In order to become an indie developer on Nintendo platforms, certain requirements must be met. For instance, a dev must maintain a dedicated business place. Studios can't receive kits without meeting this criteria.
Interestingly, it seems that Nintendo could be abandoning the requirement.
Take a look at this tweet from Nintendo of America’s Dan Adelman:
The tweet above coupled together with others rumor suggest that Nintendo may allow indie devs to make titles for its platforms without having an office space. That would only lead to a better situation for fans - it means more games!