The 21-day clock on a Director Penalty Notice starts on the issue date, not...

https://bizzmarkblog.com/does-delegating-bas-and-payroll-to-an-accountant-protect-me-from-a-dpn/

The 21-day clock on a Director Penalty Notice starts on the issue date, not upon receipt. You must distinguish between lockdown and non-lockdown status to properly shield your client from personal liability