Probably just the MOT guy being cautious but certainly worth doing. My front subframe was covered in surface rust and have just finished cleaning it up with a wire wheel brush on the grinder -
http://cgi.ebay.co.uk/100mm-4-TWIST-KNOT-WIRE-WHEEL-BRUSH-ANGLE-GRINDER-/220597768504?cmd=ViewItem&pt=UK_Home_Garden_PowerTools_SM&hash=item335ca6d138#ht_1544wt_991
Then treated it with rust converter, then anti rust paint and a black top coat - looks fab now:)
The subframe is quite thick steel but worth treating now especially if you plan to keep the car long term.
Yes that was the advisory I had on Slave's last MOT. I would do it but where's the fun in wire brushing when you can be driving around with your top down.