I suspect it's due to cost and licensing to use that particular brand and technology.
As far as I know Dolby Atmos can be seamlessly mapped onto to 5.1 or 7.1, so from the developer perspective there should be no effort/cost to provide Dolby Atmos audio. I might be wrong about this but I assume the licensing cost would be for the playback device and not for the 'right' to bundle an Atmos audio track with your game?