Do you have any actual reasoning for why the ruling might be different?
Because if there's some actual point we can address, we'll be happy to do so. But I can't see any reason why there would be a difference between the upgrade itself being an action or not. The effect is the same.
For the record, the FAQ really isn't that specific. We often have to take specific rulings for a specific card and extrapolate it to others. If you don't think it's going to apply for some reason, again, please state that. If it's just "It says action for this one but Isard isn't" then there's nothing anyone here can do to answer that for you, so just send it to FFG.
my thought would be that with an action header, its actually a separate action regarding the crit. Like expert handling is it's own action that allows you to barrel roll and remove a target lock. Same with r7-t1. They are their own actions separate from the action bar. Isaard and Jake on the other hand are conditions that when met may let you perform an action, but arnt actions themselves. (I think it could get sent for clarification, or my understanding of the cards are wrong. Could be that)