I think you mean the DCT firmware update but that was not a recall just an upgrade. Only applies if you got the double clutch tranny.
These days manufacturers will reprogram your car to workaround post-production design issues if they can without your knowledge to avoid a costly recall even if that means the car is not going to perform at the edge of its advertised capability. There have been filed lawsuits of owners around bi-turbo bmw engines before. But no known problem yet with the NA E9x M3 !
Good luck F80...