I've seen nowhere that says it takes X number of images -- 1 would trigger it from what I've seen.
To quote Gruber:
Furthermore, one match isn’t enough to trigger any action. There’s a “threshold” — some number of matches against the CSAM database — that must be met. Apple isn’t saying what this threshold number is, but, for the sake of argument, let’s say that threshold is 10. With 10 or fewer matches, nothing happens, and nothing can happen on Apple’s end. Only after 11 matches (threshold + 1) will Apple be alerted. Even then, someone at Apple will investigate, by examining the contents of the safety vouchers that will accompany each photo in iCloud Photo Library. These vouchers are encrypted such that they can only be decrypted on the server side if threshold + 1 matches have been identified. From Apple’s own description:
Using another technology called threshold secret sharing, the system ensures the contents of the safety vouchers cannot be interpreted by Apple unless the iCloud Photos account crosses a threshold of known CSAM content. The threshold is set to provide an extremely high level of accuracy and ensures less than a one in one trillion chance per year of incorrectly flagging a given account.