My initial thoughts were that photos should have to be updated when the papers are updated from temporary to permanent, but then I got thinking what difference does it really make? When we get Shetland papers, they have foal photos on them and since they don't have temporary/permanenet papers for the ponies, the photos they are initially registered with are the photos that stay on the papers for life. If foal photos are good for ponies then I guess they are good for Minis too.
I'm not going to bother updating any photos if it will cost me $20 to do so. I have two Minis to bring permanent this year & I don't know if I will send in photos or not. Partly it depends on whether or not we get around to taking some photos of these two horses--if we don't fit that in, they can just keep their foal photos.
Personally I am not a fan of photos. They help in the case of pintos or appaloosas (except where the appy "greys out") but as far as using those photos to identify horses, it's far from wonderful. If someone raises 10 or even 5 black (for instance) foals, unless those foals have some white markings, one black foal looks a lot like another black foal. People have joked that they're going to go out & take some photos of one foal & print a bunch up & send them in for all their foals of the same color. Could happen. I sent in permanent photos once (papers already had photos on them but the 3 year old photos were better) & they did put the new photos on the papers, but they changed the markings completely--gave my flaxen chestnut with no white (which was quite obvious on the earlier photos) 4 white legs (new photos showed him with the light gold legs that flaxen horses often have, quite clearly they were not white) on his permanent papers. What got me was they would do such a major change (from no white to 4 stockings!) without question. They did fix it up when I called to complain but it meant more postage to return the papers, and more wait time to get them back again. That pretty much put me off of updating photos--it's just a whole lot less hassle to not bother.
Bad registration photos? What does it matter, no one sees them anyway now that they aren't being posted on horsestudbook and the stud book on line doesn't include photos. If you send copies of the papers into a show, well, even if they've got bad photos on them everyone sees the real horse at the show. If someone buys the horse and you give them the papers, they've already seen the horse as it really is, so they know the horse really doesn't look like its registration photos.