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

https://wiki-spirit.win/index.php/I_Resigned_as_Director_%E2%80%93_Can_the_ATO_Still_Issue_Me_a_DPN_Years_Later%3F

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