i think it is walkons only, even though it would make sense for it to be full-year ineligibles (ineligible recruits) because they don't practice. i don't think they count - but not 100% on that. definitely the in-season ineligible guys don't count.
also, the amount of stunted development is relatively minor, not worth sweating much. i think its also on the 3rd walkon when the penalty starts, but this is a pretty stand-alone issue (it doesn't connect to much else) and the penalty is minor, so my grasp on these details is definitely not the best.