According to that site linked, FlatpanelsHD.com,
"Technically QMS is a derivative of VRR so a device with VRR should technically be able to support QMS too (but it is not guaranteed)"
So all things willing, maybe a firmware update could enable it on TVs that "only" have VRR support today.
Would I be so lucky to receive such an update down the line, I might consider switching my A12 ATV into the A15 (though I feel that's a rip) just for this feature.
My TV's signal processor has automatic judder detection, aka it can detect 24fps content when fed from a 60Hz-source and adjust without any black screens. I think it internally refreshes at 120Hz when it's being fed 60, so as long as it catches the pattern it can just send each actual new frame 5 times and it will look correct.
25fps (PAL land..) on the other hand still needs this feature. I use my TV provider's ATV-app which is mostly great but all video feeds (representing channels) are of course 25 or 50 fps while switching between channels toggles a 60 fps UI mode. Lots of black screens.
To tack on, your tv would still need to support QMS. No tv currently on the market supports QMS
directly, but LG OLEDs—since the CX—support QMS by consequence a la firmware.
Two requisites must be met by your TV's firmware to indirectly support QMS:
First, your tv must have support for VRR (as many do). Second, your tv must also support LFC (low frame rate compensation) as a supplemental feature to the VRR standard. I'm sure many of you see the labels/tech specs when purchasing your TVs or reading up on firmware updates:
Support for 48Hz - 60Hz, or 48Hz - 120Hz, depending on the model.
Well, back in late 2021 LG added LFC support to the LG C1 via firmware update. Up until this point my Xbox Series X was still blacking out when launching a game in HDR10/Dolby Vision (with VRR enabled; all that good stuff), but post firmware update to the C1, the Series X became snappier—near instant—when switching from the Dashboard [SDR] to a game [HDR/DV].
With LFC, the LG C1 OLEDs expand their VRR support specification from 48Hz - 120Hz, to
20Hz - 120Hz.
In conclusion, if your TV supports VRR
and LFC then you'll be good to go when using your ATV 4K Gen 3 in regard to QMS when Apple updates it via tvOS "later this year"—granted you connect your ATV directly to your TV.
Edit: Seeing as how iOS 16.2 is slated for a mid-December release we can safely assume tvOS 16.2 will release in tandem with QMS support in tow.