NRVO requires the compiler to analyze the flow, like if 2 different variables/constructions can lead to the return (what one do we take, or can we do either later?).
Also, with RVO it's easy to detect and elide destruction calling for things going out of scope whilst NRVO would require more careful management of destruction order,etc.
Basically, NRVO touches a lot of things in "inconventient" places that can easily require reworking internal compiler structures to track destinations whilst RVO was probably far easier to just "hack in".