The answer is: no one knows.
Well, someone knows, but the inrush pass/fail test is considered proprietary information and how that determination is made is not published by the USB-IF, for reasons that are theirs to know. I know that's not a very satisfying answer, but that's the simple truth.
To quote the electrical compliance tests page (the text is in red so you know they're even more serious than the normal level of USB-IF seriousity):
NOTE: Some of the following approved test solutions use proprietary software to assess signal quality and inrush current events. The only official analysis tool for certifying signal quality and inrush current is USBET20 published by the USB-IF. Please be sure to run captured signal quality and inrush current test data through USBET for an official assessment of the measurement.
So they are explicitly saying that you cannot make the determination using a waveform capture alone or several oscilloscopes' "USB inrush test" feature (I've never seen this, so I must not using expensive enough oscilloscopes) not valid and the only way to meet inrush current compliance is if USBSET20 says your device meets compliance. It takes in .tsv/.csv waveform capture data and poops out USB compliance justice (in html format).
From the USB tools download page:
USBET20 (8MB, August 2016) is a stand-alone electrical signal analysis tool for USB Compliance testing. USBET20 is the official compliance electrical analysis tool that performs pass/fail assessments on signal quality and inrush current data captured from an oscilloscope.
To elaborate further, they only tell you the minimum measurement time because that's all you need to know. You don't need to know how the actual pass/fail determination is made, and indeed, they aren't telling. The USB-IF is willing to tell if you if you are in compliance, but they aren't telling anyone how they actually determine that (at least for inrush current).
That maximum downstream load is a specification relevant to an upstream device (host port or hub), meaning when designing one of those and NOT a peripheral, then that hub or port should be able to withstand a maximum downstream load of a 44Ω resistor and a 10µF capacitor in parallel. And you're absolutely correct - this could draw as much as 25mA over the 100mA limit under the most extreme conditions. As such, an upstream device must be able to handle such a load ("handle" meaning not suffer more than a 330mV droop) being connected.
However, if your peripheral were such a load, it would not pass compliance because it will draw over 100mA at some (essentially all) of the possible voltage range. That load is meant entirely as a worst-case design scenario for upstream devices, and is used to test them. It is not relevant to a peripheral inrush current compliance test.
What is relevant is that is not really about the current. It's about charge, so you're already sort of on the right path with this. Specifically, it is about the voltage droop. An upstream port on a hub must have no less than 120µF of very low ESR capacitance on its output VBUS, the bus powering downstream peripherals.
A host or powered hub yielding the worst case output voltage (4.75V), going through the crappiest connectors, the crappiest cable, to an unpowered hub that also uses the crappiest connectors, then that hub further has the crappiest VBUS input voltage to VBUS output/downstream voltage drop (350mV), the voltage will be 4.4V. That 4.4V, connected through crappy connectors to a crappy peripheral can cause it to see the real absolute minimum voltage for a low-power device: 4.35V. From page 175 of the USB 2.0 spec:
Let's do some math. an unpowered upstream hub must have 120µF of downstream capacitance. At 4.4V*120µF, that's 528µC of charge. A device connected has a 10µF capacitor. If you pretend that there is no static load or power, just a charged capacitor on the port, and an uncharged 10µF one in the peripheral, charge will be distributed not until the other is full, but until the voltage between them is equal. Charge is conserved, so the point at which the two capacitors voltages will equal each other, given 528µC of starting charge, is roughly 4.06V. Or, 40.6µC transferred. Add in the connector resistances, and the downstream capacitor will not even be able to draw that much charge during inrush.
So, literally the only important factor is that it does not exceed 10µF. Current is not really the thing that matters, its how depleted the hub's downstream port capacitance can be depleted without drooping more than 330mV during the transient before things like cable inductance give time for the actual host power to catch up. And a 10µF capacitor is the closest available value that won't do that.
Also note that there is no capacitance limit. You can have 1F of all ceramic capacitance on a downstream device, as long as you have it divided into 10µF sections, and only one of which will connect on attachment. Once the device is attached, you must stay below any 10µF step, but you may gradually "online" more capacitance in 10µF increments. The whole point is avoiding that transient.
And yes, this means a low-power peripheral is not only supposed to work down to 4.35V, but also withstand a 330mV voltage droop transient, such as when something new is connected to a hub. This also means that, theoretically, if you plugged in two devices at JUST the right times so as to be nearly simultaneous, you could possibly disrupt operation of other devices on the unpowered hub. I'm sure the robots, with their HPETs, will exploit this critical flaw in our USB bus specification to bring about our downfall.
Now, there are probably other subtle aspects like dI/dT rates or whatever else. Who knows exactly what is incorporated into the pass fail test. Considering that they have an entire 7.5MB installer for the program that performs that test, its probably safe to assume that its not something simple. But just keep in mind that you are trying to avoid over depleting upstream capacitor reservoirs with your own downstream capacitance, and that's really all there is to it. As long as you don't cause other devices to fail due to the voltage transient your peripheral could potentially cause, you'll be ok. And really, it just amounts to keeping the capacitance seen on attach or other power state changes to 10µF. It actually would be better to try to have less than that, 10µF is the maximum. I don't know where the idea started that the absolute maximum should be the 'standard' capacitance started, but good engineers know better than to go for maximum ratings. Always underrate. I like a nice 4.7µF capacitor. If you need more decoupling, all you have to do is not connect it directly to VBUS and limit it to 100mA surge draw and you're golden. But you're allowed far in excess of 100mA - as long as only 40.6µC worth of charge is transferred during a region.
Don't worry about the inrush current. The inrush current test is not really about inrush current.
... do I need to or should I provide unrush current regulation on my device? The device is only ever plugged into a laptop/desktop. What are the consequences of not providing any inrush current regulation on the device?
"Properly" you should provide device side current limiting.
Worst case you can dip the power rail and cause an outage on other connected equipment or cause startup problems with the device you are connecting.
In practice I'd expect that most systems will survive plugging in capacitors substantially greater than 10 uF. However, if this did cause misoperation or even damage in practice you would have no grounds for complaint.
10 uF would have trouble pulling the skin off most rice puddings and even say 100 uF is not a vast amount of capacitance*.
But, if you did want to provide startup protection you should be able to achieve this with 1 x MOSFET, 2 x R, 1 x C and an optional diode.
The MOSFET is in series with the large capacitor - call it C1.
When power is off the MOSFET is off.
Place a resistor R2 across FET d-s to provide some startup current if desired.
Place a timing cap C1 from gate to source and a turn on resistor R1 from gate to supply.
At turn on the MOSFET is off. FET gate rises (or falls depending on whether low side N Channel or high side P Channel) and FET starts to conduct and then is fully conducting. By making R2 suitably low and turn on time delay from R1, C1 long enough the main cap can be charged mainly via R2. This is not essential but without R2 the FET needs to transition from off to on slowly enough not to cause inrush problems (still).
Best Answer
You can have as much capacitance as you want. You just have to limit how fast you ramp up the voltage on those capacitors.
You can google "inrush current limit circuit" to find circuits that solve this problem. Or, if you're using a switching supply, you can look for one with a "slow start" circuit.
If you have some part that has a maximum voltage ramp-up time (some digital circuits are like this) powered by the same supply as the big capacitors, that might limit how slowly you can ramp the voltage, and thus limit how big your capacitors can be without violating the current limits for USB.