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I'll throw out that __file__ is strictly optional, per https://docs.python.org/3/reference/datamodel.html. IMO it is more important to define importlib.abc.InspectLoader than __file__ (so tracebacks have source context).
Given that __file__ is optional, I'll throw out the idea of shipping modules without __file__/__cached__ and see what issues/pushback occurs. I anticipate this will likely result in having to restore advertising __file__ in frozen modules in 3.11 due to popular demand. But we /could/ use this as an opportunity to start attempting to ween people off __file__ and onto more appropriate APIs, like importlib.resources. (importlib.resources was introduced in 3.7 and I'm not sure that's old enough to force people onto without relying on a shim like https://pypi.org/project/importlib-resources/.)
Alternatively, defining a path hook referencing the python executable that knows how to service frozen modules could also work. zipimporter does this (__file__ is <zip_path>/<virtual_module_path>) and it is surprisingly not as brittle as one would think. It might be a good middle ground.