"In general, VDM and similar technologies do not satisfactorily run most older DOS games on today's computers. Emulation is only provided for the most basic peripherals, often implemented incompletely"
"The 16-bit real-mode system files are stripped down derivations of their MS-DOS 5.0 equivalents IO.SYS, MSDOS.SYS and COMMAND.COM"
Quoted from
https://en.wikipedia.org/wiki/Virtual_DOS_machine#NTVDM
Haven't compared myself, but according to Wikipedia, no.
Nigel