A specific regulatory approach is needed to adapt to reflect the new reality in which the role of DSOs is increasing significantly. The Network Code on Demand Response is key to fill an existing gap in regulation and simultaneously it needs to be framed to complement (and not overlap or infringe) existing legislation. Demand response is a relatively untapped area that has been emerging, in part as a result of the rapid development of distributed energy resources and two-way energy flows. This part of the power sector is only partially covered by the current EU legislative framework and this framework will need to change in the coming years. Regulatory certainty and simplicity are key for market participants. We recommend a legislative analysis of the existing network codes and guidelines (in particular the Demand Connection Code, CACM, the Electricity Balancing Guidelines, and the System Operator Guidelines) and the development of a clearer definition of what is in scope for this Code and what is under the scope of other pieces of legislation. There should also be a better understanding of the foundational elements to be tackled in this Code which are not already covered elsewhere. This Network Code should be more focused on the local market and flexibility services in its specific provisions, while identifying needed revisions topics under the scope of other existing network codes. This Code must not exclude any resource provider as the main aim of the new rules shall be to ensure access to all electricity markets for all resource providers (FG paragraph 4).The current draft Code must include load, storage, and distributed generation (aggregated or not), however, generation in particular is missing from the definitions and key articles throughout the Code.