From code comment:
/* Geometry instances do not support motion blur correctly yet. The #key used in * #motion_blur_deform_data_get has to take ids of instances (#DupliObject.persistent_id) into * account. Otherwise it can't find matching geometry instances at different points in time. */
For 3.1 we should find a better way to support motion blur for geometry instances (which can currently only be created with geometry nodes). Fundamentally changing how the mapping of objects at different times works for 3.0 seems a bit risky now.