To maximise the capacitance per unit area, the dielectric between the bottom plate (normal metal interconnect layer) and the top plate must be a minimum. To maximise the BV of the capacitor, the dielectric material is usually nitride. So this requires that the dielectric and top metal are not part of the conventional metal stack where there would not be a MIM. The MIM top metal is much closer vertically than the conventional metal layers, so an extra layer just for the capacitor is required.