In this paper we prove that an isometric stable minimal immersion of a complete oriented surface into a hyperkähler 4-manifold is holomorphic with respect to an orthogonal complex structure, if it satisfies a Bernstein-type assumption on the Gauss-lift. This result generalizes a theorem of Micallef for minimal surfaces in the euclidean 4-space. An example found by Atiyah and Hitchin shows that the assumption on the Gauss-lift is necessary.