The short answer to your question is probably *never* since compliance generally refers to the drone itself or an external broadcast module that you would attach to the drone. I think it's probably better to refer to the smart controller as being updated (if necessary) to properly allow the drone to broadcast RID. Seems older equipment which may not include your mobile may be most vulnerable. Before DJI made their submission, approval should have been based on all components being capable; however, we all know the FAA is incompetent when it comes to administering this process and likely don't care if it all works or not; pretty sloppy if you ask me.
The Smart Controller cannot comply which means it will never get issued an official FAA Declaration of Compliance which you can look up here and let's hope this is never an roadblock in the future: UAS Declaration of Compliance