Most likely because it's taking pace into consideration, and the only way it can (semi-) accurately determine pace is by GPS.
It's all an estimation anyway. A real VO2max test uses a mask to measure oxygen uptake, and there's no way a watch can measure that. It's using an algorithm derived from studies of actual VO2max tests, and correlating your performance with the results of those tests to assign a value to it.
Clinical VO2max tests are done with steady-state cardio on calibrated equipment with known speeds, distances, workloads, temperatures, etc. The further away you get from that level of control, the less accurate the correlations are. If you're running in extraordinarily hot weather over a surface with varied elevation changes, that's going to skew the results. If you're performing HIIT/interval workouts, that's going to skew the results. If you're training at a much higher/lower elevation than whatever was used for the algorithm, that's going to skew the results.
The only useful thing about the VO2max "results" from any training watch (Apple or otherwise) is to take note of the baseline and monitor the changes over time - that will at least give you an idea of whether your cardiovascular fitness is increasing, maintaining, or decreasing. The results themselves may not be clinically accurate, but if it says 32.5 when you start training and 41.7 three months later, you know you've improved your cardio fitness.