Aren't most recalls software updates now? e.g. "Toyota is recalling over 42,000 Corolla Cross Hybrid SUVs from the 2023 and 2024 model years to fix a software

Aren't most recalls software updates now? e.g. "Toyota is recalling over 42,000 Corolla Cross Hybrid SUVs from the 2023 and 2024 model years to fix a software error that may cause drivers to lose power braking assistance if they brake while turning a corner." I don't know that it makes sense for the distinction between "recall" and "not a recall" to be whether the software update can happen OTA or not.