Because compilers can and have implemented sqrt in terms of rsqrt which is .. fun to work with. This also on SSE.
Every 754 architecture (including SSE) I've worked on has an accurate sqrt().
I'm assuming you're talking about with "fast math" enabled? In which case all bets are off anyway!
Or maybe the library you use...
FMAs were difficult. The Visual Studio compiler in particular didn't support purposeful FMAs for SSE instructions so you had to rely on the compiler to recognise and replace multiply-additions. Generally I want FMAs because they're more accurate but I want to control where they go.
Now, there is also often an approximate rsqrt and approximate reciprocal, with varying degrees of accuracy, and that can be "fun."