Someone asked Dan Adelman of Nintendo on Twitter if it is was still true that indie developers needed an office to develop games on the eShop. Here is what Adelman said:
Ask me again in a couple weeks.
From what Adelman said it sounds like Nintendo is going to get rid of the requirement for indie developers that they need to have a physical office to be able to develop for the eShop. If this is going to happen then we may be seeing more eShop games coming out since smaller indie developers will be able to develop for it.