I thought maybe he meant Lisps whose compiler isn't another Lisp, or maybe macros at a stretch ..
(2 + 3)
(- 3 4)
All are valid s-expressions. Only one is a valid Lisp expression.
When we parse an expression, we usually parse a textual representation into an object. If the object is meant / subject to evaluation -> then we call this a form.
Every character in a S-expression must be "dealt with at the reader level" (and produced at the printer level).
The term "S-expression" was originally in contrast with "M-expression", but that's a historic usage.