MPI is a standard: it outlines a particular model for message passing in a distributed system. However, it only gives a series of requirements: it does not actually include any code, nor does it specify how exactly these requirements need to be fulfilled. For example, take a look at this excerpt from the official MPI 2.2 spec (as of today):
A valid MPI implementation guarantees certain general properties of
point-to-point communication, which are described in this section.
Order Messages are non-overtaking: If a sender sends two messages in succession to the same destination, and both match the same
receive, then this operation cannot receive the second message if the
first one is still pending.
It then goes on to explain the rationale behind this requirement and provide an example, but says nothing more about the requirement itself.
An MPI implementation is a library that fulfills every requirement - like the one above - in the MPI specification. However, the standard contains absolutely no requirements as to what language constructs, OS calls, 3rd party libraries, etc can/can't/should be used. Occasionally, it will give advice to implementors, like this:
Advice to implementors. The implementation may keep a reference count
of active communications that use the datatype, in order to decide
when to free it. Also, one may implement constructors of derived
datatypes so that they keep pointers to their datatype arguments,
rather then copying them. In this case, one needs to keep track of
active datatype definition references in order to know when a datatype
object can be freed. (End of advice to implementors.)
however, these are still vague, very language-agnostic, and only recommendations: an implementation can ignore every single one of these advices, and still conform to the standard.
So yes, in essence it's similar to various implementations of a compiler. If a program takes valid source code for a language, and produces binary code that does everything that the language specification says it should do given the original source code, it's a conforming compiler for that language. Similarly, if you can use a library to pass messages in a way that doesn't break any rules of the MPI spec, then that's a valid MPI implementation.