PSC Pension Declaration of compliance

Contractor trades via Ltd Company, pays himself salary of £732 per month (so below the £833 auto enrolment threshold).

Company was set up early this year. Neither Director or previous accountant have completed the Delcaration of Compliance with the pensions regulator and have therefore missed the 5 month deadline. No reminders have been sent to client.

I believe this declaration is a requirement even if his salary is below the threshold - is this correct? Are they likely to be more lenient on a PSC missing the deadline if they had no other staff and were paid below the £833 threshold?