Scholes, who was an integral part of Alex Ferguson's dominant United teams for almost two decades, was quoted by the BBC as saying there was a "lack of creativity and risk" in Van Gaal's team.
United exited the League Cup on penalties to second tier Middlesbrough on Wednesday, having failed to score in 120 minutes at Old Trafford.
"It's a team now you wouldn't want to play against because they're tightly organised," Scholes told the BBC.
"But it seems he (Van Gaal) doesn't want players to beat men and it's probably not a team I'd have enjoyed playing in."
United, who are fourth in the Premier League, failed to score for the second straight game against Middlesbrough after also drawing a blank against rivals Manchester City at home on Sunday.
Van Gaal's side have scored 15 goals in their 10 Premier League games this season, fewer than any other team in the top four.
Captain Wayne Rooney has scored only two Premier League goals this season, but Scholes defended his former team mate and said any striker would struggle in Van Gaal's team.
"The hardest thing to coach is scoring goals and creativity," he said.
"I was at the derby on Sunday and Rooney's movement was brilliant but when he's playing in that team there's no one prepared to pass to him. I think after 20 minutes you'd be tearing your hair out.
"I played with some brilliant centre forwards and I don't think they could play in this team -- the likes of Ruud van Nistelrooy, Andy Cole, Dwight Yorke, Teddy Sheringham.
"You don't get crosses into the box or midfielders looking for runs."
(Reporting by Toby Davis; editing by Rex Gowar)
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