The general rule is that NVME SSD tends to be faster than SATA SSD so it is a trade-off of cost v speed. For many purposes the difference may not be that noticeable.
it is worth noting that even using an HDD that is not part of the array (I.e. as a cache drive) will still provide performance advantages for docker/mv performance over having them hosted on the main array as the process of updating parity on the main array significantly slows down write speeds. It is just that for most people using an SSD is a better trade-off of cost v performance, and also many modern motherboards have slots for M2 based SSDs built into them.