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It's 2.
I forget where I saw it. Not in game at the moment. Somewhere it told me "As a duke you should only hold 2 duchy titles" or something along those lines. Not sure what it was for a king. It may have been on the tooltip for a warning about holding too many duchies?
Even worse is that having unnecessary vassals within several duchies will also make them "powerful vassals" with the -40 "not on council" modifier. Desiring the title is another -25.
And if a duchy doesn't exist, they also will be "not de jure" with another penalty.
So generally you only want to hold on duchies until you have a kingdom. Then get rid of them asap, in particular if you only have 1 county in them. Instead revoke / murder any unnecessary counts within your primary duchy to consolidate power for further generations.
However, there is no direct economic penalty like the domain limit, which represents the limit of what your character + steward can administer efficiently. So in theory you could live with a -25 opinion from vassals, but not with the crippling penalties from holding too many counties and baronies.
Just saying "yes" for the prestige now makes sense, but it's also a short sighted reward.
But on the other hand, having rebellious dukes is its own reward once they're in your dungeons...