Only if they are using an insufficiently smart compiler. SBCL handles TCO just fine, as do a number of other implementations, see : https://0branch.com/notes/tco-cl.html
If it's not encoded in the language's specification, it's not a feature of the language but just an optimization. You can't rely on optimizations for correctness.
Even SBCL doesn't do TCO at all times. Compiling at (debug 3) means no TCO.
Another related footgun is deep recursion of other kinds, for example when recursively traversing down lists. For long lists it's easy to exceed the stack size limit. The common idiom is to recur on list elements, but iterate or map to go along a list.