Virtual Reality is uniquely positioned to enable multi-user interactions through embodiment in virtual environments. Beyond verbal communication, this embodiment allows for various modes of nonverbal communication, such as body language, facial expressions, gestures, and avatar design. Nonverbal communication plays a significant role in face-to-face communication and is especially relevant in inclusive education, where both the diversity of expression of the students and their various communicative needs can be better catered to with a wider range of available communicative means. To explore the current state of practices and perceived benefits of nonverbal communication in multi-user virtual reality learning environments, a systematic review was conducted. The review identifies 14 relevant papers but concludes that this area represents a research gap. A discussion of potentials for nonverbal learning highlights future directions to address this gap.