It should when it's required by the NHTSA and comes along with mandatory reporting, notification, and deadline obligations, along with optional free on-site execution of the fix.

That's what makes it a recall. A software update is the mechanism, the recall is the "Tesla did something wrong and is being held accountable" part.

I'm not saying it shouldn't count as a recall, but for the consumer it's just an update.

I'm not sure there is a need for a distinction here, legally it is considered a recall whether or not it can be resolved with an update.

I meant the title of the article probably should have used the term "update". To someone like me who doesn't know anything about vehicles, I was totally confused to see Tesla "recalling" vehicles over software.