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I think you should do it during a maintenance window.
I somehow sure that you cannot use Multi-Version Cluster (MVC) during update because SMS is running on the gateways (Full HA Cluster).
The upgrade process in R81.10 Installation And Upgrade Guide follows "Upgrading Security Management Servers in Management High Availability from R80.20 and higher" on page 215 (redirected from page 423).
Such, I would expect a downtime during upgrade.
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