I seem to recall having to give them a credit card number to activate the iPad, am I wrong on this? If so, that's a good incentive for them not to offer OTA updates, etc. It puts consumers in front of content for sale, at worst.
They could move the activation into an on-device app that launches on first boot before proceeding to the home screen. In any case there currently exist hacks for activating your iDevice from a Linux (!) box [1], so it clearly works without a credit card, additional restrictions imposed by iTunes itself notwithstanding.