The FCC can not block firmware updates from being applied. They can declare them illegal after the waiver date, but actually blocking the updates would be a fruitless game of whack-a-mole for the FCC.
It doesn't really matter. Unless the ban is...
That order fixes a mistake in the original FCC order that had blocked firmware updates for pre-approved devices. They rushed out the blanket ban without considering that it had covered.
If you are looking for blame, that bill had broad...