Nigeria's Petroleum Industry Act 2021 (PIA) represents the most significant legislative intervention in Nigeria's oil and gas sector in over five decades. Among its most debated provisions are those establishing Host Community Development Trusts (HCDTs): a statutory mechanism compelling upstream operators to fund and engage with oil-bearing communities as a precondition for the maintenance of operating licences. This article argues that, despite the PIA's well-documented shortcomings, its structural architecture of mandatory community engagement offers a productive comparative lens for examining persistent tensions in Canada's duty-to-consult jurisprudence, particularly as that doctrine confronts the demands of the United Nations Declaration on the Rights of Indigenous Peoples Act 2021 (UNDRIP Act). By juxtaposing the Nigerian experience where decades of voluntary corporate social responsibility regimes failed to prevent conflict and ecological destruction against Canada's constitutionally grounded but procedurally contested consultation framework, this article identifies three critical design challenges shared by both systems: the consent-versus-consultation binary, the structural asymmetry between communities and operators, and the enforcement deficit that undermines good-faith engagement in practice. The article concludes that while Canada's constitutional foundation is normatively superior, the PIA's insistence on pre-project community needs assessments and trust fund structures offers implementation insights that Canadian regulators navigating energy transition could usefully adapt. Conversely, Canada's evolving doctrine of meaningful accommodation provides normative scaffolding that could strengthen future reforms to the PIA.