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...
2014 F25 X3 M-Sport Carbon Black, Technology/Premium/Winter/Driver Assistance
2011 e92 335is DCT - Cobb, ETS IC, AFE DCI, BMW PS kit, M3 control arms, various cosmetic improvements RETIRED!
2007 X3 RETIRED!
2006 e90 330i 132k miles RETIRED!