But, although FAT32 does indeed have the virtue of relative simplicity, that's no excuse for VFAT.
FAT32 is a variant of FAT introduced in the mid 90s with Windows 95 OSR2 that better supports large hard drives (beyond size limits, cluster sizes were getting too large on FAT16 drives etc.).
The reality, certainly in respect of the headlined subject, is that the bitness of the FAT and the style of the root directory (fixed location or variable length) are the only meaningful variants. In 2026, no-one aims not to support long filenames on FAT, and EFI understands them natively. EFI copes with all three bitnesses. And it does the conventional thing of variable length root directory on 32-bit and fixed-length root directory on 16-bit and 12-bit.
FAT is a very poor filesystem format, and no, it's not a minimum filesystem format if one is writing one's own operating system. It's a lazy filesystem format, inasmuch as the cross-development tooling for it exists. But if one were writing a minimum filesystem for one's own operating system, one could start from much better places. FAT is not minimal by any reasonable definition even if one is not writing one's own operating system, and requires an awful lot of hoops to be jumped through that are only there because one is being compatible with the cross-development tooling, several decades of historical changes, and whatnot.
One could use the original UFS, for example. LEAN exists. Over 20 years ago, I invented HPFS2.
Given that normally UEFI only needs to read the filesystem, not write it, I think a more appropriate filesystem might be something like ZIP.