On the 3ds virtual console (as far as I know) there is no way to hard reset--making manips impossible to execute. But if you're not using manips it should be fine. (Also, if there is a way to hard reset on 3dsVC, someone please let me know!) Edit: I stand corrected. Soft resetting on virtual console acts as a hard reset for manips. But yea excellent points below by Pinkish.
Interestingly, standard Start + A + Select + B soft resets actually act as hard resets on 3DSVC. This would technically make it the fastest option due to the faster Bios screen, but due to a lack of an emulator for 3DS, manips are not botted, and thus must be manually found, often leaving something to be desired. I would personally just recommend using the Gambatte emulator.
i know i'm a bit late, but start+sel+a+b resets ARE actually soft resets on the 3DS VC (i tested). however resetting by screen tapping counts as a hard reset.
