The oil filter on my Subaru bypasses some oil at cold idle rpms with the oil at 30 degrees C. In really cold weather, it will be bypassing over 80% of the oil flow.
How do you know that?
I calculated an estimate for oil flow at the bypass pressure, based on the pressure differential test results for the FRAM Ultra in the Ascent Filtration oil filter test. (I use a FRAM Ultra).
The XG3593A filter I use is smaller than the tested filter, and I so I estimated that it hits the bypass pressure at 85% of the flow shown in the test. As far as I can tell, the filters use the same media and number of pleats, but the tested filter is taller and has more media area.
Based on this, my oil filter would hit the 12 psi bypass pressure at 47 L/min oil flow, at the same 13.5 cST viscosity used in the test, equivalent to the flow from my oil pump at 4500 rpm. In other words, even with warm ~85 degree C, 5W30 oil, some oil will be bypassed at high rpm with this filter.
I found a source that says that pressure drop across a filter goes up linearly with viscosity. I calculated the flow at which the filter will bypass at different viscosities based on this.
Of course, a Subaru filter with its 23 psi bypass probably does not bypass as easily. However, many filters that other manufacturers recommended for this engine will bypass even more easily than the filter I'm using, especially since the XG3593A has around 15% more media area than the filter FRAM recommends for this engine.
Now, Subaru engines are atypical since they use high flow oil pumps, but I suspect that if you did the math for a more typical vehicle, the oil would start bypassing at cold idle rpms at an oil temperature somewhere between 0 and 20 degrees C.