Each display requires substantilal memory bandwidth AND a Hardware rasterizer/Display-generator.
There is One available (plus built-in) on the M1, two available rasterizer/Display Generators on the M1 Pro, and four available on the M1 Max.
Closed-Display Mode:
To re-use the one for the Built-in display takes additional very high speed multiplexing Hardware and generates a lot of Heat, and Apple has decided NOT to design it that way. The general article supporting closed-display mode has been removed from the article Library, which I see as an additional indication that the feature is not going to be available.
But but but...
the built in display (for which you paid dearly) is now approaching a 4K display all on its own. Leave the built-in display open and use it as one of your displays.
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