The IRS specified which entities are required to submit a Nil report to the IRS for FATCA reporting purposes. Accordingly only Direct Reporting Non-Financial Foreign Entities (NFFE) have to submit a Nil report to the IRS. For all other entities, the submission of a Nil report is optional. However, this specification is only applicable for fulfilling the FATCA reporting requirements to the IRS. Following this, Reporting Swiss Financial Institutions and other entities (other than Direct Reporting NFFEs) subject to the Swiss IGA are currently not required to submit a Nil report to the IRS. Nil reporting may however still be required by a local government for entities located in a Model 1 jurisdiction.
For more information please refer to the IRS FATCA IDES Technical FAQs.