With Microsoft's permission, OEMs can ship Windows 11 PCs without TPM


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"Upon approval from Microsoft, OEM 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."

 

source: Windows 11 Minimum Hardware Requirements

 

https://download.microsoft.com/download/7/8/8/788bf5ab-0751-4928-a22c-dffdc23c27f2/Minimum Hardware Requirements for Windows 11.pdf

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There's always some exception out there.  Still it looks like if you want to upgrade to 11 from 10 or try to do a clean install, at this point, you won't be able to without TPM and the supported CPU.  

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