No it does not.
I am running Windows 11 on secure-bootless Bios only TPM-less machines.
All you need is to replace applaiser.dll in Win 11 installer.
(this instruction says to replace applaiserres.dll as well but it is wrong. )
Then run regedit during the installation.
[edit]
Just found this:
Obviously, there is more than one way to accomplish the mission 