Require confirmation modal on submit action

Is it possible to trigger a confirmation modal from an action that submits a form? Adding requireConfirmation() appears to have no effect if submit() is used. The docs only mention it not working when using a url() action, but I assume the same is true with a submit() action? Reading through the source of Action, MountableAction, CanSubmitForm and CanOpenModal, I've not been able to figure out why it's not being called so far.
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