ABCDFV posted this on another thread.
Well you could format emuNAND, create a new emuNAND, and update it to like 8.2 using a ROM which includes that firmware update. You wouldn't be able to play anything online or use any online features, but at least you'd have access to playing all 3DS ROMs released thus far. Then you'd just need to wait until Gateway updates their loader to work with 9.3.
So I formatted my EmuNAND nad everything is back to 4.5. However when I re-run gateway and attempt to play Super Smash Bros, it's not asking me to update my firmware... instead I can only play the game and get a black screen :/













