From the HMRC P11D guide:
When don’t you need a form P11D?
You should not complete a P11D if there are no expenses payments or benefits to be returned for an individual.
You should not complete a P11D if there are no expenses payments or benefits to be returned for an individual.
If she was on the payroll, they should have ticked the box on the last PAYE submission to indicate no P11d was due.

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