Is a P11D and P11D(b) due in this instance?

I have taken on a new limited company client and I've noticed that the previous accountants ticked the box on the P35 Employer's Annual Return (for the year ended 5 April 2011) that a P11D was not due.  The Director was the sole employee.  However, in that particular year, his salary was a lowly £6000 per year.  But, in addition, he also received a car benefit of £7012.  Surely, both combined, means that both a P11D and P11Db (upon which Class 1A NIC of £897.54 would now be due) should have been submitted to HMRC?  If so, what penalty would now be due?  I am no PAYE expert, so I missing something here?