I have never seen a BIOS that didn't allow offline updates? However SSL is much less processing then a WPA2 WiFi stack, I would certainly expect this to be fully secure and boycot a manufacturer who failed. Conversely updating your BIOS without worrying if your OS is rooted is nice.
Updating your BIOS without worrying if your OS is rooted can be easily and more securely done from an USB memory.
The BIOSes recent enough to be able to connect through the Internet normally have the option to use a USB memory from inside the BIOS setup.
Some motherboards can update the BIOS from a USB memory even without a CPU in the socket.