In general, MP3tag knows only the current file to be treated by an action. There is no comparison between this one and possible other files.
If a filter could be applied by an action it would be applied to the current file - which then could lead to the effect that the current file would disappear from a list - and you would perhaps get error that there is no file to be treated.
The current implementation, BTW, does not allow to apply an action if there is no file selected and no file to be selected - as no file matches the criteria.
The only way around is to either write a lot of $IF statements which are fairly hard to maintain - or use the far superior function of the filter that tells you if you got the criteria right immediately and not after the unsuccessful treatment of numerous files (which also may be misleading because you think that you treated the files but in fact none or far fewer than expected have).
But there have been so many changes in the recent time. Perhaps this feature is long planned.