ISO/IEC 23001-7 Common encryption in ISO base media file defines a subsample as:
9.5 Subsample encryption
9.5.1 Definition (Normative)
Subsample encryption SHALL divide each sample into one or more contiguous Subsamples. Each Subsample SHALL have an unprotected part followed by a protected part, only one of which MAY be zero bytes in length. (Note: usually both are non-zero values). The total length of all of the Subsamples (BytesOfClearData + BytesOfProtectedData for all Subsamples that make up a sample) SHALL be equal to the size of the sample itself, and they SHALL not overlap.
The specification provides some examples with 8 subsamples per sample.
I can't find any mention of an upper limit for the allowed subsample count.
In a production environment, I encountered streams with up to 10 subsamples per sample.
Is there a limit to the subsample count in specification? It could be in a different document.