Pretty much all vintage axes can be sharpened with a file - with few exceptions. The problem arises from the oxidation layer that forms on old axes (under the rust). That surface layer is harder than the underlying steel.
Work through the oxidation layer in one small area. Then work out from there with the file, raising the oxidation layer from below. It's much easier this way and you won't dull your file so easily. When your file clogs up, clean it with a file card.
I always thought that hard layer was work hardened. Harder just from being pounded. Oxidation causes this? Is this just on rusted heads?