see this earlier question for difficulties actually getting a repo doc embedded in Excel in Comment mode - Embedding of repo docs with Comment ability - why does it hang | Community
When you finally get the content embedded, and try and use the Add new comment button, a black popup message appears with the same content, but nothing else happens and there’s no way to add the comment. Nothing happens when attempting the Attach Debugger menu option.

I am the overall Process Accelerator admin, but not the repo/process owner, so it shouldnt be a permissions issue.
I also had a non-licensed user try the commenting feature without anything being embedded, ie they just opened a doc from a repo, and same nothing when pressing the comment button.