You wouldn't be departing far from the accuracy of the concentration approximation if you had a 2 M solution of HCl, and that's enough to get you a negative pH. They sell pH paper that can measure in the negative pH range.
I'm not even sure that the activity necessarily has an effect here, since the pH is defined by the concentration. I guess it could have an effect if you had so little water that the HCl wasn't actually dissociating. That's probably hard to do though. Concentrated HCl is only 37% HCl (remainder water), so I doubt you're even approaching that situation with 12 M conc. HCl.