Google Play 12 Testers Not Counting: Troubleshooting Guide
If Play Console is not treating your tester count as qualifying, check the exact condition instead of looking only at how many invitations you sent.
Primary source: Google Play Console Help.
The actual rule
For newly created personal developer accounts covered by Google's testing requirement, the closed test needs at least 12 testers opted in continuously for at least 14 days before you can apply for production access.
Invitation is not opt-in
A tester receiving an invitation does not prove that the tester is opted in. Confirm that the tester actually joined the closed test.
Continuity matters
A tester who leaves before the qualifying period ends does not provide an uninterrupted 14-day period. A later opt-in does not retroactively make the earlier and later periods continuous.
Check when you apply
Google's wording is specific: at the time you apply, at least 12 testers must be opted in to the closed test continuously for the preceding 14 days. Check the status of the qualifying group at application time.
Use a buffer
Keeping more than 12 testers can reduce the operational risk of a dropout. A buffer does not change Google's minimum, but it can help you stay above it.