There is a setting in the preferences Audio ID3 tab to "Write ID3v1 information".

This is great because the USB in my car only shows artwork for files with this setting.

However, it is only applied when the editing state has changed so I need to modify the file and save it to have these settings applied.

Can I do this directly via an action without having to modify the file beforehand?

You can do it in an action via Save - Save Files Always

You can also do it in the UI via File>Save Selected Files>Save Always