Presumably you refer to the iPad's on-screen keyboard. If so, you are correct - there is no Command ⌘ Key - as this keyboard modifier is unnecessary in normal usage with the iPad's touch-keyboard.
If instead you are using an external (physical) keyboard, these keyboards do include CMD and ALT keys - the style and key-layout being determined by the country and platform (generally Windows PC or Mac Computer) for which they are generally intended for use.
With that said, Apple does invite submission of comments and feature requests via its Product Feedback portal. If you feel that iPad and iPadOS would benefit from considered improvements, this would be the most appropriate channel through which to submit your request to Apple:
Feedback - iPad - Apple