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The AI units are suffering from this penalty as well.
There's a thread on the official forums: https://forum.paradoxplaza.com/forum/index.php?threads/confused-by-stacking-penalty-compared-to-hoi2.464500/
What you can do to increase your odds while keeping the amount of units in your attacking army the same is that you need to attack from 3+ sides (when on land) or use navy to bomb the shores (when doing a naval assault)
stacking penalty = 1 - (sqrt(8*units + 1) - 1) / (2*units)
{LINK REMOVED}https://forum.paradoxplaza.com/forum/index.php?threads/stacking-penalty.580760/
By this formula we get 33.33% stacking penalty for 3 divisions, 50% for 6 divisions and 77.78% for 36 divisions.
You need to maximize the quality of your divisions as only mere quantify is penalized. Also use tactics that increase your effective quality like using 3+ angles of attack. If somehow you can manage 6 angles of attack you get +100% on attack and defence which obviously is a gamechanger.
I always do try to encircle my enemies. Before even when I had trapped my enemy in a single province(fully encircled) and attacked from 5, 6 directions, my divisions suffered -75% of stacking penalty. So I thought I must have missed something but now I understand it's just part of the game you can't do much about.