The playable character (PC) is the focus of attention and therefore gets disproportionate effort put into it. There is usually only 1, maybe 2-3 of them so making a 100 outfits for each PC probably means making a 100 outfits, maybe 300 in the absolute worst case.
If I remember correctly, a game like GTA San Andreas had around 300 different NPCs. So making just one second outfit for each (toggle, not slider) is extra 300 outfits. For most games, the effort is better spent either adding more outfits for players or more NPC types to improve variety (more gamers care about that than NPC sexualization). Or just bigger map, or more missions, etc. Of course it depends on the type of game.