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Thanks for the answer.The answer isn't straight forward. Some users elect to use a certain BIOS for speed or stability gains they might have on a particular game for certain game-play sections. It highly depends on a case-by-case setup.
What endrift says isn't wrong. You generally won't see a benefit using an external BIOS vs the mGBA internal BIOS, on average/most of the time. The option to use BIOS are for those who codes their own / borrow a special built BIOS, trying to sequeeze a few extra FPS and what not.