It needs 2 updates because..
the tech behind 3D gaming and 3D Blu-Ray is very different. I would have hoped a tech site would have understood that.
It's also been mentioned the PS3 HDMI implementation is being updated to support 3D, incorporating most aspects of HDMI 1.4 (all but the Ethernet support), as the HDMI chipset in the PS3 is much more firmware/software based than your average BD Disc player's HDMI chipset..