Before making an MFT replica one should decide whether the holes will be used for indexing or as clamping/workholding holes only. If second is your answer, simply take a ruler and a square triangle, mark approximate holes and use a router with a 20mm boring bit. It will satisfy the purpose fully.
For indexing, it's obviously different.
Contacting your local CNC shop to manufacture a tabletop is the best solution.
Second best will be using the largest template possible. MFT/3 table top will work great for that because it has been made on a CNC. As it was pointed, MFT tops can vary in hole diameter, but not within one tabletop. When deciding upon the diameter of our Precision Dogs, I have visited multiple dealers in the area and took measurements of the holes in over a dozen MFTs. It was done 8 years ago, but I doubt that Festool has walked back on it’s quality control. To support my assumption, we would hear complaints about the fit of our dogs if that would have been the case, and there has been none.
Why use MFT as a template? Simply because of its size. You will have to reposition it the least amount of times and keep a setup error to a minimum. Every time a template is moved, setup error will be accumulated.
Assume you have a 4x3 hole template with a starting point in the bottom left corner going from left to right. Your initial 12 holes will be dead on relative to the origin. When the template is moved, your origin changes ( the last three holes on the right take its place). There is always some play in dogs or pins (if they would be the exact size of the holes, you won’t be able to insert them) which adds an error. Move a template again, error builds up. If one is trying to replicate a MFT tabletop (10x7 holes) with such template, to reach the top right corner template has to be repositioned 7 times, so it will get at a maximum 7x setup error relative to the initial origin(bottom left hole).
A few years back we have done testing when we looked into making our template, and none has produced results which we would be able to call precise, thus defeating the purpose of making it.
Coming back to a large MFT fabrication. To get the best results one will need:
MFT top and a plunge router with dust extraction.
20mm guide bushing for a router base
½” boring bit or a metric equivalent
1” long ¼” flush trim router bit with an upper bearing or a metric equivalent
About 4 clamps to secure table tops to one another.
A couple of dogs that have shaft length longer than original MFT (our Precision Rail dogs with adjustable collars, for example)
To begin with, align the two edges of the MFT with the edges of your future table top and secure it using some clamps. Using a router with a 20mm guide bushing and a boring bit, place it in every hole and plunge it. After every holes has been done. Remove the bushing and swap the boring bit with the flush trim router bit. Plunge the router into a hole made by a boring bit and secure at the required depth. Turn the router on trace MFT hole with an upper bearing. Repeat with every hole.
Next, reposition MFT table top and align holes on the edges of the original MFT with newly made one using Rail dogs. Secure with quick clamps and repeat the above.
Making an MFT top with a “holly” rail, as described above, is a great option too.
I hope this long read will be found helpful
Jerry