I presume it checks sometimes, like probably roughly once a day or something...when it's awake. It can check for updates on lte. It just won't download an update until you connect to wifi.
You can force a check to see if there's a new update for you by going in the settings, on the page that shows updates. Note that this only checks if an update is available for your car, it doesn't force getting an update if your car isn't due for one.