The problem is the “submit” part. I.e. the docs say “xcrun aitool” but doing that gets some you an undocumented CLI app where it seems like you have to supply your Apple ID and password on the command line.
Seems... less than ideal? How does that work with 2FA?
It's for people who want to submit their app non-interactively (e.g. as part of a build process). Those people aren't going to use 2FA since the keys are under control of a robot.