Many people claim the Studio is completely silent even though it has always-on fans. Those people need to be ignored. My opinion is based on the fact that many of us have tried multiple, in some cases 5 or more, and we are able to hear the whine on all. You would think that one of them would be like what the majority claims.
I'm not sure ignored so much as understanding that their environment probably washes it out. But, it's definitely audible with a moderately quiet space (probably most home offices and somewhat fewer workplaces).
In my home office (tends to be in the low 20s dbA) background noise, the M1 Studio was always audible from a normal operator position, and from further, too. The whine was audible until about 50 dbA background noise, which was very rare here. Under more normal background noise, it was immediately noticeable from the hallway (with the door open).
I never cared about the fan noise (excluding the whine). It was on the loud side, but pleasant enough (I tested that by using a recording to drop out the whine and listening to what was left). But, the whine was very disruptive. I returned it, got an equally-specced MBP14 (probably should have gone 16) as a desktop laptop (M1 Max/32 GPU/64GB RAM/2TB SSD, and carried on.
I'm interested to see how the M2 Studio experience shakes out for people who buy it. The studio design (without the whine) is pretty much exactly what I want in a Mac.