I found the problem. Documenting here for posterity.

I had a file in /etc/apt/preferences.d/ containing this:

Package: *                                                                      
                                             
Pin: Release v=18.04, -l=Ubuntu                                                 
                                             
Pin-Priority: 10 

I had added this a while ago to upgrade smartmontools to the version
from Bionic, but forgot about it. Removing this (commenting out these 3
lines) made the do-release-upgrade succeed.


** Changed in: ubuntu-release-upgrader (Ubuntu)
       Status: New => Invalid

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https://bugs.launchpad.net/bugs/1922401

Title:
  do-release-upgrade fails because it marks e2fsprogs for removal

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