Yes, you would need to do this process for each frame, but at least that's only once per character, not once per character per costume.
Another possibility is applying color transformations only to certain colors, like blue for Marth (see sig, the skin tone is unchanged) and pink for Peach. I don't think this is easy at runtime for Flash with ColorMatrixFilter, but it wouldn't be too hard with a photoshop/gimp filter (or maybe shaders, which I know nothing about). Of course, this helps the manpower problem, but not the download size, to which there is another potential solution: Include only the base sprites in the download, and generate palette swaps clientside on first loading the game. Not sure how feasible that is, but it's worth looking into.
There's one last problem of characters sharing the same color in their clothes and body. Fox (white) is the only one to my knowledge. And Marth's hair.