There is a bigger picture to consider...
For the reciprocity theorem, if an antenna has a low efficiency in
transmission, it has the same efficiency when receiving.
Just to be absolutely clear about this: you can have a very good and fairly efficient receiving "antenna" that makes a very poor transmitting antenna. Reciprocity theorum doesn't always give the bigger picture.
Consider ye old faithful ferrite rod antenna used in long and medium wave receivers: -

It is very good at collecting and funneling the magnetic part of the incident EM wave and is broadly used in a lot of radios. However, it makes the most abysmal transmitting antenna because it can only produce the magnetic part of the EM wave and the H field it will produce will disperse with distance at a magnitude of \$\frac{1}{d^3}\$.
Compared to a regular antenna like a dipole - it will produce E and H fields that disperse with a magnitude of \$\frac{1}{d}\$.
Consider also the quarter wave monopole (just as an example). Many are used that are much shorter than \$\lambda/4\$ but can work very effectively as a receive antenna because the output impedance they present to a radio receiver is highly capacitive: -

At \$\lambda/4\$ in length its impedance is about 37 ohms resistive and neither capacitive nor inductive. This is the traditional reasoning for using a quarter wave monopole. However, as length drops or required operating frequency drops the monopole becomes progressively more capacitive and the resistive part tends towards zero.
This is just fine for a radio receiver that operates on a certain band - it can use an inductor to form a good front-end bandpass filter and it doesn't care about the resistance being low.
However, that resistance is important for a transmitter - it represents the resistance of the transmission medium (modified by the antenna from the 377 ohms of free-space to 37 ohms electrical). That resistor is what you want to push your PA power into and, if the antenna is "short", you are rapidly battling to put power into a 1 ish ohm resistor while coping with antenna losses (also about 1 ohm). So immediately you are losing out on power transmitted.