How does the FCC define a security flaw? Would updates only be distributed when there is a flaw that needs fixing?
Remote update mechanisms can themselves present security problems in some domains. Thus, some devices should only be updatable if the owner has physical access to the device. Will the manufacturer be liable for damages caused by attacks on vulnerable devices that were not sufficiently updated by their owners?
IoT is making its way into defense and enterprise environments where reliability is a matter of national security. An update nearly always results in some downtime for the device, even if it's just a couple seconds. Sometimes, it may be in the best interest of a device's owner to defer an update indefinitely, until that device's continuous operation is no longer mission-critical. Even if the owner can't control exactly what is in an update, they absolutely MUST be able to control when an update occurs.