The defining difference between Shards and Dawnshards is that Shards are Aspects, nouns defined by an adjective, that are heavily based on Intent and Being a certain way
Dawnshards are verbs, Commands that need a degree of Intent to drive them, and which are inimical to certain Intents
Shards seem to be driven by inherent aspects of an omnipotent God and fit with traditional attributes given to God.
Thus I agree that actions probably fit the picture for Dawnshards but probably on a more metaphysical level than Forces of Physics (which Rosharan Surges cover), either forces that define sapience, or life, or God.
I'm inclined to think the latter. Not what God (as he is imagined, whether you think one exists or not) IS (Honourable/Honest, Passionate - I still Odium is corrupted from his original Shard possibly by the act of attack on Adonalsium-, Preserving etc) and more on what actions set God apart.
In that regard, God is usually set apart not by what he can do (everything!) Or must do (nothing) but what cannot be done to God. After all, in the Cosmere these things WERE done to God and it made him God no longer, and the Dawnshards are what did this.
By some schools of thought, God is unchangeable - giving us Change as a Command. He also can't be Created, which I think might be another DS. He can't be Broken, which might be something similar to the Command used to do the Shattering we have seen, though maybe that's too simple given how all the DS were needed to Shatter Adonalsium. An alternative would be Bound.
And he can't be Understood.
I think Empathise/Understand/Know could be Hoid/Sigzil's Command, it fits the divine and "people" in general, it fits the Shattering (you have to understand Adonalsium or know how to break it to break it), it fits the characters of Hoid and Sigzil to a tee, and it fits their Torment imo - the more you understand the more you feel what they feel and the less able you are to harm them