Apparently this error has something to do with Windows 95 not knowing what to do with today's super powerful CPUs (lol). I'm still reading this article by MS: https://support.microsoft.com/en-us/kb/263466
Well in virtualbox you can actually specify the type of CPU and RAM. If you allocate too much memory and anything too severe the VM won't run. KB263466 just deals with systmem device corruption. Also there are many different versions of 95, older versions will be prone to more issues: such as when I expanded a very old tower from 64 MB of RAM to 128 MB, 95 can't start anymore as a result. It can be fixed, but I'd have to remove the memory, patch 95, put the memory back in etc.
Said tower can expand up to 256 MB with SIMM modules! Very unique and (now) rare hardware.
But yeah, why virtualize windows 95 when 98SE is much easier.