A document MUST contain at least one of the following top-level members:
- data: the document’s “primary data”
- errors: an array of error objects
- meta: a meta object that contains non-standard meta-information.
The members data and errors MUST NOT coexist in the same document.
You are correct that the spec does not say that you
MUST have at least one error document inside of the top-level errors key.