An employer has provided a company car to an unpaid director in 2022/23. They do not have a PAYE scheme and are trying to report the BIK and so will need to apply for, and open, a PAYE scheme for 2022/23. When they open the PAYE scheme, will the employer also need to submit 12 nil RTI submissions for the year? Will this trigger an automatic penalty from HMRC? Will the employer need to continue making RTI submissions for 2023/24 and onwards?