This edit https://commons.wikimedia.org/wiki/Special:Diff/309221779 holds the summary line "Imported with FileImporter from …". Technically, this is supposed to be a null edit with no changes, only with this summary line. But it contains two changes: The HTML comment `<!--This file was moved here using FileImporter from …-->` is added to the top, and the template replacements are made.
The next edit https://commons.wikimedia.org/wiki/Special:Diff/309221781 holds the summary line "Replaced 1 template names with Wikimedia Commons template names".
Another worst-case example: In http://mwfileimport.wmflabs.org/wiki/index.php?title=File:Stolperstein_f%C3%BCr_Lina_Speiser,_Br%C3%BCckenstrasse_11,_Bad_Cannstatt,_Stuttgart.JPG&curid=105&action=history the summary line "Replaced … template names with … template names" got lost entirely, because the edit was empty (the user did not made additional edits).
* The template replacements are clearly made in the wrong revision.
* The summary line gets lost.
* Shouldn't the HTML comment also be added in the next revision?
Reported at T194505#4391840.