Synapse recently added some validation to /keys/upload (element-hq/synapse#17097). As a result of that, it turned out that matrix-bot-sdk was calling /keys/upload with device_keys: null.
Synapse has worked around this for now (element-hq/synapse#19023) but it remains non-spec-compliant behaviour on the client side which we need to fix. Synapse will begin enforcing this in a few months (element-hq/synapse#19030).