Like what happened when FW 3.61 was released, new games will not immediately ask for the new firmware. This is because physical cartridges are flashed days or weeks before release due to shipping. Digital-only games may be updated to require the latest FW quicker but this isn’t always the case. For example, Minecraft (v1.49) kept on supporting FW 3.60 until late May 2017, a whopping 9.5 months after FW 3.61 was released.
Looking at what happened in Aug-Sep 2016 when FW 3.61 was quite new, I was able to conclude that games released a few weeks to a month after the new FW have a good chance of still requiring the previous FW. Keep in mind that FW 3.61 was released on August 8, 2016 and the following were released after that date but only required FW 3.60:
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