As others alluded to, there's no true "bare" minimum. Tornado formation isn't really a yes/no science, and we consistently see tornadoes form in situations that just defy common knowledge.
My personal favorite example is the activity over Northern Alabama during the early morning of February 6, 2008. We saw not one, but two long tracked supercells that produced 2 EF-4 tornadoes just before sunrise in an area of 250-300 J/KG of CAPE.
SBCAPE, while a nice tool, is somewhat overrated IMHO in the larger scheme of things. In low to moderate CAPE environments, I view lapse rates as the most important tool for judging a thermodynamic environment. When I'm chasing a dryline setup across Kansas in late May when there's 4,000 J/KG of SBCAPE, it's a little different. But in Dixie in February and March, I tend to look at lapse rates before looking at SBCAPE.