Motorola recently launched several phones with no Android updates but five years of security patches in Europe.
This could be due to the company’s interpretation of EU regulations regarding software updates.
It seems like the regulations don’t actually force smartphone makers to offer software updates at all.



Wrong, keep reading. You only quoted (6)(a). Now go and read (6)©:
As soon as a security patch is published in AOSP they now have 4 months to roll out an update.
Yes… and it also seems to me like (6) (d) would prevent Motorola’s policy of only providing security updates:
But the language here is quite tricky… I’m not 100% sure that points © and (d) force a manufacturer to provide updates under point (a) if Google updates AOSP.