NTFS would require a whole new driver and it's not a part of the Nintendo OS. Using NTFS in an operating system also requires a license from Microsoft.
This would be a huge undertaking and I don't expect it to happen unless Nintendo officially supports the format in the future.
NTFS only requires a licence from Microsoft if you want to use the official driver. There have been open source linux drivers for NTFS for quite a while. That being said, implementing them into Horizon, or SXOS for that matter would probably require modifying the kernel, which is patched in ram using current methods. If we wait long enough for Atmosphere devs to finish Mesophere it might be possible to add support there, but that might be a while, as the atmosphere devs have been tackling the 6.2.0 problems with the TSEC key(Which looks promising, as they have been commiting all sorts of patches for just that.)