It looks like every cartridge contains the required FW as an update.Is it true that any game cartridge that requires 4.1.0 will have the update on the cartridge?
Kirby is the only game that has the "^Update 4.1.0 on cartridge^" added in the list.
Then there's also this, but no mention of it on the list:
All games interacting with an online service require you to update. Look at how nintendo auth's your console to learn why that is the case.Could we add a list what games need updates to work properly(not online multiplayer) or to get free additional content?
Regarding day 1 patches that are needed to run the game: they are labeled as such in the list (see Kerby)