I'll try to be more nuanced in my answer.
PIPEDA allows for implicit consent and requires explicit consent based on criteria that generally makes sense. Does it work? It all depends on whether meaningful consent is obtained, and people do come to us frequently to say, “Maybe the law allows for implicit consent, but I never understood that I was giving implicit consent for this or that conduct by the organization.” How this applies and what kind of information is given by organizations in order to obtain meaningful consent is the subject of my last annual report. It's a very open question, and I think many improvements would be required.
If I understand the question posed to me in terms of comparing CASL consent with PIPEDA consent, I concede that CASL consent is more onerous for organizations. Therefore, the PIPEDA consent regime could work if proper information was given to consumers, but in addition to that, I would suggest that you need to ask yourself, among other things, what the expectation of consumers is in terms of receiving unsolicited communications from organizations? That's the first question.
I don't have the answer to that question. Different countries have different answers, but one question is, what is the reasonable expectation of consumers?