When a DPN hits, the 21-day clock starts on the issue date, not the delivery...

https://www.lawyersweekly.com.au/sme-law/44139-what-solicitors-need-to-know-when-a-client-receives-a-director-penalty-notice

When a DPN hits, the 21-day clock starts on the issue date, not the delivery date. Misjudging the distinction between a lockdown and non-lockdown notice can be fatal to your client’s position