It don't understand how it's even legal to issue any firmware upgrade without filing the image itself, verified by checksum & detailed change log with the DoT.
Since firmware controls so many aspects of vehicle behavior, including many safety issues, any other procedure makes it too easy to issue malicious updates by 3d parties, and very difficult in investigate safety problems that may be related to firmware.
Just as it isn't legal in most cases to change a model's HW by the manufacturer without some kind of re-certification procedure (at least not in my jurisdiction), it should be the same for firmware.
I never ever install any software update on anything without a detailed change log -- as a SW professional for 40 years, I know very well that any change can introduce just as many bugs as it fixes, so if an update doesn't fix something relevant to me, the risk isn't worth it.
At least for a general-purpose operating system or application upgrade, it's not a life and death matter... It certainly is on a vehicle.