Form 5329 is not a federal tax return (Form 1040). If you are not required to file a Form 1040, then you don't need to file a NY tax return.
From the IRS Instructions for Form 5329 (2020): "If you don’t have to file a 2020 income tax return, complete and file Form 5329 by itself at the time and place you would be required to file Form 1040, 1040-SR, or 1040-NR."
