There is no all-encompassing rule.
Let's say you have a menu that calls a customer inquiry program. The customer inquiry in turn calls a program that verifies the user so she can see confidential customer information that low level users are not allowed to see. The menu would be one program, one display file, one record format. The customer inquiry would be one program, one display file and several record formats: one to search by name, one to search by ID number, one to search by phone number, one to display the results. The ID verification program would be one program, one display file and one record format (which could even be a window).
You put record formats together which make sense together. You wouldn't put the accounts payable record formats in the customer inquiry display file because they don't make sense together.
The operating system doesn't particularly care how many record formats are in a display file. It's all about how you want to organise your work.