ET> I have that VKBD.SYS file in \OS2\MDOS in my boot partition, but it is
 ET> not listed in config.sys. The virtual driver VKBD.SYS is loaded (I
 ET> checked with Process Commander) so I assume it's loaded silently?

There are two sorts of VDDs, "base" VDDs and "installable" VDDs.  The "base"
VDDs are always loaded, since they are essential to the operation of a VDM. 
The "installable" VDDs are the ones listed in CONFIG.SYS .

There's a list of the "base" VDDs in the Virtual Device Driver Reference in
the OS/2 DDK.

 ¯ JdeBP ®

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