Yes. As far as I understand, the problem was that the requirement for a certificate is a per-request thing, but HTTP 2 can have multiple requests in flight over the same TLS connection at the same time and thus can't just renegotiate the connection when it comes up. There have been proposals to fix this, but nothing has gained the necessary interest and traction.
Servers can ask the client to fall back to HTTP 1.1 instead, and then use client-certificates there.
Servers can ask the client to fall back to HTTP 1.1 instead, and then use client-certificates there.