Payrolling benefits, but not on payroll

Hi.
A director it's not on payroll. No salary, but has the medical insurance through the business.
Is this considered benefit in kind?
How to treat it in the light of the new P11D changes from 6th of April 2025?
Do they need to be on PAYE now, although zero salary?
Thanks.

Hi 
Mandatory payrolling of benefits will go live for the 2026/2027 tax year.
Please report the benefit on kind through a P11d if you have not registered to payroll this benefit for the 2025/2026 tax year.
Please see guidance at:
Payrolling: tax employees' benefits and expenses through your payroll and 
Confirming plans to mandate the reporting of benefits in kind via payroll software from April 2026
If you wish to discuss this further please see options at:
Employers: general enquiries.
Thank you.