It all depends on the steel and the alloy in the steel. It's like a cake mix, lots of ingredients. Good steel that is hardenable is more expensive than plain low end steel with little to no alloying agents. Even steel like 1144 can be hardened. It gets case hardened to a depth of about .030 Can't really get it much deeper than that. On the surface it would pass a file test, but you can drill a hole through it as it is soft in the middle. A good tool steel like O1, A2 or other steels can be thru hardened to achieve a hardness of Rc55-58 or even up to Rc61 or so, but it would not be practical at Rc61. Steels like D2 can be brought up to Rc62 but it is expensive and would be difficult to sharpen.