Microsoft is planning to remove the 32GB size limit for FAT32 partitions in Windows 11. While FAT supports volumes up to 2TB, Windows has had a 32GB arbitrary limit in place for nearly 30 years.
The limit is only being removed from the format command line right now, so the existing format dialog box will continue to have the FAT32 size limit unless Microsoft finally decides to update this Windows feature it has forgotten about for decades.
Announcement: Announcing Windows 11 Insider Preview Build 27686 (Canary Channel)
Want to migrate an SMB share from one storage array to another using file tools? Haha Linux mount it and use rsync or else, loser.