All three commands of the interaction module involve performing a scroll into view in case the element we want to interact with is not in view.
However, even with behavior instant, the document handles scrolls in a queue, so there's no guarantee the scroll is synchronously executed, and that a corresponding scroll event is emitted in the page. If the test page has some logic attached as a listener to the "scroll" event which is necessary to make the element in view (eg changing the visibility of the element or its parent), then we would need to wait a bit after the scroll in order to perform the next is in view check.
This originally came from https://bugzilla.mozilla.org/show_bug.cgi?id=2014538, where the tested application uses a panel list widget which does react to the scroll event. Without waiting after the scroll, this application cannot use element click / clear / send keys to test their widget.
The current suggestion was to at least wait for the next animation frame. But we can have other strategies.