This was my initial thought and a sentiment I've seen expressed elsewhere, but I think I'm missing something about how they'd implement this.

Sure, Rockstar can enforce a minimum software revision to launch the game, but couldn't some homebrew software just (a) lie about the software revision to any running game, or (b) apply any relevant software updates minus patching the kernel vuln?

It seems to me that the cat's out the bag now.

You need to get the game in the first place, which requires a console that’s authorized to download games from PSN.

I don’t know how Sonys attestation works, and how resistant it is; but presumably it’s a bit harder than “lie to the game about what firmware you’re running”.

(GTA VI will famously not have a physical release, so you can’t rip data off the disk.)