verify that new software can be legally loaded into a device to meet these requirements
And this is the required means, that the router vendors prevent loading of software that does not meet the desired ends. Previous documents instead specified that DD-WRT not be loaded.
The FCC document is no longer available: please see http://web.archive.org/web/20150803065407/https://apps.fcc.gov/kdb/GetAttachment.html?id=1UiSJRK869RsyQddPi5hpw%3D%3D&desc=594280%20D02%20U-NII%20Device%20Security%20v01r02&tracking_number=39498
It is cited in https://via.hypothes.is/http://www.wired.com/2015/09/hey-fcc-dont-lock-wi-fi-routers/