I believe that is largely true even if they shipped a game on the cart. Many games ship broken, and they also change many times over the course of their life. I don't think official media can be considered any part of a future accessibility strategy for at least a decade now. Game keycards don't change that fact in any way.

It can be a part.

Games shipping broken and needing day-1 updates is a consequence of our indifference towards physical media dying.

On the Switch and the Switch 2, I’ve never had a physical game that didn’t let me skip updates and play offline.

Probably due to a mix of Nintendo actually reviewing retail releases before they are “pressed”, and due to the fact that these are portable devices with no cellular.