I've built a couple of kernel drivers over the years and what I know is that ".sys" files are to the kernel as ".dll" files are to user-space programs in that the ones with code in them run only after they are loaded and a desired function is run (assuming boilerplate initialization code is good).
I've never made a data-only .sys file, but I don't see why someone couldn't. In that case, I'd guess that no one ever checked it was correct, and the service/program that loads it didn't do any verification either -- why would it, the developers of said service/program would tend to trust their own data .sys file would be valid, never thinking they'd release a broken file or consider that files sometimes get corrupted -- another failure mode waiting to happen on some unfortunate soul's computer.