Fun fact: the FAT32 limit - which, by the way, was literally just added by Dave Plummer because he thought anything larger would have too much wasted slack space - made its way into the SD card spec. It is perfectly valid behavior for a device to refuse to read a >32GB card with a FAT32 file system, or a <32GB card with exFAT, or a card with multiple partitions, etc. None of those are actually SD cards as they are formatted.

In practice, nobody in their right mind would design a device's firmware that poorly, unless they were deliberately trying to force users to stay within the bounds of the device's QA test procedures. I don't have any examples of this. There are devices that will misbehave with such a card, however: for example, the Nintendo 3DS will happily use an oversize FAT32 card, but the Data Management screen will take way longer to load for some reason.

Also fun fact: the first time you plug a correctly formatted SDXC into a Nintendo Switch, it "downloads an update" and restarts. Presumably Nintendo wanted to save money on exFAT licensing fees so Nintendo is only paying for each unit that actually uses the exFAT library?