21 days
Both notices run on a 21 day clock
Lender Briefing - ATO Enforcement - October 2026
For credit, workout and portfolio teams
A Director Penalty Notice and a Direction to Pay are routinely confused, can arrive in close succession, and each changes how a board behaves over the following 21 days. This briefing sets out how the two notices differ and what they tell a lender about the borrower.
Authors: Brendan Richards and Claire GaffneyPublished 27 October 2026
Download the briefing (PDF)
21 days
Both notices run on a 21 day clock
84,000+
Director Penalty Notices issued to directors in FY2024-25.
$1.73bn
super guarantee charge raised by the ATO in 2024-25
01The two notices side by side
02What the notices tell you about the borrower
03Six questions worth asking this week