In general, 9P2000 is simple and fairly elegant. If you don't need POSIX semantics (and fs metadata), it's really quite simple to implement. For a bit more cost in terms of complexity you can go for 9P2000.u which makes things POSIXy enough if you've got a single client (as you do with VM -> host). This is great if you want to provide virtual filesystems, either proxied from the host or backed by something more exotic. In addition to QEMU, the gVisor folks (https://gvisor.dev/) have made heavy use of 9P (with enhancements) for similar reasons (in addition to Google being generally populated with Plan 9 aficionados).

Then, there's 9P2000.L... This has that "let's just take the filesystem vtable and export it as a protocol" flavor. This works well enough on Linux if you're just looking to translate the calls over into syscalls. I wouldn't recommend implementing a bespoke server for it, though. You're better off just implementing things with FUSE.