If you have a cut-off saw or angle grinder with cut-off blades, taking a short piece off the tip, then etching will show if the file has been carburized... would be a dark line around perimeter if it has been (from Wayne Goddard).
Fully hardened files range from about 0.95% to 1.25% carbon. Charts/tables in Heat Treaters Guide for 1095 show tempered hardness of 65 HRc at 300F, 62 HRc at 450F, 57.5 HRc at 600 from "as hardened" of 67 HRc. The change between the temps is relatively proportional.
I think a person can reasonably assume fully hardened file hardness of 65-67 HRc as common from industry quality control. The same tempering temperatures as above on "as hardened" 65 HRc would give 63 HRc and 60 HRc and 55.8 HRc... or about that.
Mike