Phone OS has direct ability to query the manufacturer for updates and download them if available/requested by the user.
Works for Apple. (Until iOS 5 download to PC and install with iTunes was required but now phone can directly download.)
Works for Sony TVs (and probably many others too) that are connected to the internet. Broadcast (with digital TV at least in Europe) can also be used to update OTA but may need broadcaster approval. In this scenario using both approaches makes sense as not every TV is connected to the internet or broadcast signals.
A better question is how to make it happen. I would suggest that Samsung is big enough and their phones high profile enough that they should be able to insist and still have their phones offered by the operators. However they would need to consider it an important point worth arguing for and may have to trade something else whether it is price or customization support or something else.