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

https://www.bookmarkingvictor.win/receiving-a-dpn-is-a-critical-moment-for-any-sme-client-crucially-the-21-day

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