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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.
Six years ago Apple TV added support for playing 4K YouTube video:

https://9to5mac.com/2020/06/22/tvos-14-brings-support-for-st...

YouTube's 4K videos are only available in VP9 and AV1.

So the YouTube app on tvOS has supported at least VP9 for six years and I wouldn't be surprised if it supports AV1 today.