1. Introduction Over the past thirty years, the Australian Human Rights Commission (Commission) has conducted inspections of immigration detention facilities in Australia.1 This has included national inquiries into immigration detention,2 thematic reports to highlight particular issues,3 and periodic monitoring of detention facilities across the country.4 In conducting inspections of immigration detention facilities, the Commission aims to assess whether these facilities and the treatment of those detained complies with Australia’s obligations under international human rights law. The Commission has consistently expressed a range of concerns about aspects of Australia’s immigration detention system and its compliance with Australia’s international obligations.5 In recent times, the Commission has raised specific concerns about the use of hotels as alternative places of detention (‘hotel APODs’) and has warned that they are not appropriate places to detain people for extended periods of time.6 This report records the key observations and concerns that arose from the Commission’s consideration of the use of hotel APODs in Brisbane and Melbourne, following inspection visits and interviews conducted in 2022. The Commission particularly acknowledges the contribution made by Dr Suresh Sundram, who assisted with these inspections as an independent medical consultant. Dr Sundram participated in the inspection visits and interviews alongside Commission staff, and provided advice on issues relating to health care and other medical issues concerning people in immigration detention. We also acknowledge the NSW Service for the Treatment and Rehabilitation of Torture and Trauma Survivors (STARTTS) for the training provided to Commission staff, and all of the individual staff at the Commission who assisted with these inspections. The Commission also acknowledges the assistance provided by the Department of Home Affairs (Department), and Australian Border Force (ABF) in facilitating the Commission’s detention inspections. The Commission team was assisted during the inspections by staff from the Department, ABF and detention service providers, and we are grateful for the assistance that was provided. In accordance with the usual practice, the Commission provided a copy of this report to the Department on 11 April 2023 to provide an opportunity for response to the Commission’s findings and recommendations prior to publication. The response from the Department was received on 23 May 2023, and has been published alongside this report. Since the time that this inspection was initially planned and then undertaken, the majority of individuals detained in hotel APODs have been released,7 and the average period of time spent detained in hotel APODs has significantly reduced. The Commission welcomes these developments and acknowledges the efforts to reduce both the overall number of people detained in hotel APODs and the length of time that they are detained. Even with this reduction in numbers, it is the Commission’s view that examining the past and continued use of hotels as APODs, and the impact this has had upon the people who were (or are still) detained, is important. It is our intention that this report will not only document the recent use of hotel APODs and help to improve current conditions and policies, but will also influence future policy decisions around the use of APODs in Australia. The Use of Hotels as Alternative Places of Detention (APODs) • 2023 • 7