It will be copied once per drawing, since the calls usually go:
1. RenderTarget::draw //constructed default or passed here as const&
2. Drawable::draw //copy here
3. RenderTarget::draw //the vertex overload, also takes by const&
Also almost all sf::Drawable classes that come with SFML modify it, I think just VertexArray doesn't. It's also 100% trivial to copy.
In theory and for the sake of C++ trivia: yes, it might be faster or it might be slower, but either way it doesn't matter.
It's not performance issue and will probably never be.
The actual OpenGL draw calls (which are some pretty old/legacy functions of GL) time inside RenderTarget::draw is dominating so heavily that it will completely dwarf this in any profiler.
It just doesn't matter. It's impossible to write a real life program which would be impacted by this change in any way.