P11D's - Micro Companies

I have couple of clients who operate through Limited Companies, and who regularly use

-  their own money to make company payments,

-  and the company's debit and credit cards to make private payments. 

I am reasonably happy that there are no taxable benefits as I do a fairly thorough audit as part of the accounts preparation, and post the private entries to credit/debit the directors' loan accounts as appropriate.

However, should these companies be completing P11D's - particularly where the directors have a company credit card that they are able to use, even though they reimburse the company?  If no tax due, could there still be penalties for not completing the P11D's?

I have been advised in the past (by HMRC) that where a director uses own funds to make purchases for the company, and assuming the purchases are made in the company's name, and a credit posted to the director's loan account, there is no need to report these on a P11D.