I asked my SA regarding this and he said that recoding is only needed if battery specs change. If it is a direct replacement, no need to recode your car. This applies to ALL BMWs...
2016 F80 M3 BSM with Black interior DCT/Driver Assistance/Executive/LEDs/Adaptive/Black Wheels
2014 F32 435i xDrive AW/CR
2014 F25 X3 M-Sport Carbon Black
2011 e92 335is 2007 X3 122k miles 2006 e90 330i 132k miles