manufacturers who are approved by Microsoft can bypass the TPM requirement for certain types of systems.
Microsoft stirred up a lot of confusion following the Windows 11 announcement by listing TPM 2.0 as a requirement to run the operating system. Originally, this seemed as a requirement mostly focused on manufacturers, as Microsoft has required TPM on Windows 10 for the past few years. However, digging into the detailed system requirements reveals that manufacturers have a lot of flexibility with TPM. As discovered by Tom’s Hardware, page 16 of the Windows 11 hardware requirements says that “upon approval from Microsoft, [manufacturer] systems for special purpose commercial systems, custom order, and customer systems with a custom image are not required to ship with a TPM support enabled.” Relaxing the requirement for manufacturers makes sense.
