BIOS updates are required for most SGX-related microcode updates, as the microcode has to be up-to-date before enabling the SGX feature via
a MSR (which is usually done by the BIOS). This is so you can't start an enclave with old microcode, exploit it, upgrade microcode, and still pass remote attestation.
Also, the more major spectre-related microcode updates have to be applied very early (in the BIOS) probably for technical reasons. For this latest microcode update, for example, Intel didn't even include it in their downloadable microcode package as you linked to. On my v6 Xeons, I was able to get to revision 0x84 with the latest OS microcode package, but 0x8e with a BIOS upgrade.
Also, the more major spectre-related microcode updates have to be applied very early (in the BIOS) probably for technical reasons. For this latest microcode update, for example, Intel didn't even include it in their downloadable microcode package as you linked to. On my v6 Xeons, I was able to get to revision 0x84 with the latest OS microcode package, but 0x8e with a BIOS upgrade.