This submission looks at the principles around consumer protections in the energy market and argues the case for a vulnerability-based approach to consumer protection. A balance is sought between requiring adequate consumer protections and reducing barriers to innovation. The paper suggests that in the forthcoming review of the National Energy Consumer Framework (NECF) consideration be given to developing an enforceable energy-related code to complement the Australian Consumer Law (ACL), rather than amending the NECF. In terms of defining categories of energy services (new and emerging, the suggested categories are grid-connected, behind the meter or off-grid.