My 10 year old iPhone 7 can play 1080p AV1 video in software for more than 200 minutes with VLC. The iPhone 7 was released a year and a half before AV1 was.
So I think it's a safe bet the current Apple TV devices are capable of playing AV1 video in software. There's a VLC release for Apple TV:
https://www.videolan.org/vlc/download-appletv.html
https://apps.apple.com/us/app/vlc-media-player/id650377962?p...
Not especially relevant, as the obvious use of AV1 on the AppleTV is streaming, and the OS frameworks don't request AV1 without hardware decoding. Services which provide their own video decoding (are there any?) don't seem interested providing their own software decoder for the ATV, despite the bandwidth savings.