in the absolute words you wrote/typed you can actually break the huddle with 22
if you have 11 substitutes coming into the game at once and as they are entering the huddle as it breaks the replaced players are leaving the huddle to the sideline in a timely fashion to finish the substitution process and it is not decieving the the opposition. this would be legal.
i get so sick and tired of hearing coaches whine about breaking the huddle with 12.
it is not a FED rule (at this time) to break the huddle with 12!!!
as long as a substitution is made in a timely manner and not intentionally trying to deceive the oppponent they are allowed to complete the substitution.