Based on the observation that with a stereo default device and the sub or buttkicker connected to that, the sub activates appropriately throughout gameplay, I observe that the sub 200Hz frequencies they need are present in the game
Further, with a 7.1 audio device and downmixing all channels to stereo then passing those to the sub/buttkicker, the sub frequencies are present in surround sound mode. Just not on the LFE channel where you would expect them to be.
To test this, I took a 3 minute recording of 'Introduction to VR' scenario gameplay with a 7.1 virtual sound device set as windows' default device*, Full Range disabled, and DTS:Headphone X off, and recorded all 8 channels to a WAV file.
I then loaded the WAV into Audacity and displayed the bottom 500Hz of each channel in spectrum analyzer mode. A (large) screenshot:
The WAV file is available here:
https://www.dropbox.com/s/irwiv2k4lfoh5ng/elite_snd_test_master 2017-10-20 at 08h32m27s.wav
Note that the 4th channel, LFE, which in a normal surround sound configuration is the only input to a subwoofer or buttkicker, only has activity in 3 places, corresponding to hyperspace start, end, and supercruise drop due to interdiction.
The other channels, however, contain significant amounts of activity (dock lift, collisions, port airlock force fields, engines, weapon firing and hits, explosions) in the 0-200Hz band which would generate nice bass or sub-bass effects if they were going to the sub or a buttkicker.
* This excludes audio driver or misconfiguration issues; however, to exclude an artificial issue with the Voicemeeter virtual device, I observed the same behaviour with the Realtek soundcard I originally opened the ticket about, and a separate USB sound card.