start to finish:

6. Confirm you meet every statutory affirmation. If even one program or degree title is secular, do not file the affidavit — you do not qualify, and the alternative is the CIE new institution application for a full license.
7. Complete CIE Form 113. An officer, director, or person holding a similar office at the institution must execute the sworn affidavit.
8. Submit the affidavit to the Commission. Be ready to provide supporting documentation within 30 days if the Commission requests it.
9. The Commission reviews your affidavit at a public meeting and votes to approve or deny it.
10. On approval, the Commission issues your letter of exemption. Renew the affidavit annually to keep it current.

Because approval now happens in an open meeting and the affidavit is sworn, accuracy is everything. A name, program list, or degree title that does not match what the Commission sees on your website can stall — or sink — your filing.

Religious Exemption vs. CIE License vs. Accreditation

A religious exemption, a CIE license, and accreditation are three different things — and a religious exemption gives you none of the recognition the other two provide. Founders routinely conflate them, then discover the gap when a student asks about federal aid or transfer credit. The table below lays out the differences.

The takeaway: a letter of exemption confirms you can operate lawfully in Florida without a license, but it is not accreditation, and it does not by itself open the door to federal student aid. Under the U.S. Department of Education's Title IV framework, federal financial aid eligibility requires accreditation by a recognized agency, valid state authorization, and certification by the Department — a religious exemption satisfies only part of that chain. Founders who need secular degrees, programs that lead to professional licensure, or Title IV access usually pursue a Florida CIE provisional license instead of the exemption.

Religious Exemption and Online Programs: The FL-SARA Requirement

If your religious-exempt institution enrolls online students who live in other states, you still have to address state authorization for distance education — the exemption does not make that obligation disappear. According to the Florida Department of Education, institutions operating under Section 1005.06(1)(f) must submit a Memorandum of Understanding annually with their FL-SARA application. That memorandum is a direct contract with the Postsecondary Reciprocal Distance Education Coordinating Council, which provides additional oversight for institutions enrolling out-of-state distance-education students.

In other words, being exempt from CIE licensure in Florida is not the same as being authorized to teach a student sitting in Georgia, Texas, or Ohio. Distance education reaches across state lines, and each state expects some form of authorization — which is why reciprocity agreements like SARA exist. If you are mapping out where your online students will live, our guide to navigating state authorization walks through how multi-state approval actually works.

Is the Religious Exemption Right for Your Institution?

The religious exemption is the right path only if your institution is fully religious in name, mission, programs, and degrees — and you are prepared to stand behind that under oath every year. For a seminary, Bible college, or ministry-training institution, it can be the cleanest, fastest way to operate lawfully in Florida without entering the full licensure system.

It is the wrong path if you plan to award secular degrees, run programs that lead to state professional licensure such as nursing or counseling, or offer students access to federal financial aid. Those goals require a license, accreditation, or both — and filing a religious-exemption affidavit you cannot honestly support now carries real risk, because the Commission reviews and can revoke approval in a public meeting.

This is the decision Expert Education Consultants helps founders get right before a single document is filed. We assess whether your institution genuinely fits Section 1005.06(1)(f), prepare an accurate CIE Form 113 affidavit, and — when the exemption is not the right fit — map the licensure or accreditation route that is. State authorization is a journey, not a one-time form, and the institutions that succeed are the ones that choose the correct path at the start.

For more information about whether the Florida CIE religious exemption or full state licensure is the right path for your institution, contact Expert Education Consultants (EEC) at +19252089037 or email sandra@experteduconsult.com.

Frequently Asked Questions

What is a religious exemption?

A religious exemption allows a qualifying religious postsecondary institution to operate without a state license. In Florida, it is granted under Section 1005.06(1)(f) of the Florida Statutes, which removes religious institutions from the Commission for Independent Education's licensing jurisdiction when they file an approved annual sworn affidavit. The institution must be religious in name, programs, and degree titles.

What is state authorization for colleges?

State authorization is the legal approval a college needs to operate and grant degrees within a state. In Florida, most degree-granting institutions obtain it through a license from the Commission for Independent Education under Chapter 1005 of the Florida Statutes. A religious exemption is one narrow alternative to standard state authorization.

How is state authorization different from accreditation?

State authorization is government permission to operate; accreditation is a quality review by a private, federally recognized agency. A state license or a religious exemption lets you legally operate in Florida, but neither one is accreditation. Under the U.S. Department of Education's framework, an institution generally needs both state authorization and accreditation to access federal student aid.

Do online colleges need state authorization in every state?

Yes — an online college generally needs authorization in every state where it enrolls students, not just its home state. Most institutions handle this through the State Authorization Reciprocity Agreement (SARA). Per the Florida Department of Education, religious-exempt institutions in Florida must submit a Memorandum of Understanding annually with their FL-SARA application to enroll out-of-state distance-education students.

What is the difference between licensing and accreditation?

Licensing is permission from a state agency to legally operate; accreditation is voluntary recognition of quality from a federally recognized accreditor. In Florida, the Commission for Independent Education issues licenses, while agencies like SACSCOC or DEAC grant accreditation. You can be licensed, or religiously exempt, without being accredited, but federal student aid generally requires accreditation.