Setups for hardware decoding are based on the underlying OS. An example quite common is docker on Debian or Ubuntu. You will need to pass the appropriate /dev/ directories and at times files into your jellyfin docker container with the device environment variable. Commonly that would be /dev/dri

It gets more complicated with a vm because you are likely going to be passing the hardware directly into the vm which will prevent other devices outside the vm from using it.

You can get around this by placing docker directly on the os or placing docker in a Linux container with appropriate permissions and the same devices passed into the Linux container. In this manner system devices and other services will still have access the the video card.

All this to say it depends on your setup and where you have docker installed how you will pass the hardware into jellyfin. However jellyfin on docker will need you to pass the video card into the container with the device environment variable. Docker will need to see the device to be able to do that.