A family of Microsoft relational database management systems designed for ease of use.
I've lost count of the number of subforms I must have created over the years which parallel what you are doing, but I must admit that I've never found empty space reserved for a vertical scroll bar to be visually objectionable. I have never come across an example of anyone resizing a subform control horizontally on the basis of the subform's recordset's RecordCount.
At the end of the day it all comes down to personal preferences of course, but I have never used a subform in datasheet view. Invariably in this context I set the DefaultView property to 'continuous forms'. I also set the DividingLines property to True (Yes), one consequence of which is that the space to the right of the bound control is occupied by these, so is not vertically unbroken when the vertical scroll bar is absent. Alignment of the subform control's boundaries with controls in the parent form is to my mind also a factor in the aesthetics of the interface.
You'll find an example as StudentCourses.zip in my public databases folder at:
https://onedrive.live.com/?cid=44CC60D7FEA42912&id=44CC60D7FEA42912!169
If you have difficulty opening the link copy its text (NB, not the link location) and paste it into your browser's address bar.
This little demo file illustrates several way to represent a many-to-many relationship type in a form, and the example for a conventional subform illustrates the above points. In the demo the few rows in the subform as it stands means that the vertical scroll bar does not show, but if the subform control is shortened it will show in some cases.