That would be on Arris (at this point, the CPE devices are under Vantiva ownership), not Comcast. Arris has to submit (and pay) for the Kyrio testing/validation (along with Arris having to engage/pay their own staff to work the process).
Only offering new capabilities on new devices (so you have to purchase a new device and indirectly pay for the new development) is not exactly a new thing in any industry. It is, however, annoying when you know the old device is/should be capable. Some manufacturers choose to offer licenses to upgrade to new capabilities, or offer generous trade-in allowances to upgrade, either of which can soften the blow a bit, but Arris (which reportedly was not in great financial shape, which is one reason CommScope sold the home network division to Vantiva) has chosen to do neither. The early adopter penalty hits again.
