I don't think it is a requirement of MFM/RLL drives for PC and compatibles; more of a recommendation.
For example, in the Seagate document 'ST-506 MICROWINCHESTER SERVICE MANUAL MAY 1, 1982' is the following:
"Thermal isolation of the stepper and spindle motor assemblies from the disc enclosure yields a very low temperature rise within the enclosure, providing significantly greater off-track margin
and the ability to immediately perform read and write operations after power up with no thermal stabilization delay."
So, when the drive is cold, the heads-to-platter relationship is not normally where it is (normal: when the drive is at normal operating temperature), but it is still within the 'capture range' of the drive.
If I am low-level formatting an MFM/RLL drive, ideally, I want to do that when the heads-to-platter relationship is where it is in the vast majority of its powered-up (operating) time. So I always low-level format after a warm-up period.
Similarly, if I am testing an MFM/RLL drive, ideally, I want to do that when the heads-to-platter relationship is where it is in the vast majority of its powered-up time.