Yeah, I was gonna say I dual boot and I can’t recall the last time that Windows nuked my UEFI bootloader.

But back when Windows still did BIOS boot, it was like every major release without fail.

edit: Rewreading your post it sounds like you meant updating the BIOS as a whole and not BIOS boot, so that’s my bad. Yeah, I definitely haven’t seen your circumstance, I had that happen consistently before Microsoft embraced the UEFI style booting