OK, so it seems the update was added somewhere between 8.1 and 9.2. I don't have a way to test anything in between due to the lack of being found on a retail cartridge.
On 8.1, it still lets you see the manual, and if you run it in Classic Mode, it does attempt to boot and just bootloops with the Nintendo 3DS on the top screen.
Updating to 9.2, it now hides the manual and refuses to launch.
What I find interesting is that under 9.2 emuNAND, Codename STEAM also refuses to run, even though that needs 9.4. Did the SDK really change that much between those two? I remember running Pokémon Y on 4.5 emuNAND, it booted fine, just no wireless features as those needed 6.x+