Fixed in Oracle Solaris SRU 33 (Hardware Management Pack for Oracle Solaris version 220.127.116.11).
For some Oracle SPARC systems, such as the T series and M series, the fwupdate list and update commands might not work with Intel-based network controllers after performing a hot plug of a controller device. For example, after a hot plug of an Intel-based network controller, if you run the fwupdate list command you might not see any Intel-based network controllers listed. If the fwupdate command cannot list the details of a device, it cannot update that device.
If you encounter this issue, you need to reboot the server in order for the fwupdate command to see and list details of Intel-based network controllers in the system.