Microsoft could have implementes the Docker API as part of WSL1 instead of loading up a real Linux kernel for it. That's how LX Zones on Illumos work for running Docker containers on non-Linux without hardware virtualization.
I'm sure it's tricky and hard (just like WSL1 and WINE are tricky and hard), but we know it's at least possible because that kind of thing has been done.
I think it was mainly the docker crowd that kept asking for compatibility there :(