Technically yes, but it would produce an untrusted remote attestation signature (quote). This is roughly equivalent to using TLS with a self-signed certificate — it’s not trusted by anyone else. TPMs have a signing key that’s endorsed by the TPM vendor’s CA.

We don't allow games to run in virtual machines and require TPM. Check TPM EK signing up to an approved manufacturer.

It is not "fake", a software TPM is real TPM but not accepted/approved by anticheat due to inability to prove its provenance

(Disclosure: I am not on the team that works on Vanguard, I do not make these decisions, I personally would like to play on my framework laptop)

Yes! https://github.com/stefanberger/swtpm