Ref T13242. Warn user that they'll need to MFA (so they can go dig their phone out of their bag first or whatever, or don't type a giant comment on mobile if their U2F key is back at the office) on the comment form.
Also, when they'll need MFA and won't be able to provide it (no MFA on account), stop them from typing up a bit comment that they can't actually submit: point them at MFA setup first.