Even though we got rom dumps floating around, we still can't tell what firmware update comes with that rom atm, very few sites will bring that up. Games with a firmware payload will only tell you it needs to update, it doesn't tell you what version it will update to. The majority of the games out there have been identified with what firmware payload they carry, but that information is what is scattered. If an online update of the 3DS firmware is done, it will always update to the latest version.
You can goto sites like
http://3ds.essh.co/ but they don't list what 3DS firmware comes with certain games. The last time someone asked about firmware updates coming with the game was back in 2011, when no games at that time had a firmware update with it.