Visual Studio Code is a browser session for a complex website. I've had the OOM killer kick in on moderate C compilation loads -- well below what I subject my Linux daily driver to. I've even seen OOM when running Emacs for a long enough time on Termux on my cellphone.

In general, any long-running environment that can generate a lot of garbage presents a risk of triggering the OOM killer, especially when you have to share your development environment with effectively a whole 'nother OS. Enabling swap helps mitigate that risk.