Of the couple dozen AHJs I work in, only one enforces the 120 percent rule on the feeder conductor in that situation. However the 2013 California code still includes the 'Busbar or Conductor' 120 percent rule, so if your AHJ says it's too small then yes, you'd have to upgrade the conductor size. Or, alternatively, if that 100A breaker isn't the lone service disconnect, you could downsize it; you might have to show your AHJ a compliant load calculation on the sub to get them to allow that.
In 3 months California will go on the 2014 NEC equivalent and then you won't have this conundrum as long as the main and PV breaker at at opposite ends of the feeder.