Don't count on it, at least 3 times my car has been returned without firmware being updated even though service order states that it was, I recently brought this up with my SA & he said some things on the service order are "boiler plate".
Visible Tesla shows your cars firmware version so when my service order was emailed to prior to pick up I was confident they had not updated again, so when I got there I had my SA check his computer & it showed my last update was a month ago so I then I had my SA call the technician & he confirmed they had a newer version available, we walk out to my car to double check the version or see if they had preloaded it but not installed & sure enough still my old firmware.
So the other times they didn't even bother to preload it? That's too bad. I've seen the update staged before and it caused some initial confusion for me too at first, but after I got back the car I realized what had happened.
I must say my last service at Van Nuys was exceptional. I literally had nothing to complain about. Too bad this doesn't apply to everyone, but perhaps it's a sign of things to come.