Hard to say, but possibly less since it's a still image, not a video, so it inherently corresponds only to a part of AV1.
No need to worry about these risks for using it though. You can never say that no patent troll will surface tomorrow for literally anything. That's not a reason not to use things.
> You can never say that no patent troll will surface tomorrow for literally anything.
Well I guess you can use 20+ year old standards when they exist.
AVIF supports multiple frames. It's a good replacement for animated GIFs.