As far as I know, 1) Windows 11 will run on hardware without a TPM if asked very nicely (and will run on hardware with the obsolete TPMv1 without much prompting), and 2) it indeed has an exception specifically for VMs, or at least had one around 21H2 from what I remember [it may have been removed?].
But also 3) Virtual machines can provide software-emulated TPMs (Hyper-V does, QEMU does, latest VirtualBox does) – although those won't have a valid EK (attestation certificate), but many things don't really care about attestation; they merely need OS-controlled storage without any of the DRM frills.
Specifically I suspect that Windows' TPM requirement is primarily due to BitLocker auto-unlock and/or Windows Hello (both the consumer FIDO2 one and the Business one), i.e. MS wanting to guarantee that those will be available on every system, instead of "may work if your manufacturer bothered to wire it up, I guess".
And neither of those features ask for attestation from the TPM; e.g. BitLocker just relies on the boot measurements unchanging from one boot to another, while Hello treats the TPM like if it were a classic smartcard.
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As far as I know, 1) Windows 11 will run on hardware without a TPM if asked very nicely (and will run on hardware with the obsolete TPMv1 without much prompting), and 2) it indeed has an exception specifically for VMs, or at least had one around 21H2 from what I remember [it may have been removed?].
But also 3) Virtual machines can provide software-emulated TPMs (Hyper-V does, QEMU does, latest VirtualBox does) – although those won't have a valid EK (attestation certificate), but many things don't really care about attestation; they merely need OS-controlled storage without any of the DRM frills.
Specifically I suspect that Windows' TPM requirement is primarily due to BitLocker auto-unlock and/or Windows Hello (both the consumer FIDO2 one and the Business one), i.e. MS wanting to guarantee that those will be available on every system, instead of "may work if your manufacturer bothered to wire it up, I guess".
And neither of those features ask for attestation from the TPM; e.g. BitLocker just relies on the boot measurements unchanging from one boot to another, while Hello treats the TPM like if it were a classic smartcard.