If you are trying to format a driver on Windows and the drive is larger than 32GB in size, then FAT32 will not be provided as an option. You must format it as FAT32 on a non-microsoft system or use a utility (such as a partition manager) to format the drive as FAT32.
there are rigt now 4 members of the FAT famility, FAT12 (for floppies), FAT16, FAT32 and exFAT. Each has a different infrastructure and file organization. FAT32 uses a 4 byte field for file lengths and can’t support more than 4GB file sizes (actually 4GB less a few bytes. exFAT uses a byte length, and can support 16EIB file sizes, however the largest file system size is slightly less than 128 PIB, so you can never reach the maximum file size.
If Apple did not fully implement the exFAT according to specifications, this will casue an issue in Windows. As part of the exFAT specification, the file drivers will inspect the integrity of the filesystem as well as compatibility before a mount, otherwise if the check fails the FS should not mount. The FS has checksums all over the place, and if a checksum is bad or not computed properly, the FS should fail to mount.