Sure, in principle, compilers can combine certain repeated atomic accesses. But in practice, compilers respect the fact that intervening code takes a nonzero amount of time to run, and always try to load the latest value of the variable. (I am entirely unable to coerce a compiler into combining atomic accesses, even with memory_order_relaxed where it would theoretically be permissible.) Volatile accesses are the same in the sense that the compiler can move the rest of the code around it (and are known to have done so in practice): the only difference is that repeated volatile accesses can't be combined even in theory, and they can't be omitted even if the result is discarded.

What use case do you have in mind where this theoretical possibility would cause issues?