I recently built a Windows Server 2012 virtual machine to do some compatibility testing for a PowerShell script I was working on. I wanted PowerShell 3.0 to be the minimum version required for the script so it could be used with older versions of Windows. Since PowerShell is included as an operating system component, I needed an older version of Windows to use PowerShell 3.0.  Windows Server 2012 fit the bill.

After getting Windows Server 2012 installed, trying to check for updates returned error 0x80072EFE. Microsoft had updated distribution of updates, and the Windows Update Client installed with Windows Server 2012 is out of date. You must download and install the KB2937636 update. After a reboot, the Windows Update Client will install an additional update and then it will be able to search for and install updates.

These are the links to support article and update download.

Update to Microsoft Update Client (Support Article)

Update to Microsoft Update Client (includes links to update download for Windows 7 and 8 and Windows Server 2008, 2008 R2, and 2012)