Timer vs Comment required

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I have a Step with a "cancel" path. On this path I have enabled "comment required" => User always should enter a comment if he is cancelling the workflows.

Now I have a "housekeeping" timer in that step.
The timer exections an action (Change field value => [System]Comment) and has path transistion after action execution "cancel"

=> Timer throws an error: field validation "Comment" on path "cancel".

1. idea:
I make a special cancel-path for the timer => problems:
* I have more such steps => would result in many workaround paths
* Some cancel path do have flow-control behind, to determine the correct final step

2. Idea:
I disable "comment required" in that path and create a form-rule which checks if the user is a real user or the system-user. Then checking the comment => found no way (via form-rule) to check if the user has entered a comment or not. Could be doable via JS I guess, but want to avoid that.

Any solutions, ideas?

Thanks Ernst