Well a possible solution would be:
1. remove the due date from the edit screen.
2. Add a global transition using a screen with duedate and add to that transition a comment required validator.
so if someone wants to change the duedate he needs to use that transition where he has to add acomment.
I just tried to do this via global transition, but I've found no way to get this done as I decribed. Sorry for that. The only way is to use separate transitions for each status (where the duedate could be changed "In Progress" > "In Progress", etc. ). The different transitions (different IDs) however could have the same name (e.g. Change Due Date). So it would be depending on the number of statuses in your workflow more work to do than I originally expected.
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