Just wanted to give an update- I have a 2012 BMW X5 xDrive 35D delivered to me October 31, 2011.
It had 2011 Maps loaded.
I finally purchased 2012 Maps on eBay and was not sure if I needed the FSC Code- but I decide to try without it and it worked!
I had the engine running all the time (approx 2 hours) - but it took th eforst disc, then asked for second and third - then said it was done - but when checked version, the screen was blank (gave me a scare!)
But then I shut the system down completely and restarted again and the version came up as 2012.
All is working perfect.
I do not know which dates have the cut-off for Code free update, but mine had it.