Embodiments of system, method, and apparatus for virtualizing TPM accesses is described. In some embodiments, an apparatus including a CPU core to execute a software program, a manageability engine coupled to the CPU core, the manageability engine to receive a trusted platform module (TPM) command requested by the software program and to process the TPM command utilizing a manageability firmware by at least creating a TPM network packet, and a network interface coupled to the manageability engine to transmit the TPM network packet to a remote TPM that is external to the apparatus for processing is utilized as a part of this virtualization process.