>>maxmcd+Q63
That's correct. The initial versions of the microvm patch series did require KVM, but the one that got upstreamed does work with TCG [1], thanks to the QEMU's maintainers feedback.
That said, I'm not sure for which kind of use cases it would be useful to run it this way, as the performance won't be amazing. I find TCG acceleration mainly useful for debugging and foreign systems emulation.
[1] https://wiki.qemu.org/Documentation/TCG